BPBI is a registered investment advisory firm organized under the laws of the State of New York
in October 2016 as a Limited Liability Company. BPBI is wholly owned by Adolfo Rios Oliver.
BPBI obtained SEC registration on March 15, 2017.
BPBI is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. BPBI offers and seeks to offer asset management services to
domestic and international clients, primarily from Mexico. BPBI’s goal is to help our clients meet
their financial goals according to their risk tolerance and investment time horizons. We are held
to a fiduciary standard that covers our entire investment advisory relationship with you. As a
fiduciary, it is BPBI’s duty to always act in the client’s best interest. For example, we are required
to monitor your portfolio, investment strategy and investments on an ongoing basis. We are
required to identify and eliminate conflicts of interest, or tell you about them in a way you can
understand, so that you can decide whether or not to agree to them. BPBI is a service-oriented
advisory practice that values long term relations based on trust and results.
Types of Advisory Services Offered Comprehensive Portfolio Management: As part of our investment services clients are l provided asset management and financial planning
services. Our service is designed to assist clients meet their financial goals considering their
risk-return objectives and liquidity needs via the implementation of a diversified investment
strategy. BPBI conducts client meetings to understand their financial situation, assets, liabilities,
financial goals and risk tolerance. Based on the above, an investment strategy is presented to
the client which is implemented primarily through Exchange Traded Funds (“ETFs”) and as
appropriate individual stocks, bonds, mutual funds and other public and private securities or
investments. Once the appropriate portfolio has been implemented , portfolios are continuously
and regularly monitored, and if necessary, rebalanced based upon market conditions and the
client’s individual needs. Upon client request, BPBI will provide a summary of observations and
recommendations for the planning or consulting aspects of this service.
Tailoring of Advisory Services
BPBI offers individualized investment advice to each of our clients. Each client has its own
investment portfolio and the client has the opportunity to place reasonable restrictions on the
types of investments to be held in its portfolio. Specific restrictions on investments in certain
securities or types of securities sometimes may not be possible for instance when investing
through ETF of mutual fund instruments.
Independent Third Party Managers
BPBI may select other advisors or third party managers (“Independent Managers”) to actively
manage all or a portion of its clients’ assets. The specific advisory services under which a client
engages an Independent Manager will be set forth in a separate written agreement with the
designated Independent Manager. In addition to this Brochure, clients will also receive the
Brochure and written disclosure documents of the respective Independent Managers engaged to
manage their assets.
Fees charged to BPBI’s clients by the Independent Managers depend on several factors,
including the size and type of the investment, trading strategy, maturity and degree of risk.
Independent Managers may charge performance fees on realized or unrealized gains in their
portfolio. Please refer to the Independent Manager’s Forms ADV, for additional information. BPBI
does not receive any portion of fees, commissions or other charges from Independent Managers,
brokers, or other service providers. BPBI does not receive fees or commissions for
recommending any securities, or investments, or a particular Independent Manager.
BPBI evaluates a variety of information about Independent Managers, which may include the
Independent Managers’ public disclosure documents, materials supplied by the Independent
Managers themselves and other third-party analyses from sources we believe to be reliable. We
analyze Independent Managers based upon their investment strategies, experience, performance
track record, reputations, and fee arrangements. To the extent possible, BPBI seeks to assess
the Independent Managers’ investment strategies, past performance and risk results in relation
to its clients’ individual portfolio allocations and risk exposure. BPBI also takes into consideration
the Independent Manager’s management style, returns, reputation, financial strength, reporting,
pricing and research capabilities, among other factors. On an ongoing basis, BPBI monitors the
performance of those accounts being managed by Independent Managers. BPBI seeks to ensure
the Independent Managers’ strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests.
BPBI may also offer sub advisory services to independent Investment Advisors and or family
offices, primarily from Mexico.
Participation in Wrap Fee Programs
BPBI does not offer wrap fee programs at this time.
