Description of Advisory Firm
Telos Capital Management, Inc. (“TCM,” “we,” “our,” or “us”) is a privately-owned corporation
headquartered in San Diego, CA. TCM is registered as an investment adviser with the U.S. Securities and
Exchange Commission.
Stefan Meierhofer originally co-founded A&M Investment Management in January 2003. In January
2009, the firm incorporated and changed its name to Telos Capital Management, Inc. In December 2012,
Stefan Meierhofer became TCM’s sole owner, and in 2014, Jonathan P. Fairchild acquired a minority
interest in the firm. In January 2019, Andrew Weld acquired a minority interest in the firm.
Fiduciary Duty
Registered investment advisers are considered fiduciaries under federal law. Our fiduciary duty carries
with it an obligation to act in the best interest of our clients pursuant to a relationship of trust and
confidence. It encompasses a duty of care and a duty of loyalty.
Duty of Care
The duty of care includes, among other things:
1. the duty to provide advice that is in the best interest of the client;
2. the duty to seek best execution of a client’s transactions where the adviser has the
responsibility to select broker-dealers to execute client trades; and
3. the duty to provide advice and monitoring over the course of the relationship.
The duty to provide advice suitable to each client based on a reasonable understanding of the client’s
objectives is a critical component of the duty of care. Providing suitable advice includes making a
reasonable inquiry into the client’s financial situation, investment experience, and financial goals and
then updating this information as necessary throughout the course of the relationship to reflect the
client’s changing objectives over time and adjusting the advice we provide to reflect any changed
circumstances.
When TCM has the responsibility to select broker-dealers to execute client trades in discretionary
accounts, we seek to trade such that the client’s total cost or proceeds in each transaction are the most
favorable under the circumstances. In doing so, we consider the full range and quality of a broker’s
services and so the determinative factor is not necessarily the lowest possible commission cost but
whether the transaction represents the best qualitative execution. Moreover, we periodically and
systematically evaluate the execution we receive on behalf of our clients.
Our duty of care includes an obligation to provide advice and monitoring at a frequency that is in the
best interest of the client, taking into account the scope of the agreed relationship. This scope is
indicated by the duration and nature of the services as outlined in each client’s advisory arrangement
and extends to all personalized advice provided to clients.
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Duty of Loyalty
TCM adheres to a duty of loyalty where we seek to serve the best interests of our clients and never
subordinate the interests of our clients to our own. Simply put, TCM cannot place its own interests
ahead of the interests of our clients. In observance of this duty, we must make full and fair disclosure to
clients of all material facts relating to the advisory relationship. Further, we also seek to eliminate or at
least expose through full and fair disclosure all conflicts of interest which might incline TCM, consciously
or unconsciously, to render advice that is not disinterested. We believe that in order for disclosure to be
full and fair, it should be sufficiently specific so that each client is able to understand the material fact or
conflict of interest and make an informed decision whether to provide consent. Consequently, we
provide this ADV 2A brochure to all prospective clients at or before entering into a contract so that they
can use the information within to decide whether or not to enter into an advisory relationship.
Advisory Services Offered
TCM offers the following services to advisory clients:
Investment Management Services
TCM provides investment management services to individual investors, trusts, estates, charitable
organizations, participants of retirement plans, small businesses, and high-net-worth individuals.
Investment portfolios are generally managed on a fully discretionary basis in accordance with the
particular investment strategy selected by the client. Although TCM exercises investment discretion for
each account that it advises, clients are given the ability to impose reasonable restrictions on the
management of their accounts, including specific securities or security types.
TCM actively manages client portfolios on an ongoing basis and rebalances them when, in TCM’s
judgment, rebalancing is warranted in light of market conditions and/or changes in clients’
circumstances. In constructing portfolios, the principles of asset allocation and security diversification
guide our investment management process. Recommended asset allocation strategies take into
consideration a client’s investment objectives, risk tolerance, liquidity needs, time horizon, tax situation,
and other unique, personal circumstances.
Clients who engage TCM to provide investment advisory services will be required to complete an
Investment Management Agreement (IMA) and Client Profile. The IMA details the terms and conditions
of the engagement and the scope of the services we will provide. The Client Profile provides TCM with
valuable personal information regarding the client’s financial situation and risk tolerance. This
information is used in the design, implementation, and management of a client’s investment portfolio.
TCM offers three distinct programs of managing client accounts:
• TCM Managed Portfolios
• TCM McCuen Portfolios
• Sherman Core Portfolios
Each of these programs is described in further detail under Item 8 - Methods of Analysis, Investment
Strategies and Risk of Loss, below.
