A. Virtue Capital Management, LLC
Virtue Capital Management, LLC (“VCM”) is a limited liability company organized in the state of
Tennessee. Virtue Financial Holdings, LLC (“VFH”), which owns 100% of Virtue Capital
Management, LLC, is owned by Jeremy Rettich, Matthew Rettich, and James Webb. Jeremy Rettich
and Matthew Rettich are the control persons of VFH. VCM has been offering investment advisory
services since October 2013.
B. Advisory Services Offered
VCM is an asset management and financial planning firm offering a variety of investment
management, financial planning, portfolio monitoring and third-party manager monitoring
services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, other
investment advisers and the clients of such independent investment advisers.
B.1. Investment Advisory and Portfolio Management Services
VCM generally provides continuous and regular supervisory or management services. VCM gives
continuous advice to its clients through its investment adviser representatives based on the
individual needs of each client. VCM manages client accounts on a discretionary basis. VCM has
discretionary authority regarding the securities to be bought or sold, the amount of securities to
be bought or sold as well as the authority to hire and terminate third-party money managers.
Account supervision is generally guided by the stated objectives of the client (e.g., capital
appreciation, growth, income, or growth and income). Consideration is also generally given to the
allocation of assets among securities-based investment strategies and managers and
recommendations and selections are generally tailored to the client’s overall investment
objectives and risk profiles. VCM’s investment committee also seeks to perform due diligence on
third-party money managers and investment solutions prior to these being offered through the
VCM platform and then strives to perform ongoing due diligence as to such managers and
solutions.
B.2. Selection of Other Advisers
VCM may utilize or recommend sub-advisers or third-party money managers (“TPMMs”) to clients.
VCM will generally be compensated via a fee share with the TPMMs to which it directs those
clients. The fees shared will not exceed any limit imposed by any regulatory agency. Before
recommending TPMMs to clients, VCM performs due diligence and research on such TPMMs.
B.3. Consulting and Financial Planning Services
Consulting and financial planning services may include, but are not limited to: investment
planning, life insurance; tax concerns; retirement planning; college planning; and debt/credit
planning. The services and fees for such services are negotiated in advance and documented in
an exhibit to the Financial Planning Agreement. VCM does not, however, provide tax or legal
advice.
In offering financial planning, a conflict exists between the interests of the investment adviser and
the interests of the client since the investment adviser will benefit from the fees earned from
managing the client’s assets in the event the client chooses to invest through the VCM platform.
However, the client is under no obligation to act upon the investment adviser's recommendation,
and, if the client elects to act on any of the recommendations, the client is under no obligation to
affect the transaction through the investment adviser. This statement is required by California
Code of Regulations, 10 CCR Section 260.235.2.
Clients will usually receive a written or oral report (depending on the client’s preference) providing
a basic financial plan designed to help achieve the client’s stated financial goals and objectives.
Based on the client’s needs, financial planning services may include (but are not limited to) the
following:
▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio
among different categories of investments, such as domestic and international
small,
medium, and large capitalization securities; corporate and government fixed income
(short-, intermediate-, and long-term maturities); emerging market securities (i.e., foreign
issuers); real estate investment trusts; and such other alternative asset categories including
those offered through exchange traded funds that are suitable in light of the client's
investment goals, objectives, and risk tolerance.
▪ Preparation of a retirement plan that serves to identify whether the client is saving enough
and investing in a way that meets retirement objectives in light of the client's financial
circumstances and risk tolerance.
▪ Preparation of cash flow projections to ensure that the client can meet daily living
expenses and obligations.
▪ Insurance planning to meet the needs of the client, taking into account family, business,
and other financial objectives of the client.
▪ General family office and business consulting:
• Retirement objectives
• Philanthropy
• Estate planning
• Wealth transition
• Business succession and related issues
• Recommendation of third-party managers for use by the client
VCM usually gathers client information through, among other things, in-depth personal interviews
and questionnaires. Information gathered includes a client's current financial status, investment
objectives, future goals, and attitudes toward risk. Related documents supplied by the client are
carefully reviewed, and a report may be prepared, subject to mutual agreement with the client
and VCM, covering one or more of the above-mentioned topics as directed by the client.
B.4. Retirement Answers 101 Financial Education Course
We may offer this course to provide pre-retirees and retirees with a better understanding of the
many financial planning areas that should often be considered as they enter into or maintain the
lifestyle to which they have become accustomed during their retirement years. The materials
covered in this course will revolve around addressing some of the greatest retirement fears
including changes to investing as you near or enter retirement, social security election strategies,
generating income, investment advice “suitability standard versus fiduciary responsibility,” and
passive/strategic investing vs. active/tactical investing among many other topics. The information
covered is general in nature and not intended to give specific investment advice to attendees.
B.5. ERISA & Qualified Plan Services
VCM offers to ERISA and other Qualified Plans consulting services that involve one or more of the
following services, either onsite or through an electronic medium, as requested by the Plan:
▪ Enrollment meetings to Plan participants
▪ Education as to the Plan’s options and features
▪ Education for employees on financial topics such as compound interest, debt, benefits of
financial planning as examples
▪ Discuss with HR payroll and related matters pertaining to Plan services and enrollment
issues that may arise
▪ Individual discussions with employees regarding Plan features and operations
▪ Discuss investment changes with the Plan’s trustees that the 3(38) Plan fiduciary makes
from time to time
▪ Periodically benchmark the plan as to costs and benefits to other plan providers to assess
the Plan's competitiveness for industry, size, and features
C. Client-Tailored Services and Client-Imposed Restrictions
Each client’s account will usually be managed on the basis of the client’s financial situation and
investment objectives. The client is required to notify the firm in writing of any reasonable
instructions to be imposed on the management of the portfolio.
D. Wrap Fee Programs
VCM does not participate in wrap fee programs, where brokerage commissions and transaction
costs are included in the asset-based fee charged to the client.
E. Client Assets Under Management
As of December 31, 2023, VCM managed approximately $787,466,708 in discretionary assets and
$0 in non-discretionary assets.