Family Office Services
BPBI will also offer the following services for high net worth investors and family offices:
• Supervisory oversight of the client's investment portfolios held at various financial
institutions and managed by the client’s financial advisors, brokers, private bankers or
portfolio managers (collectively “Financial Intermediaries”);
• Development of an Investment Policy Statement;
• Communicating to the Financial Intermediaries the Client’s objectives and any Client
imposed constraints or limitations;
• Sourcing and providing due diligence on investment opportunities;
• Negotiating agreements commissions, fees and volume discounts, as applicable,
between the Client and the Financial Intermediaries and custodian(s);
• Reviewing existing Financial Intermediary and custody arrangements and if appropriate,
identifying new Financial Intermediaries to manage the client’s investment portfolios, or
new Qualified Custodians, as defined under Rule 206(4)-2 of the Investment Advisers Act
of 1940, (“Advisers Act”), to hold client’s assets.;
• Coordinating estate planning and trust services;
• Participating in family office meetings and providing educational training to family
members
Regulatory Assets Under Management
As of January 31, 2020, BPBI has regulatory assets under management of $58,000,817 of which
$17,591,337 are managed on a discretionary basis and $40,409,479 are non-discretionary assets
under management.
please register to get more info
Compensation for Our Advisory Services
BPBI provides comprehensive portfolio management services for a base fee, as outlined in the
advisory agreement signed by each client. The maximum annual fee charged for this service by
BPBI or any Independent Managers is negotiated based on the size of the portfolio and will not
exceed 1.50%. Annual fees are billed on a quarterly basis in arrears, based on the monthly
statements three month average value of the assets under management of the client’s account(s).
Clients may elect to be billed directly for advisory fees or authorize their custodian financial
institutions to pay BPBI’s and the Independent Manager’s advisory fees. When deemed
appropriate, BPBI may agree to provide services on a flat fee basis depending on the amount of
assets and other services to be provided.
BPBI may waive, adjust or rebate fees in certain situations. At BPBI’s discretion, BPBI may
combine the account values of family members to determine the applicable advisory fee. BPBI
may also waive or discount fees for employees and employee’s family or Access Person
accounts. Clients are advised that other clients with similar assets may pay different fees. Clients
should also be aware that the same or similar investment services may be available from other
investment advisors for a lower fee. The more assets you have in the advisory account, including
cash, the more you will pay us. We therefore have an incentive to increase the assets in your
account in order to increase our fees. You pay our fee quarterly even if you do not buy or sell. An
asset-based fee may cost more than a transaction-based fee, but you may prefer an asset-based
fee if you want continuing advice or want someone to make investment decisions for you.
Although BPBI believes the charges and fees offered are competitive with other investment
advisors and/or investment sources, we make no guarantee that the aggregate cost of a particular
program will be lower than that which may be available elsewhere.
Other Types of Fees and Expenses
BPBI’s fees are exclusive of brokerage commissions, transaction fees, and other employee costs
or expenses which shall be incurred directly by the client. Clients may incur certain charges
imposed by custodians, brokers, and other third parties such as fees charged by fund managers,
custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic funds fees, and other fees and taxes on brokerage account and securities transactions.
In addition to all other fees and expenses incurred in the management of an advisory account,
client accounts that utilize margin strategies will also incur interest charges. For accounts that
use margin, although the account statements may reflect a negative amount for the margined
securities, our advisory fees are based on the absolute market value of the securities. The clients’
margin balance is typically included when calculating BPBI's fees. Clients should note that they
may already be paying margin interest on these same assets. This poses a conflict of interest for
BPBI. We manage this risk through disclosure so that clients can make an informed decision and
through policies and procedures that require us to act in the client’s best interest.
Mutual funds and ETFs also charge internal management fees, which are disclosed in a fund’s
prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads,
12b-1 fees, surrender charges, individual retirement account (IRA) and qualified retirement plan
fees, and other fund expenses). BPBI does not receive a portion of these fees.
BPBI’s policy is to offer clients funds with the lowest cost and most favorable share class based
on the client’s individual needs. Mutual fund companies generally offer multiple share classes of
the same fund. Share classes are described in the mutual fund's prospectus. Each share class
charges different fees and internal expenses. Depending on the share class selected, fees and
internal expenses charges may be higher or lower. Certain funds do not charge a transaction fee
but have higher internal expenses. Selecting funds that charge higher fees and expenses may
adversely impact an account’s long-term performance.