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Within the above programs, we primarily utilize the following investment types when making purchases
in client accounts:
1. Equity securities, including stocks and foreign securities listed on US exchanges (ADRs) or foreign
exchanges (ordinaries)
2. Fixed income securities, including corporate and government bonds, commercial paper, and
certificates of deposit (CDs)
3. Exchange traded funds (ETFs)
4. Municipal securities
5. Money market funds, cash sweeps, and other cash equivalents
Depending on the client’s individual investment objectives and needs, many portfolios further include,
as appropriate:
1. Securities with equity and debt characteristics, including convertible bonds, preferred stocks, or
other preferred securities
2. Real estate investment trusts (REITs)
3. Mutual funds
4. Exchange traded notes (ETNs)
5. Closed-end funds
6. U.S. government securities
7. Mortgage-backed securities
8. High-yield debt
9. Treasury inflation-protected securities (TIPS)
10. Inflation-indexed bonds
11. Master limited partnerships (MLPs)
Occasionally, TCM also offers advice regarding additional types of investments if they are appropriate to
address the individual needs, goals, and objectives of the client or in response to client inquiry. We may
offer investment advice on any investment held by the client at the start of the advisory relationship.
We describe the material investment risks for many of the securities that we utilize under the heading
Specific Security Risks in Item 8 below.
We discuss our discretionary authority below under Item 16 - Investment Discretion. For more
information about the restrictions clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this item below. We describe the Fees charged for investment management
services below under Item 5 - Fees and Compensation.
Please note that those clients that invest in the TCM McCuen Portfolios will be managed on a fully
discretionary basis and will be transitioned into the TCM Managed Portfolio styles over a period of time,
dependent upon the suitability, tax considerations and investment needs of the individual client.
Financial Planning Services
TCM’s financial planning services focus primarily on retirement planning, retirement plan allocations and
investments. Through personal meetings with the client, we collect, organize, and assess relevant
information, including the client’s current financial status, investment objectives, tax considerations,
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financial goals, and attitudes towards risk. The primary objective of this process is to allow TCM to assist
the client in developing a written financial plan, which can also be accessed in electronic format. This
may include a retirement model, portfolio analysis or other recommendation based on the financial
planning agreement. For situations where projections show less than the desired results, we may make
recommendations that include showing clients the impact on those projections by making changes in
certain variables (i.e., working longer, saving more, spending less, taking more risk with
investments). This service is not considered holistic or comprehensive financial planning. Services do not
include income tax, gift, or estate tax returns, or preparation of any legal documents.
TCM does not receive separate compensation for financial planning related services, and
implementation of the recommendations is at the client’s discretion and their responsibility. Financial
planning services are not ongoing in nature and clients must understand that their overall situation or
needs may not be fully addressed due to these limitations.
Limitations on Investments
In some circumstances, TCM’s advice may be limited to certain types of securities.
Limitation by Plan Sponsor/Employer
When we provide services to participants in an employer-sponsored plan, the participant may be limited
to investing in securities included in the plan’s investment options. Therefore, TCM can only choose
from among the available options and will not invest the client’s account in other securities, even if
there are potentially more suitable options elsewhere.
Mutual Fund Limitations
TCM limits selections of mutual funds to no load funds or load-waived equivalents.
Limitation by Client
TCM may also limit advice based on certain client-imposed restrictions. For more information about the
restrictions clients can put on their accounts, see Tailored Services and Client Imposed Restrictions in
this Item below.
Non-Managed Assets
Non-Managed Assets are assets over which the Client does not grant us investment discretion. TCM
does not provide any discretionary or non-discretionary investment advice on such assets, nor do we
provide opinions as to the merits of any non-managed asset held in the account, but we will include
those assets on the Client’s Reporting Package for informational purposes only. We also do not make
any judgments as to the appropriateness of assumed risk or suitability of any non-managed asset given
the client’s situation.
In limited cases, TCM offers securities trading activities for non-managed positions held within a client’s
managed account, acting as an intermediary between the client and the custodian. We offer this service
at no charge and at our discretion, in consideration of the client’s other assets that we manage.
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Tailored Services and Client Imposed Restrictions
TCM manages client accounts based on the investment strategy the client chooses, as discussed below
under Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss. TCM applies the selected
strategy for each client, based on the client’s individual circumstances and financial situation. We make
investment decisions for clients based on information the client supplies about their financial situation,
goals, and risk tolerance. Our investment choices may not be suitable if the client does not provide us
with accurate and complete information. It is the client’s responsibility to keep TCM informed of any
changes to their investment objectives or restrictions.
Once the client chooses a certain strategy, each client will have the opportunity to place reasonable
restrictions on the account, such as when a client needs to keep a minimum level of cash in the account,
or limitations on the purchase or sale of certain securities, types of securities, or industry sectors. We
make every effort to manage restricted portfolios along with other clients within similar mandates.
However, it is possible that security selection and trade placement will be delayed for these portfolios
while we determine whether a proposed investment decision complies with the account guidelines and
restrictions or identify alternatives. Accounts subject to investment restrictions or directed broker
agreements may forfeit some of the advantages that may result from aggregated orders and may be
disadvantaged by the market impact of trading for other portfolios.
TCM reserves the right to not accept and/or terminate management of a client’s account if we feel that
the client-imposed restrictions are unreasonable and would limit or prevent us from meeting or
maintaining the client’s investment strategy.
Wrap Fee Programs
TCM does not manage accounts as part of a wrap or bundled fee program.
Assets Under Management
TCM manages client assets in discretionary accounts on a continuous and regular basis. As of December
31, 2023, the total amount of assets under our management was $1,254,803,384.