We specialize in the following types of services: comprehensive portfolio management and
referrals to third party money managers. Our assets under management are $995,000,000 as of
April 2024.
A. Description of our advisory firm, including how long we have been in business and our
principal owner
(s)1.
We are dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a corporation formed in the State of South Dakota.
Our firm has been in business as an investment adviser since 2011 and is owned as follows:
John Haller – Thirty Four-percent owner
Jesse Haller – Thirty Three-percent owner
Jasen Haller – Thirty Three-percent owner
B. Description of the types of advisory services we offer.
(i) Comprehensive Portfolio Management:
Our comprehensive portfolio management service encompasses asset management as well
as access to financial planning/financial consulting for clients. It is designed to assist
clients in meeting their financial goals through the use of financial investments. We try to
conduct at least one, but sometimes more than one meeting (in person if possible, otherwise
via telephone conference) with clients in order to understand their current financial
situation, existing resources, financial goals, and tolerance for risk. Based on what we
learn, we propose an investment approach to the client. We may propose an investment
portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds,
or other securities. Upon the client’s agreement to the proposed investment plan, we work
with the client to establish or transfer investment accounts so that we can manage the
client’s portfolio. Once the relevant accounts are under our management, we review such
accounts on a regular basis and at least annually, if the client makes themselves available.
We may periodically rebalance or adjust client accounts under our management. If the
client experiences any significant changes to his/her financial or personal circumstances,
1 Please note that: (1) For purposes of this item, our principal owners include the
persons we list as owning 25% or
more of our firm on Schedule A of Part 1A of Form ADV (Ownership Codes C, D or E). (2) If we are a publicly held
company without a 25% shareholder, we simply need to disclose that we are publicly held. (3) If an individual or
company owns 25% or more of our firm through subsidiaries, we must identify the individual or parent company and
intermediate subsidiaries. If we are a state-registered adviser, on Form ADV Part 2A Page 2, we must identify all
intermediate subsidiaries. If we are an SEC-registered adviser, we must identify intermediate subsidiaries that are
publicly held, but not other intermediate subsidiaries.
the client must notify us so that we can consider such information in managing the client’s
investments.
(ii) Referrals to Third Party Money Managers:
We may provide clients with a list of investment advisory services of third party professional
portfolio management firms for the individual management of client accounts. As part of this
process, we assist clients in identifying an appropriate third party money
manager. We
provide initial due diligence on third party money managers and ongoing reviews of their
management of your account.
In order to assist clients in the selection of a third party money manager, we typically gather
information from the client about their financial situation, investment objectives, and
reasonable restrictions they can impose on the management of the account, which are often
very limited. It is important to note that we do not offer advice on any specific securities
or other investments in connection with this service. Investment advice and trading of
securities is only offered by or through the third party money managers to clients.
We periodically review third party money managers’ reports provided to the client, but no
less often than on an annual basis, if the client makes themselves available. Our associates
contact the clients from time to time, as agreed to with the client, in order to review their
financial situation and objectives; communicate information to third party money managers
as warranted; and, assist the client in understanding and evaluating the services provided
by the third party money manager. The client will be expected to notify us of any changes
in his/her financial situation, investment objectives, or account restrictions that could affect
their account. The client may also directly contact the third party money manager
managing the account or sponsoring the program.
C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs
of
clients, whether
clients may impose restrictions on investing in certain securities or types of
securities.
(i) Individual Tailoring of Advice to Clients:
We offer individualized investment advice to clients utilizing the following services
offered by our firm: Comprehensive Portfolio Management. Additionally, we offer general
investment advice to clients utilizing the following services offered by our firm: Referrals
to Third Party Money Managers.
(ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of
Securities:
We usually do not allow clients to impose restrictions on investing in certain securities or
types of securities due to the level of difficulty this would entail in managing their account.
In the rare instance that we would allow restrictions, it would be limited to the following
services: Comprehensive Portfolio Management. We do not manage assets through our
other services.
D. Participation in
wrap fee programs.
We offer wrap fee programs as further described in Part 2A, Appendix 1 (the “Wrap Fee
Program Brochure”) of our Brochure. Our wrap fee accounts are managed on an individualized
basis according to the client’s investment objectives, financial goals, risk tolerance, etc. As
further described in our Wrap Fee Program Brochure, we receive a portion of the wrap fee for
our services.
E. Disclosure of the amount of
client assets we manage on a
discretionary basis and the amount
of
client assets we manage on a non-
discretionary basis as of April 2024.
We manag
e2 $995,000,000 on a discretionary basis and $0 on a non-discretionary basis as of
April 2024.