A. Diversified Investment Strategies, LLC (the “Registrant”) is a limited liability company
formed on December 16, 2004 in the state of Louisiana. Diversified Investment Strategies,
LLC does business as Advisor.Investments, and markets itself as such. The Registrant
became registered as an Investment Adviser Firm in November 2006 and as Producer
Agency for insurance sales by the State of Louisiana in April 2015. The Registrant is owned
by James Pope and Shane Haag.
B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts
and estates, etc.) investment advisory services. The Registrant does not hold itself out as
providing financial planning or estate planning services. To the extent specifically
requested by a client, Registrant shall generally provide limited consulting services to its
investment management clients on investment and non-investment related matters that are
generally ancillary to the investment management process. The type and scope of the
advisory and consulting services offered will vary on a client by client basis.
INVESTMENT ADVISORY SERVICES
The client can determine to engage the Registrant to provide discretionary investment
advisory services on a fee basis. The Registrant’s annual investment advisory fee is based
upon a percentage (%) of the market value of the assets placed under the Registrant’s
management as per the following fee schedule:
TAX PREPARATION AND ENROLLED AGENT SERVICES
The Tax Preparation and Enrolled Agent Services may be offered to existing and new clients on a
selective basis.
TAX PREPARATION SERVICES
The Registrant may determine to offer tax preparation services on selective basis with a stand-alone
separate fee set forth in a separate engagement letter. Registrant’s typical tax preparation fee for a simple
tax return is $250 per return. However, Registrant’s fee could be substantially more for more complex
returns. No client is under any obligation to engage the Registrant for tax preparation services.
ENROLLED AGENT SERVICES
Shantelle Palermo, Enrolled Agent, at her discretion on a selective basis, may offer engagement to
represent the client before the Internal Revenue Service (IRS) and/or the State Department of Revenue for
matters relating to any of the following.
Tiers Tier Chargeable Assets Annual Rate
1 First $500,000 1.35%
2 Plus, additional assets up to $1,000,000 0.85%
3 Plus, additional assets up to $2,000,000 0.70%
4 Plus, additional assets up to $4,000,000 0.45%
5 Plus, additional assets up to $8,000,000 0.35%
6 Amount over $8 million negotiable
• Communicating with the IRS and/or State Department of Revenue for a taxpayer regarding the
taxpayer's rights, privileges, or liabilities under laws and regulations administered by the IRS
and/or State Department of Revenue.
• Representing a taxpayer at conferences, hearings, or meetings with the IRS and/or State
Department of Revenue.
• Preparing and filing documents with the IRS and/or State Department of Revenue for a
taxpayer.
• Corresponding and communicating with the IRS and/or State Department of Revenue for a
taxpayer.
The terms and conditions, and corresponding fee, for any such engagement shall be set forth in a separate
engagement letter between Ms. Palermo and the client. No client is under any obligation to engage Ms.
Palermo for any of the above services.
Non-Investment Consulting/Implementation Services. Neither the Registrant, nor any of its
representatives, serves as an attorney, and no portion of the Registrant’s services should be
construed as legal or accounting services. To the extent requested by a client, the Registrant may
recommend the services of other professionals for certain non-investment implementation purposes
(i.e. attorneys, accountants, etc.). These professionals may also include employees or agents of the
Registrant in their separate registered or licensed capacities as discussed above (Tax Preparation)
and below (Insurance). The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from the Registrant. Please Note: If
the client engages any unaffiliated recommended professional, and a dispute arises, the client agrees
to seek recourse exclusively from and against the engaged professional. At all times, the engaged
unaffiliated licensed professional[s] (i.e. attorney, accountant, etc.), and not Registrant, shall be
responsible for the quality and competency of the services provided. Please Also Note: It remains
the client’s responsibility to promptly notify the Registrant if there is ever any change in their
financial situation or investment objectives for the purpose of reviewing and revising Registrant’s
previous recommendations or services.
