Foundation Resource Management (FRM) is a fee-based, value investment advisory firm
headquartered in Little Rock, Arkansas. Greg Hartz and Mark Millsap are majority co-owners of FRM,
which was founded in 1992. FRM currently serves individuals, high net worth individuals, retirement
plans, charitable institutions, foundations, insurance companies, and hospitals.
As of December 31, 2023, FRM managed approximately $918,400,000 on a discretionary basis. No
assets were managed on a non-discretionary basis.
Clients may require that their investment portfolios be tailored to comply with, for example, certain
regulatory restrictions or restrictions on investing in certain securities or types of securities. FRM is
happy to accommodate our clients in tailoring our advisory services to meet their needs.
Engagement Limitations FRM does not provide financial planning and/or related consulting services
regarding non-investment related matters such as estate planning, tax planning, or insurance. FRM
does not serve as an attorney, accountant, or insurance agent, and no portion of our services should
be construed as legal, accounting, or insurance services. Accordingly, FRM does not prepare estate
planning documents or tax returns and does not sell insurance products. To the extent requested by a
client, we may recommend the services of other professionals for certain non-investment
implementation purposes. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over such implementation
decisions and is free to accept or reject any recommendation from FRM and/or its representatives. If
the client engages any recommended unaffiliated professional and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance
agency, etc.), and not FRM, shall be responsible for the quality and competency of the services
provided.
Retirement Rollovers - Potential for Conflict of Interest A client or prospective client leaving an
employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll
over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll
over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). If FRM recommends that a
client roll over his or her retirement plan assets into an account to be managed by FRM, such a
recommendation creates a conflict of interest if FRM will earn new (or increase its current)
compensation as a result of the
rollover. When acting in such capacity, FRM serves as a fiduciary
under the Employee Retirement Income Security Act (ERISA), or the Internal Revenue Code, or both.
No client is under any obligation to rollover retirement plan assets to an account managed by FRM.
Portfolio Activity FRM has a fiduciary duty to provide services consistent with the client’s best
interest. As part of its investment advisory services, FRM will review client portfolios on an ongoing
basis to determine if any changes are necessary based upon various factors, including, but not limited
to, investment performance, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time when FRM
determines that changes to a client’s portfolio are neither necessary nor prudent. Of course, as
indicated below, there can be no assurance that investment decisions made by FRM will be profitable
or equal any specific performance level(s).
Wrap Program Engagements FRM has clients who participate in wrap-fee programs with Raymond
James. Wrap fees are comprehensive charges levied by these institutions for brokerage services.
These wrap fees do not include FRM’s investment advisory fees. FRM clients who participate in wrap-
fee programs contract directly with FRM for investment advisory services. There are no differences in
the method that these clients’ advisory fees are calculated and the method that our other clients’
fees are calculated. FRM does not receive wrap fees for our services.
In the event that FRM is engaged to provide investment advisory services as part of an unaffiliated
wrap-fee program, FRM will be unable to negotiate commissions and/or transaction costs. Under a
wrap program, the wrap program sponsor arranges for the investor participant to receive investment
advisory services, the execution of securities brokerage transactions, custody, and reporting services
for a single specified fee. Participation in a wrap program may cost the participant more or less than
purchasing such services separately.
Client Obligations In performing our services, FRM is not required to verify any information received
from the client or from the client’s other professionals and is expressly authorized to rely thereon.
Each client is advised that it is his or her responsibility to promptly notify FRM if there is ever any
change in his or her financial situation or investment objectives for the purpose of reviewing,
evaluating, or revising our previous recommendations and/or services.
Investment Risk Different types of investments involve varying degrees of risk, and it should not be
assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by FRM) will be profitable or
equal any specific performance level(s).