Disclosures
As an investment adviser with assets under management in excess of $100 million, LIMC is regulated by the United State Securities and Exchange Commission (“SEC”), primarily under the Investment Advisers Act of 1940. The Form ADV is the uniform form used by investment advisers to register with both the SEC and state securities authorities. The form consists of three parts.
Part 1 requires information about an investment adviser’s business, ownership, clients, employees, business practices, affiliations, and any disciplinary events of the adviser or its employees. Part 1 is organized in a check-the-box, fill-in-the-blank format. The SEC reviews the information from this part of the form to process registrations and manage its regulatory and examination programs. Although designed for a regulatory purpose, investment adviser filings of Part 1 are available to the public on the SEC’s Investment Adviser Public Disclosure ("IAPD").
Part 2 requires investment advisers to prepare narrative brochures written in plain English that contain information such as the types of advisory services offered, the adviser’s fee schedule, disciplinary information, conflicts of interest, and the educational and business background of management and key advisory personnel of the adviser. The brochure is the primary disclosure document that investment advisers provide to their clients and is available to the public on the IAPD website.
Part 3, also referred to as Form CRS, requires SEC-registered investment advisers and SEC-registered broker-dealers to deliver to retail investors a brief customer or client relationship summary that provides information about the firm. The relationship summary is designed to assist retail investors with the process of deciding whether to (i) establish an investment advisory or brokerage relationship, (ii) engage a particular firm or financial professional, or (iii) terminate or switch a relationship or specific service. The summary is also available to the public on the IAPD website.