Ellis Investment Partners, LLC ("EIP" or "Ellis") is an SEC registered investment adviser located in the
State of Pennsylvania. The firm was founded in 2011 by David Y. Sun, owner and President of the
firm.
Portfolio Management Services
EIP manages investment advisory accounts ("Portfolio Management") for individuals, small
businesses, retirement plans, trusts, partnerships, corporations or other business or institutional
accounts. An initial interview and data gathering questionnaire is undertaken to determine the client's
individual needs and risk tolerance. The recommendations are implemented in a portfolio that may
include no-load or load waived mutual funds, stocks, bonds, ETF's and other investments deemed
appropriate for the client. Other investments may include REITS, limited partnerships and options
(covered call writing).
EIP utilizes a dynamic asset allocation approach and maintains several models that are used as
guidelines to achieve the client's objectives. While each client account is separately maintained at a
third-party custodian and each client retains his or her right of ownership over the account, client
accounts with similar risk profiles and objectives may utilize similar investments based on these
models.
In some cases, EIP may determine that a client would benefit from the inclusion of a third-party
investment management team. In these cases, separate offering materials will be provided to clients
who choose to utilize the services of a third-party co-advisor to EIP. Such materials disclose the
portfolio management services, fees and termination procedures specific to the investment
management team. Clients should read all offering materials carefully. Clients are under no obligation
to engage the services of any third-party investment manager.
Through EIP's Portfolio Management Services, EIP offers clients implementation assistance and
ongoing and continuous review of investment assets and consolidated performance reporting. EIP
provides these Portfolio Management Services on a discretionary basis, whereby transactions or
actions are taken by EIP Associates on behalf of the client, without the express written permission of
the client. While EIP does have discretion over client accounts, clients may place reasonable
restrictions on the types of investments or investment strategies used for their accounts.
EIP may also offer non-discretionary portfolio management services. If a client enters into non-
discretionary arrangements with our firm, we must obtain client approval prior to executing any
transactions on behalf of the account. Non-discretionary clients have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
As part of the Portfolio Management Services, client accounts are reviewed by EIP on an on-going
basis, to determine that assets are performing consistent with the investment objectives, overall market
conditions, and current asset mix. Consolidated asset reporting to the client is done quarterly. For
Portfolio Management, EIP typically recommends that clients start with a minimum portfolio of
$250,000. While this is generally the case, lower minimums may be accepted subject to the sole
discretion of EIP and based on such factors as related family accounts or other special situations.
Portfolio Management clients should also carefully consider investing only those funds that can be
committed on a long-term basis, usually at least three to five years. Clients should expect volatility
from investing in equity securities, as all investments carry risks.
Financial Planning Services
EIP provides Personal Financial Plans consistent with the individual client's financial situation and
investment objectives. Planning may be comprehensive or may be "segmented" and focus on
investments, insurance, taxes, retirement, and/or estate plans. Dependent upon the scope of the
financial planning services to be performed by EIP, the preparation of a plan involves guiding clients in
gathering, compiling, preparing, and analyzing personal financial data. If EIP provides estate planning
coordination and analysis, the client may be referred to an outside entity, Estate Wise, LLP dba Estate
Plan Navigator ("EP Navigator"), for preparation of estate planning documents. The client is under no
obligation to utilize the services provided by EP Navigator and does so at their own discretion. The
client will receive a written financial plan at the completion of the financial planning process and the
client will then have the option to implement recommendations through Associates of EIP, but is not
obligated to do so. If Associates of the firm assist in the implementation of any recommendations,
clients may engage the firm separately, for Portfolio Management Services described above. Financial
plans are based on a client's financial situation at the time the plan is presented, and on the financial
information a client provides us. Clients must promptly notify our firm if their financial situation, goals,
objectives, or needs change.
Consulting Services
In addition to individualized investment management and financial planning, EIP offers investment
consulting services on a more limited basis. Such consultation is offered to assist a client in an isolated
area of concern, such as an existing investment portfolio or qualified plan. For example, for clients with
existing portfolios, EIP may provide on-going advice regarding investment reallocation. This advice will
not necessarily involve the development of a financial plan or the actual management of the underlying
portfolio assets, but may simply assist clients in evaluating existing holdings and determining
necessary reallocations. Consulting services may be rendered differently for different clients, based on
the client's individual needs. Clients will be asked to sign a Consulting Services Agreement in order to
engage EIP for consulting services.
Retirement Plan Services
Ellis, through its investment adviser representative, provides investment advisory services to
retirement plans, as selected by the plan fiduciary. In some cases, Ellis may recommend the services
of a third-party advisor. The services that may be selected are either ERISA fiduciary services or
ERISA non-fiduciary services, as identified, and may be provided on an annual or as-needed basis.