You will pay your proportionate share of the mutual fund’s management and administrative fees
and sales charges, as set forth in the mutual fund prospectus. Such advisory fees are
compensation to the mutual fund-manager and are generally not shared with your Advisor
BPBI’s policy is to generally recommend that clients invest in the lowest cost share class available
based on the client’s individual needs. BPBI typically recommends institutional or advisor share
classes that typically have the lowest expense ratios and are more beneficial than other share
classes. Institutional or Advisor share classes are usually available to investors in qualified fee-
based advisor programs, or accounts that meet certain minimum investment requirements.
When deemed appropriate for a client’s specific situation, your Investment Advisor
Representative may at times recommend selecting or holding a mutual fund share class that
charges higher internal expenses than other available share classes for the same family. BPBI
will conduct periodic testing to ensure that the appropriate recommended share class has been
selected for its clients. For share classes transferred in from other institutions.
BPBI will as soon as practicable evaluate whether more beneficial share classes may be available
for the client to exchange at no cost and recommend that the client switch to a different lower cost
share class, or may recommend liquidating the existing mutual fund holdings, which could result
in tax consequences, or the client having to pay contingent deferred sales charges, or other
redemption fees. Clients may be able to purchase mutual funds directly from their respective fund
families without incurring our advisory fee. When purchasing directly from fund families, clients
may incur a front- or back-end sales charge. We urge clients to carefully review the mutual fund
prospectus that describes the fund’s investment objectives, fees and expenses and discuss any
questions with their Investment Advisor Representative.
Termination
Clients may terminate the advisory agreement signed with our Firm at any time by informing us
in writing. Upon notice of termination pro-rata advisory fees for services rendered to the point of
termination will be charged. If advisory fees cannot be deducted, BPBI will send an invoice for
the advisory fees due.
please register to get more info
BPBI offers or seeks to offer advisory services to the following types of clients:
• Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Types of Businesses.
BPBI does not impose minimum account size requirements for opening and maintaining
accounts or otherwise engaging us.
please register to get more info
Methods of Analysis
We use, as deemed appropriate, the following methods of analysis in formulating our investment
advice and/or managing client assets
• Charting
• Cyclical
• Fundamental
• Technical
Investment Strategies We Use
We may use the following strategies in managing client accounts, provided that such strategies
are appropriate to the needs of the client and consistent with the client's investment objectives,
risk tolerance, and time horizons, among other considerations:
• Long Term Purchases (Securities Held At Least a Year);
• Short Term Purchases (Securities Sold Within a Year);
• Trading (Securities Sold Within 30 Days);
• Short Sales.
Risk of Loss
BPBI seeks to implement investment strategies that are designed to minimize potential losses,
but there can be no assurance that these strategies will be successful, particularly in the short
term. Clients may lose all or a substantial portion of their assets. Investment performance of any
kind is not guaranteed and past performance is not an indication of future results.
All investments and investment strategies carry risk of loss. Different types of investments involve
varying degrees of risk, and there can be no assurance that the future performance of any specific
investment, investment strategy, investment model, or product will be profitable, prove successful,
equal any corresponding indicated historical performance level. Asset allocation and
diversification do not ensure or guarantee better performance and cannot eliminate the risk of
investment losses. Unless the asset allocation or investment strategy is fully diversified,
investments in a particular strategy should only be viewed as a portion of the overall portfolio and
investors should avoid placing all their investments in high-risk investment strategies.
While the stock market may increase and the account(s) could enjoy a gain, it is also possible
that the stock market may decrease and the account(s) could suffer a loss. It is important that
clients understand the risks associated with investing in the stock market, are appropriately
diversified in investments, and ask any questions.
Foreign or emerging markets can be highly volatile. Significant changes in prices and liquidity
can occur rapidly.
