Overview
A. Description of the Advisory Firm
Predicate Investment Advisors, LLC (hereinafter “PIAL”) is a Limited Liability Company
organized in the State of Arizona. The firm was formed in February 2023, and the principal
owners are FF5 Trust and Harex Management LLC.
B. Types of Advisory Services
Portfolio Management Services
PIAL (the “Investment Manager”) is the manager and provides advice to a private
investment fund.
The fee schedule for such services are generally described in the Fund’s current disclosure
documents. PIAL will provide all disclosure documents to clients of JIML.
Services Limited to Specific Types of Investments
PIAL generally limits its investment advice to fixed income securities, real estate funds,
equities, venture capital funds and private placements, although PIAL primarily
recommends alternative investments. PIAL may use other securities as well to help
diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries 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. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
•
Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
PIAL offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client’s current
situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in
investing in certain securities or types of securities in accordance with their values or
beliefs. However, if the restrictions prevent PIAL from properly servicing the client
account, or if the restrictions would require PIAL to deviate from its standard suite of
services, PIAL reserves the right to end the relationship.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. PIAL does not participate in wrap fee
programs.
E. Assets Under Management
PIAL has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 March 2023
