Fiduciary Standard
As a fiduciary, we put our client's interests first. We do not participate in or have financial incentives in what our clients choose to invest in. Our personal trading is based on our own individual goals and is entirely independent of our clients' investment activity. Based on the client's financial objectives, we may or may not recommend a particular asset or asset class to buy or sell that we ourselves or a related party are invested. If this situation arises, we will notify the client in writing and get their written acknowledgement of this fact. Since we are not being paid on commission nor being paid by anyone other than the client based solely on their AUM, we do not see this as a conflict. Also, since we do not have discretionary authority over our clients' funds, we do not buy and sell their securities. Based on the fundamental analysis we do over time, we may recommend buying or selling at any particular time, but it is up to the client to make that buy or sell decision. If we or our related party does decide to buy or sell a position in a given asset that is also held by a client, we will notify the client in writing as to our intent as well as the timing of our buy / sell.