Please Note: 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 Registrant recommends that a client roll over their
retirement plan assets into an account to be managed by Registrant, such a recommendation creates a
conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the
rollover. If Registrant provides a recommendation as to whether a client should engage in a rollover or not
(whether it is from an employer’s plan or an existing IRA), Registrant 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. No client is under any obligation to roll over
retirement plan assets to an account managed by Registrant, whether it is from an employer’s plan
or an existing IRA. Registrant’s Chief Compliance Officer, Shane Haag, remains available to address
any questions that a client or prospective client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Custodian Charges-Additional Fees. As discussed below at Item 12 below, when requested to recommend
a broker-dealer/custodian for client accounts, Registrant generally recommends that Schwab serve as the
broker-dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge
brokerage commissions, transaction, and/or other type fees for effecting certain types of securities
transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs
charged for fixed income transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. While certain custodians, including Schwab, generally (with the potential
exception for large orders) do not currently charge fees on individual equity transactions (including ETFs),
others do. Please Note: there can be no assurance that Schwab and/or Fidelity will not change their
transaction fee pricing in the future. The above fees/charges are in addition to Registrant’s investment
advisory fee at Item 5 below. Registrant does not receive any portion of these fees/charges. ANY
QUESTIONS: Registrant’s Chief Compliance Officer, Shane Haag, remains available to address any
questions that a client or prospective client may have
regarding the above.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated
sweep account. The yield on the sweep account will generally be lower than those available for other money
market accounts. When this occurs, to help mitigate the corresponding yield dispersion, Registrant shall
(usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market
fund available on the custodian’s platform, unless Registrant reasonably anticipates that it will utilize the
cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s
account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash
balances for various reasons, including, but not limited to the amount of dispersion between the sweep
account and a money market fund, an indication from the client of an imminent need for such cash, or the
client has a demonstrated history of writing checks from the account. Please Note: The above does not
apply to the cash component maintained within a Registrant actively managed investment strategy (the cash
balances for which shall generally remain in the custodian designated cash sweep account), an indication
from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager,
and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain
exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash
balances maintained in any Registrant unmanaged accounts. ANY QUESTIONS: Registrant’s Chief
Compliance Officer, Shane Haag, remains available to address any questions that a client or prospective
client may have regarding the above.
Please Note: Cash Positions. Registrant continues to treat cash as an asset class. As such, unless
determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any
specific point in time, depending upon perceived or anticipated market conditions/events (there being no
guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash
positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss
market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could
exceed the interest paid by the client’s money market fund. ANY QUESTIONS: Registrant’s Chief
Compliance Officer, Shane Haag, remains available to address any questions that a client or
prospective may have regarding the above fee billing practice.
emoney. In the event that the Registrant provides the client with access to an unaffiliated vendor’s
website such as emoney, and the site provides access to information and/or concepts, including
financial planning, the client, should not, in any manner whatsoever, infer that such access is a
substitute for services provided by the Registrant. Rather, if the client utilizes any such content, the
client does so separate and independent of the Registrant.
Portfolio Activity. Registrant has a fiduciary duty to provide services consistent with the client’s
best interest. As part of its investment advisory services, Registrant 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, manager changes, debt burden, client
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these
factors, there may be extended periods of time when Registrant determines that changes to a client’s
portfolio are neither necessary nor prudent. The Registrant’s fee shall remain payable during such
periods of account inactivity. Of course, as indicated below, there can be no assurance that
investment decisions made by Registrant will be profitable or equal any specific performance
level(s).
Affiliated Private Investment Fund. The Registrant is the advisor to Aldabra Capital Partners,
LP (the “affiliated private fund”). The Registrant, on a non-discretionary basis, may recommend
that qualified clients consider allocating a portion of their investment assets to the affiliated private
fund. The terms and conditions for participation in the affiliated private fund, including incentive
fees, conflicts of interest, and risk factors, are set forth in the fund’s offering documents.
Registrant’s clients are under absolutely no obligation to consider or make an investment in a
private investment fund.
Risk Factors: Private investment funds generally involve various risk factors, including,
but not limited to, potential for complete loss of principal, liquidity constraints and lack of
transparency, a complete discussion of which is set forth in each fund’s offering
documents, which will be provided to each client for review and consideration. Unlike
liquid investments that a client may maintain, private investment funds do not provide daily
liquidity or pricing. Each prospective client investor will be required to complete a
Subscription Agreement, pursuant to which the client shall establish that he/she is qualified
for investment in the fund, and acknowledges and accepts the various risk factors that are
associated with such an investment.
Conflict of Interest. Because the Registrant earns compensation from the affiliated private
fund (incentive compensation) that can exceed the fee that Registrant would earn under its
standard asset based fee schedule referenced in Item 5 below, the recommendation that a
client become an investor in the affiliated private fund presents a conflict of interest. No
client is under any obligation to become an investor in the affiliated private fund.
Please Note: 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 Registrant)
will be profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Registrant shall not be required to verify any
information received from the client or from the client’s other professionals, and is expressly
authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to
promptly notify the Registrant if there is ever any change in their financial situation or investment
objectives for the purpose of reviewing, evaluating and revising Registrant’s previous
recommendations or services.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A of Form
ADV shall be provided to each client prior to, or contemporaneously with, the execution of the
Investment Advisory Agreement.
C. The Registrant shall provide investment advisory services specific to the needs of each
client. Prior to providing investment advisory services, an investment adviser
representative will ascertain each client’s investment objective(s) allocation(s). Thereafter,
the Registrant shall allocate and/or recommend that the client allocate investment assets
consistent with the designated investment objective(s) allocation(s). The client may, at any
time, impose reasonable restrictions, in writing, on the Registrant’s services.
D. The Registrant does not participate in a wrap fee program.
E. As of December 31, 2022, the Registrant had $166,417,901 in assets under management
on a discretionary basis and $12,699,734 in assets under management on a non-
discretionary basis.