A. Description of Your Advisory Firm
Poehling Capital Management, Inc. (“PCM” and/or “the firm”), a Wisconsin corporation, is
headquartered in Madison, Wisconsin, with a branch office located in La Crosse, Wisconsin. PCM
was formed in May of 2004 and is principally owned by Thomas Poehling. PCM is an investment
adviser providing financial planning, estate planning, and discretionary and non-discretionary
investment management services to its clients.
B. Description of Advisory Services Offered
PCM is an independent investment advisory and financial planning firm offering a variety of
financial services to individuals and high-net-worth individuals, trusts, pension and profit sharing
plans, and charitable organizations. Advisory services may include investment strategy, portfolio
management, financial planning, and estate planning, as well as selection of separate account
managers.
For its discretionary asset management services, PCM receives a limited power of attorney to
effect securities transactions on behalf of its clients that include securities and strategies as
described in Item 8 of this Brochure. In addition, PCM will remind clients of their obligation to
inform the firm of any changes to their personal financial circumstances, investment objectives
or risk tolerance, and modifications or restrictions that should be imposed on the management
of their accounts. PCM will also contact clients at least annually to determine whether there have
been any changes in a client's personal financial circumstances, investment objectives, and
tolerance for risk.
B.1. Financial Planning Services
PCM’s professionals interview each client at length to determine the client’s goals, objectives,
investment time horizon, and risk tolerance. PCM reviews documents supplied by the client such
as wills, insurance policies, and income tax returns.
Generally, any of the service categories listed below, on a stand-alone basis, require a minimum
of ten (10) hours to compile the necessary data to provide the requested service. In the event
the client selects an additional service category, each additional service category would add
approximately two (2) to five (5) hours of additional time to complete; for example, the selection
of two service categories would require twelve (12) to fifteen (15) hours. Please note these are
good faith estimates. Factors that could drive the amount of time and cost higher are the
number and complexity of assets, number of securities accounts, number of trusts, number and
complexity of corporate entities, client-imposed requirements, complexity of tax situation, and
related factors. Based on the client’s needs, financial planning services may include (but are not
limited to) the following:
▪ Personal Financial Planning This includes an analysis of family records, budgeting,
evaluation of liability issues, estate planning, and determination of financial goals.
▪ Cash Flow and Tax Planning This includes spending analyses and income tax planning.
PCM counsels clients concerning the current and future tax effects of various investment
vehicles.
▪ Retirement Planning PCM helps clients determine their retirement goals and formulates
investment strategies to assist in reaching those goals.
▪ Investment Planning PCM evaluates investment alternatives and their effect on a client’s
portfolio.
PCM recommends that all clients work closely with their attorney, accountant, insurance agent,
and investment advisor to implement a financial plan.
B.2. Investment Management Services
For discretionary investment management services to clients with assets generally greater than
$250,000, PCM offers its value-oriented investment methodology through a series of model
portfolios that span each of the risk tolerance categories across the risk spectrum. PCM invests
in securities of large capitalization companies that are selling at significant discounts to their
intrinsic value, with additional investments in non-correlated securities that serve to reduce
overall portfolio risk and volatility. This strategy involves the utilization of quality companies with
strong financials run by experienced, shareholder-friendly management teams that are selling at
significant discounts to historical valuation metrics and can be acquired at attractive prices.
PCM’s primary focus will be on publicly traded equities (common and preferred stocks),
exchange-traded funds, open end mutual funds, fixed income (taxable and tax-free), and option
contracts. Please refer to Item 8 of this Brochure for a complete listing of the types of securities
for which PCM provides advice.
Client portfolios are managed on an individual customized basis, taking into account the client’s
investment goals, objectives, risk tolerance, and other financial circumstances. PCM reserves the
right to offer investment management program strategies in the future whereby, if appropriate,
clients will elect to invest in a PCM-offered discretionary investment management program
strategy.
