Overview
AMTI sponsors two separate WRAP programs as described below.
Features of AMTI’s Portfolio Advisory Services (“PAS”)
PAS is a WRAP product whereby AMTI, as investment adviser, registered with the U.S. Securities and
Exchange Commission (“SEC”)
1 is the program manager. PAS is either a non-discretionary or
discretionary advisory program and is intended for customers looking for proactive and tailored
advice and where AMTI monitors the clients’ portfolio within a predefined framework. The Wealth
Advisors will interact with the client to manage his/her investments under the following rules:
The client’s Wealth Advisors (“WA”) will assist the client in clarifying their investment needs, including
but not limited to investment objective, tolerance for risk, investment experience, and investment time
horizon; and will provide professional advice for a single advisory fee. The IC will work with the client in
selecting the appropriate portfolio in an effort to assist the client in achieving their investment goals.
In non-discretionary PAS accounts, clients can buy/sell any security they wish in the account as long as the
client provides final approval on all executions. . Clients also agree that at all times the PAS account should
be within the limits of the selected investment style and grants AMTI authority to keep the account within
the investment guidelines of the client.
For discretionary PAS accounts, AMTI will actively manage the portfolio based upon the Investment
Guidelines agreed to by the client.
AMTI will provide certain types of monitoring of the PAS account such as maintaining it within its limits,
by using AMTI’s Supervision Compliance Manager trade surveillance software, ongoing monitoring of
positions in the account and contacting the client with certain regularity to discuss investments. Research,
advice, ongoing limited discretionary management and other investment adviser related services are
provided by AMTI. Execution services are provided by AMTI as broker dealer. Clearing, custody and other
brokerage related services are provided by the clearing firm and custodian, Pershing LLC.
AMTI offers Enhanced PAS in the form of a unified managed account (“UMA”). AMTI utilizes the
services of a third-party to assist in servicing the UMA accounts. The third-party service provider’s
platform will automatically rebalance positions in the sleeves based on the drift parameters to bring
the UMA in balance with the investment models selected by AMTI.
Features of AMTI’s FIP
The Fixed Income Portfolios (the “FIP”), is a Wrap product, whereby AMTI, has discretionary
authority over clients’ assets. Discretionary services require the customer to grant AMTI limited
1 Registration with the SEC or any state securities authority does not imply a certain level of skill or training.
discretionary powers to actively manage the portfolio as per agreed upon Investment Guidelines.
Discretion refers to AMTI being empowered by customers to implement, without prior consent,
decisions related to Component Selection and Execution, as well as Periodic Rebalancing.
As noted above, the client’s Wealth Advisors (“WA”) will assist the client in clarifying their investment
needs, including but not limited to investment objective, tolerance for risk, investment experience, and
investment time horizon; and will provide professional advice for a single advisory fee. The Wealth Advisor
will work with the client in selecting the appropriate portfolio in an effort to assist the client in achieving
their investment goals.
The FIPs are intended as a low turnover buy-and-hold strategy and do not attempt to time the market or
extract returns from active trading. AMTI’s approach to analysis includes a series of filters to identifying
the proper companies and securities for the model/strategy. The filters AMTI utilizes for this analysis may
include but are not limited to, inclusion attributes of fixed income securities, such as duration, credit quality
and coupon, and exclusions, such as minimum investable piece. Attributes of fixed income securities are
examined so that securities that AMTI does not want in end client portfolios are excluded.
AMTI, sorts through specific attribute fields to discern the quality of one fixed income issuer versus another.
In addition, bonds that have negative material events, failure to file financials, or other significant one-off
events, are also excluded. These filters are subject to change.
AMTI analyzes market prices of qualified fixed income securities to that of recent trades of the same or
similar securities to determine the relative value, and, as a result, a fair price to be paid for each security.
After filtering using a balanced approach with availability, price and credit, and any other criteria deemed
appropriate, AMTI ensures compliance with sector and issuer diversification in determination of a
recommended list of securities for purchase.
AMTI will run a similar issuer screening process when considering rebalancing trades. AMTI conducts its
own credit screening and analysis on all issuers considered and selected for FIP products. Uninvested cash
balances in the FIP accounts will be invested daily in the default sweep money market fund chosen by
AMTI for these types of accounts.
Although AMTI primarily trades away from its clearing broker-dealer, Pershing, LLC, Pershing, LLC,
maintains custody of the client’s funds and securities; collects interest and dividends; and performs the
normal and customary execution and custodial services.
The client’s profile is updated at least annually or more frequently depending upon material changes
which are reported by the client. The client may impose reasonable investment restrictions
2 on their
account with respect to the individual securities selected for investment by contacting AMTI.
2 Acceptable restrictions are based on a variety of factors. Customers should discuss the
limitations of imposing restrictions on the management of their account(s) with their Wealth
Advisor.
Performance Evaluation and Monitoring Services
AMTI will monitor, rebalance
3, and manage all of the changes to the client’s account. AMTI may
furnish quarterly performance measurement reports to its clients. These reports are intended to
inform clients as to how their investments have performed during the selected period. Clients will
also receive account statements from Pershing, LLC (the custodian and clearing broker-dealer)
at
least quarterly, detailing all of the activity in the client’s account, including the amount of advisory
fees paid directly to AMTI.
