A. Description of the Advisory Firm
Value Investment Professionals, LLC is a Limited Liability Company organized
in the state of Delaware. The firm was formed in June of 2012, and the principal
owner and Chief Compliance Officer is Andrew Hodges.
B. Types of Advisory Services
Value Investment Professionals, LLC (hereinafter “VIP”) offers the following
services to advisory clients:
Investment Supervisory Services
VIP offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. VIP creates an
Investment Policy Statement for each client, which outlines the client’s current
situation (income, tax levels, and risk tolerance levels) and then constructs a plan
to aid in the selection of a portfolio that matches each client’s specific situation.
Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
VIP evaluates the current investments of each client with respect to their risk
tolerance levels and time horizon. VIP will request discretionary authority from
clients in order to select securities and execute transactions without permission
from the client prior to each transaction. Risk tolerance levels are documented in
the Investment Policy Statement, which is given to each client.
Performance-based Fees
Qualified clients may be charged performance fees based on net profits above a
high water mark in addition to an investment management fee.
Financial Consulting
If financial consulting services are applicable, the client will compensate VIP on an
hourly fee basis described in detail under “Fees and Compensation” section of this
brochure. Typical topics reviewed may include but are not limited to: financial
goals, personal net worth statement, investment analysis, retirement strategy, cash
flow analysis, risk management, long-term investment plan and estate
preservation. If a conflict of interest exists between the interests of the investment
advisor and the interests of the client, the client is under no obligation to act upon
the investment advisor’s recommendation. If the client elects to act on any of the
recommendations, the client is under no obligation to effect the transaction
through VIP.
ERISA Plan Services
VIP provides service to qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit sharing plans, cash balance plans, and deferred
compensation plans. VIP may act as either a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. VIP sometimes acts as a limited scope
ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their
investment decisions on a non-discretionary basis. As an investment advisor VIP
has a fiduciary duty to act in the best interest of the client. The plan sponsor is still
ultimately responsible for the decisions made in their plan, though using VIP can
help the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
➢ Provide non-discretionary investment advice to the client about asset
classes and investment alternatives available for the Plan in accordance
with the Plan’s investment policies and objectives. Client will make the final
decision regarding the initial selection, retention, removal and addition of
investment options. VIP acknowledges that it is a fiduciary as defined in
ERISA section 3 (21) (A) (ii).
➢ Assist the client in the development of an investment policy statement
(“IPS”). The IPS establishes the investment policies and objectives for the
Plan. Client shall have the ultimate responsibility and authority to establish
such policies and objectives and to adopt and amend the IPS.
➢ Provide non-discretionary investment advice to the Plan Sponsor with
respect to the selection of a qualified default investment alternative for
participants who are automatically enrolled in the Plan or who have
otherwise failed to make investment elections. The client retains the sole
responsibility to provide all notices to the Plan participants required under
ERISA Section 404(c) (5) and 404(a)-5.
➢ Assist in monitoring investment options by preparing periodic investment
reports that document investment performance, consistency of fund
management and conformance to the guidelines set forth in the IPS and
make recommendations to maintain, remove or replace investment options.
➢ Meet with client on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services may be:
➢ Assist in the education of Plan participants about general investment
information and the investment alternatives available to them under the
Plan. Client understands VIP’s assistance in education of the Plan
participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, VIP is not providing fiduciary
advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. VIP will
not provide investment advice concerning the prudence of any investment
option or combination of investment options for a particular participant or
beneficiary
under the Plan.
➢ Assist in the group enrollment meetings designed to increase retirement
plan participation among the employees and investment and financial
understanding by the employees.
VIP may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between VIP and client.
3. VIP has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
1. Employer securities;
2. Physical real estate (real estate funds or publicly traded REITs that are less
liquid or harder to value than traditional publicly traded real estate entities
are not excluded);
3. Stock brokerage accounts or mutual fund windows;
4. Participant loans;
5. Non-publicly traded partnership interests;
6. Other non-publicly traded securities or physical property (other than
collective trusts and similar vehicles); or
7. Other hard-to-value or illiquid securities or physical property.
Excluded Assets will not be included in calculation of Fees paid to VIP under this
Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. VIP can also act as an ERISA 3(38) Investment Manager
in which it has discretionary management and control of a given retirement plan’s
assets. VIP would then become solely responsible and liable for the selection,
monitoring and replacement of the plan’s investment options.
1. Fiduciary Services are:
➢ VIP has discretionary authority and will make the final decision regarding
the initial selection, retention, removal and addition of investment options
in accordance with the Plan’s investment policies and objectives.
➢ Assist the client with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
➢ Assist the client in the development of an investment policy statement
(“IPS”). The IPS establishes the investment policies and objectives for the
Plan.
➢ Provide discretionary investment advice to the Plan Sponsor with respect
to the selection of a qualified default investment alternative for participants
who are automatically enrolled in the Plan or who have otherwise failed to
make investment elections. The client retains the sole responsibility to
provide all notices to the Plan participants required under ERISA Section
404(c) (5).
2. Non-fiduciary Services may be:
➢ Assist in the education of Plan participants about general investment
information and the investment alternatives available to them under the
Plan. Client understands VIP’s assistance in education of the Plan
participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, VIP is not providing fiduciary
advice as defined by ERISA to the Plan participants. VIP will not provide
investment advice concerning the prudence of any investment option or
combination of investment options for a particular participant or
beneficiary under the Plan.
➢ Assist in the group enrollment meetings designed to increase retirement
plan participation among the employees and investment and financial
understanding by the employees.
VIP may provide these services or, alternatively, may arrange for the Plan’s other
providers to offer these services, as agreed upon between VIP and client.
3. VIP has no responsibility to provide services related to the following types of
assets (“Excluded Assets”):
a. Employer securities;
b. Physical real estate (real estate funds or publicly traded REITs that are
less liquid or harder to value than traditional publicly traded real estate
entities are not excluded);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or physical property (other than
collective trusts and similar vehicles); or
g. Other hard-to-value or illiquid securities or physical property.
Excluded Assets will not be included in calculation of Fees paid to VIP under this
Agreement.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
C. Client Tailored Services and Client Imposed Restrictions
VIP offers the same suite of services to all of its clients. However, specific client
financial plans and their implementation are dependent upon the client
Investment Policy Statement which outlines each client’s current situation
(income, tax levels, and risk tolerance levels) and is used to construct a client
specific plan to aid in the selection of a portfolio that matches restrictions, needs,
and targets.
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 VIP from properly servicing the client account, or if the restrictions would
require VIP to deviate from its standard suite of services, VIP reserves the right to
end the relationship.
D. Wrap Fee Programs
VIP does not participate in any wrap fee programs.
E. Client Assets under Management
VIP has the following assets under management:
Discretionary Amounts: Non-discretionary
Amounts:
Date Calculated:
$45,041,245 $0 11/28/23