In the majority of instances, PCM will evaluate a host of risk management factors (client account
size, investment allocation parameters, withdrawal rate, etc.), which may result in the
recommendation of one or more third-party separate account managers to manage one or
more asset classes that fall outside the scope of PCM’s core investment management
competency and/or in order to achieve proper diversification. Please be advised that in such
instances, PCM acts in the capacity of an investment consultant and provides advice as to the
most appropriate separate account manager in light of the client’s personal and financial
circumstances. PCM’s fees for this service are the same as if it were managing the portfolio
assets on a proprietary basis. In addition to fees charged by PCM, the client will incur charges
from the separate account manager.
Although PCM places its clients’ interests first by recommending the most appropriate separate
account manager for one or more asset classes outside of its core investment management
competency, there is the potential for conflicts in that the client’s fees will always be less if the
client utilizes PCM as an investment manager rather than as an investment consultant and
allocating all or a portion of the portfolio assets to a third-party separate account manager. As a
result, PCM may have an economic incentive to recommend its proprietary managed product
over that of the third-party separate account manager. Clients should be aware that they will
incur fees from PCM and any third-party money manager utilized. Such additional fees will
detract from any increase in portfolio return as a result of hiring the third-party money manager.
Please note, though, that PCM would only consider recommending a third-party money
manager for those asset classes that fall outside the scope of PCM’s core investment
management competency and/or in order to achieve proper diversification based on a host of
client-specific risk management factors that are detailed above. In this regard, PCM believes it is
placing its clients’ interests first and fulfilling its fiduciary obligation to clients.
For clients with assets generally less than $250,000, PCM offers its value-oriented investment
methodology through mutual fund models that span each of the risk tolerance categories across
the risk spectrum. PCM invests in mutual funds whose portfolio securities consist of small- to
large-capitalization companies that the mutual fund manager believes are selling at significant
discounts to their intrinsic value, with additional investments in mutual fund securities that
consist of lower-correlated securities that serve to reduce overall portfolio risk and volatility. This
strategy involves the utilization of mutual funds consisting of quality companies with strong
financials run by experienced, shareholder-friendly management teams.
B.3. Outside Assets – 401(k) Plans and Related Assets
PCM may also provide investment advisory services to retirement plans (“Plan”) or retirement
plan participants (“Participants”). PCM may prepare personal asset allocation targets after
obtaining and evaluating information concerning individual client circumstances provided by
each Participant in response to a risk profiling questionnaire. PCM may provide
recommendations as to an appropriate asset class structure and/or securities from a list of
securities approved by the plan sponsor (“Sponsor”).
The asset allocation and mutual fund recommendations made to such clients may differ from
those made by PCM to high-net-worth and affluent individuals and institutions for one or both
of the following reasons:
▪ A Participant’s asset allocation target typically consists of a smaller number of asset
categories to reflect the relatively smaller size of the Participant’s investment assets.
▪ The Sponsor has constrained the investment alternatives from which PCM may make
recommendations. In such cases, PCM may be required to observe quantitative criteria
established by the Sponsor in preparing Participant-oriented lists of mutual funds, or to
confine the advice given to choices among a relatively narrow set of investment
alternatives established by the Sponsor. Participants are informed when the Sponsor of
the group imposes constraints on PCM’s ability to recommend mutual funds or other
securities.
C. Client-Tailored Services and Client-Imposed Restrictions
Clients’ accounts will be managed on the basis of their financial situation and investment
objectives and in accordance with any reasonable restrictions they have imposed on the
management of their accounts—for example, restricting the type or amount of security to be
purchased in the portfolio.
D. Wrap Fee Programs
PCM does not participate in wrap fee programs. (Wrap fee programs offer services for one all-
inclusive fee.)
E. Client Assets Under Management
As of December 31, 2022, PCM had $335,087,545 of discretionary assets under management,
and on $3,006,431 of non-discretionary assets.