Information contained in the performance report is believed to be accurate, however, the accuracy
and completeness of the information is not guaranteed; and is not intended to replace the account
statements clients receive from Pershing, LLC, which is the custodian of client funds and securities
for accounts participating in the PAS and FIP programs. The statements clients receive from Pershing
should be considered the official record for all pertinent account information. While this performance
report is provided in a different format from that of Pershing, and may vary in content and scope,
clients should carefully compare the asset information to that contained in the Pershing account
statement. Any discrepancies noted should be reported immediately to the client’s IC. Clients should
also notify AMTI promptly if they do not receive the account statements from Pershing on at least a
quarterly basis. Calculations and data provided on the performance reports should not be relied upon
for tax purposes, but rather clients should use the original transaction confirmations and 109’'s
instead.
Advisory Fees
The following reflects the standard advisory fee schedule charged to clients for the PAS and FIP
programs.
PAS Fee Schedule
0.75% to 1.75% (depending on account type)
FIP Fee Schedule
0.85% to 0.95% (depending on the program)
Program Fees are paid directly to AMTI and are expressed as an annual rate that is prorated for the
quarterly billing period and is applied to the asset value of the account. For this purpose, asset value
means the total fair market value of the eligible securities and cash in your account. Although the fees
listed above are standard fees, they may, in some circumstances, be negotiable and may vary
according to a variety of factors, such as size, type, and complexity of account. The fee charged is a
percentage of all assets in the PAS and FIP programs. The fee is paid to AMTI as sponsor of the
3 Depending on the PAS program selected, AMTI requires client’s prior approval for account rebalancing for the
non-discretionary program. For the PAS discretionary program and the FIP program, AMTI does not require client
approval because AMTI has discretion of the assets in the accounts.
program in which client is invested. The fee includes two free wires per twelve month period to the
client’s personal account at Amerant Bank, but does not cover incidental fees, such as fees for
subsequent wires to the client's personal account. A schedule of these charges may be obtained from
the client’s Wealth Advisor. Program fees will not be reduced or offset by these fees. Instead, these
additional fees will reduce the overall return of your account. AMTI charges customers a single fee
that covers research, advice, ongoing account management, brokerage executions, custody and other
related services.
Since AMTI receives a fee for client participation in the PAS and FIP programs they may have an
incentive to recommend it over other products or services.
Comparison of Cost of Service
Since the PAS and FIP are wrap products, whereby customers pay a single fee for investment advisory
services and brokerage services, it may cost the client more or less than purchasing such services
separately, generally depending upon commission rates, portfolio turnover and the cost of similar
non-wrap discretionary investment advisory services. Clients should consider the amount of trading
activity they anticipate and other factors when assessing the PAS and FIPs cost.
Selection of Broker/Dealer
You should note that in order to comply with principal trade restrictions, orders for most of our
advisor programs are routed for agency execution, to a third party broker dealer, usually Pershing,
LLC. However, if we believe it is consistent with our duty of best execution, AMTI as broker dealer,
on agency basis, may execute the trades.
Risks
Accounts are subject to a variety of market and other risks, including illiquidity and volatility.
Investment performance of any kind can never be and is not guaranteed—nor is past performance
an indicator of future results. In executing transactions for your accounts, we will not be liable for
losses caused directly or indirectly by government restrictions, exchange controls, exchange or
market rulings, suspension of trading, acts of war, strikes or other conditions beyond our control,
including but not limited to, extreme market volatility or trading volumes.
Automated systems are used to route and execute orders for the purchase and sale of securities for
all advisory accounts. Generally, an order is routed to an execution center that we believe will provide
the best execution. In determining the best way to execute an order for a client, we evaluate the
following:
– The speed and certainty of execution
– The price and size improvement
– The overall execution quality
Additional Fees
AMTI may offer the client the ability to pledge their securities for a loan (either through margin, or a loan
given by an affiliate bank). In the event a client chooses to utilize one of these services, they will incur
extra charges as set forth in the disclosure documents and agreements for these arrangements. IC’s may
have a conflict of interest to offer these products as they receive compensation for such. Clients are urged
to read all documentation regarding these services carefully before opting to participate.
It may be possible for AMTI to earn compensation for placing clients in certain selected money market
fund sweep program(s) chosen for the customer. Unlike bank deposits, money market funds are not insured
or guaranteed by the Federal Deposit Insurance Corporation (FDIC) or any government agency, but rather
are subject to coverage under the Securities Investor Protection Corporation (SIPC). SIPC provides
protection of up to $500,000 per customer including a maximum of $250,000 for cash claims. Complete
details of SIPC coverage can be found at www.SIPC.org. Although money market funds seek to preserve
the value of your investment, it is possible to lose money by investing in a money market fund
(see fund
prospectus). In general, money market funds are designed and managed with the investment objective of
preservation of capital, maintenance of liquidity and generating high current income.