Retirement Plan clients have the option from selecting from the services described below:
ERISA Fiduciary Services
Ellis provides ERISA fiduciary services to the plan as a fiduciary under Section 3(21)(A)(ii) of ERISA
and will act in good faith and with the degree of diligence, care and skill that a prudent person
rendering similar services would exercise under similar circumstances. As a Section 3(21)(A)(ii)
fiduciary, Ellis will solely make recommendations to the plan fiduciary, and the plan fiduciary retains full
discretionary authority or control over the assets of the plan. Ellis will have no authority or responsibility
in the administration of the retirement plan, in the interpretation of the plan documents, in the
determination of employee eligibility to participate in the plan, in the calculation of plan benefits, or in
the distribution of any notices to plan participants. Ellis does not act as an "investment manager" as
defined under Section 3(38) of ERISA and does not have any discretionary authority over any plan
assets. Ellis also does not
act as plan "administrator" as defined by ERISA, and is not the plan
custodian, trustee, third party administrator or recordkeeper. Ellis does not have any authority or
responsibility to vote proxies for securities held in the plan, or take any action relating to shareholder
rights regarding those securities.
Clients may choose from the following ERISA Fiduciary Services:
•Development of an Investment Policy Statement ("IPS"). Ellis will review plan objectives, risk
tolerance and goals of the plan with the plan sponsor. Ellis will help plan sponsor establish an
investment policy statement to state the investment policies and objectives of the plan. Plan
sponsor will have the authority to adopt and implement the objectives and policies for the plan.
•Recommendations to Select Asset Classes. Ellis will provide non-discretionary investment
advice with regard to different asset classes and investment options available to help plan
fiduciary and/or plan administrators select asset classes and investment options consistent with
the investment goals and objectives of the plan.
•Investment Strategy Review and Monitoring. Ellis will conduct periodic due diligence and
provide information, reports and recommendations to assist plan fiduciary in monitoring and
evaluating the performance of the investment options and asset allocations available in the
plan. Ellis will also provide information and recommendations to plan fiduciary or plan
administrators to remove or add investment options based on performance or other qualitative
measures.
ERISA Non-Fiduciary Services
In addition to the above described fiduciary services, Ellis offers the following non-fiduciary services
solely in a capacity that is not considered a fiduciary under ERISA or any other applicable law:
•Plan Objectives and Design Options. Ellis will assist plan fiduciary in determining the plan
objectives and structure of the plan. Ellis will work with third party administrators for the plan.
•Investment Education. Ellis will provide education for plan fiduciary regarding asset classes and
types of investment strategies available to the plan. Educational services will be general in
nature and will not speak to the individual circumstances of plan participants. Ellis does not
provide fiduciary advice to plan participants.
•Plan Development and Service Providers. Ellis will assist the plan fiduciary in evaluating plan
service providers, including the selection and evaluation of a third-party administrator, if
necessary.
If a third-party advisor is recommended for retirement plan services, the plan fiduciary will receive
additional disclosure documents from the applicable third-party advisor. If Ellis recommends the
rollover of existing qualified plan assets to an IRA rollover, Ellis will provide disclosure regarding the
features of the rollover, including expenses. When making the decision to roll over an employer
sponsored retirement plan to an IRA, clients are encouraged to consider the following factors:
•Options in the current plan
•Range of investment options
•Fees and expenses
•Services provided by employer sponsored plan
•Tax consequences
•Penalty-free withdrawals (55 in a plan versus 59 ½ in an IRA)
•Loans
•Adviser's services
Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. 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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
General Information Related to Investment Recommendations
For each of the above disclosed advisory services, EIP does not limit its investment recommendations
to any specific type of product or security. A client's individual needs and objectives are analyzed to
determine appropriate investments and products for the client. Since different types of investments
typically involve different types of risk, the firm conducts a risk analysis of the client and his/her overall
portfolio, before recommending a certain investment. EIP typically manages assets on a discretionary
basis; however, the client is always free to place restrictions on the types of investments the firm
recommends for the client's portfolio.
EIP generally recommends an investment allocation which may consist of stocks, bonds, mutual funds,
closed-end companies, or exchange traded funds. The firm may also periodically recommend that the
client invest in certificate of deposits, annuities, REITS or limited partnerships, including non-publicly
traded assets where no readily ascertainable market value exists. EIP may also engage in covered call
writing.
EIP may determine that clients would benefit from access to third-party asset managers. Clients will
receive separate offering documents from the third-party that explain the services, fees and termination
procedures for these third-party programs. Clients should read these offering materials carefully. Use
of a third-party as co-advisor to EIP may cost the client more or less than purchasing these services
separately.
EIP endeavors at all times to only recommend investments that it feels are suitable for a given client,
and the firm makes reasonable efforts to describe in detail, any conflicts of interest that may exist. EIP
may also provide advice on non-securities products. Clients should be aware that all securities
investments involve risk, including the possible loss of all or part of an investment. Clients who elect to
invest in securities must be willing to bear this risk. For this reason, EIP takes care to determine an
appropriate risk tolerance of its clients. Investment recommendations are made with this risk tolerance
in mind.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $752,323,435 in client
assets on a discretionary basis, and $48,461,850 in client assets on a non-discretionary basis.