Concentrated portfolios may not be diversified, may hold securities representing only one or a
limited number of companies or sectors and price movements could result in a greater risk of loss,
especially over the short term.
Fixed-income strategies carry interest rate and credit risk tied to the volatility of the market and
the credit worthiness of the issuers. High-yield bond strategies invest in lower-rated debt bonds
(junk bonds) and carry increased risks due to the lower credit quality of the securities in the
portfolio. Clients should be aware of the possibility for increased volatility and risk of default and
the potential for loss of all or part of the amount invested.
Alternative investments include private funds such as hedge funds, private equity, venture capital,
real estate, funds of private funds and structured products. Investors in hedge funds and
alternative Investments should be accredited, sophisticated investors that are capable of
generally understanding complex investment strategies sometimes employed, and tolerate the
risks and possible illiquidity constraints of alternative asset classes.
Investors in hedge funds, alternative investments, non-traditional Investment and private equity
investments should consider that these types of investments are: speculative and may involve a
high degree of risk; may be leveraged and their performance can be volatile; are generally illiquid
and may require that the money be invested for long periods; there is no secondary market for
the investment; there may be restrictions on transferring interests; fees and expenses may offset
trading or investment profits; periodic pricing or valuation information may not be available; there
are no assurances that the particular investment objectives can be achieved; and as with other
investments, investors may lose all or a substantial amount of the amount invested.
Real assets may include real estate and public or private Real Estate Investment Trust Securities
(REIT)s invested through public or private limited partnerships, limited liability corporations, or
private equity. Real assets have historically offered potential income and total returns, tax
advantages, portfolio diversification and an inflation hedge.
Leverage creates an opportunity for greater total returns, but also carries a greater risk of loss
from adverse price changes. Losses from short selling may be unlimited, as opposed to losses
from a cash investment which are limited to the total amount invested. BPBI generally will not
directly engage in short selling in Client accounts, but may invest in funds and other instruments
that may engage in short selling.
Transactions in a client account, including account reallocations and rebalancing may trigger a
taxable event. Clients are urged to consult with their tax advisor.
please register to get more info
There are no legal or disciplinary events that are material to the evaluation of our advisory
business or the integrity of our management.
please register to get more info
Neither BPBI nor its management or associated persons are registered, or have any application
pending to register with the SEC as a broker-dealer, or registered representative of a broker-
dealer, investment advisor, investment company, or with the Commodity Futures Trading
Commission (“CFTC”) as a Futures Commission Merchant (“FCM”), Commodity Pool Operator
(“CPO”), or Commodity trading advisor (“CTA”).
Other Financial Industry Affiliations Custodian Relationships BPBI maintains a service agreement with BNY Mellon N.A. and Pershing Advisor Solutions, LLC
and generally recommends, however is not a requirement, that clients utilize the custody,
brokerage and clearing services offered through the Bank of New York. Factors which BPBI
considers in recommending BNY Mellon N.A. and or Pershing Advisor Solutions, LLC include
their financial strength, reputation, competitive pricing and range of services including its ability to
offer our international clients a multi-currency platform. Clients should be aware that the
commissions, transaction and other fees charged by BNY Mellon N.A. and or Pershing Advisor
Solutions, LLC may be higher or lower than those charged by other Financial Institutions.
In addition to its service agreement with BNY Mellon N.A. and Pershing Advisor Solutions, LLC,
through strategic arrangements, BPBI offers custody services through Fidelity Advisor Solutions
(“Fidelity”) and Inversora Bursatil S.A. de C.V. Mexico (collectively “the Custodians”). The
Custodian’s platforms provide BPBI with certain benefits including custody, clearing and reporting
services, online access for clients, as well as access to an institutional trading desk, and access
to a wide range of investment products and services they make available to us that assist BPBI
in monitoring and/or servicing client accounts for which we would otherwise have to pay. These
services may include investment-related research, pricing information and market data, marketing
support, computer hardware and/or software, educational conferences and events or other
benefits useful to BPBI in providing investment advisory services to clients. The receipt of
economic benefits from the Custodians may create a potential conflict of interest. It may act as
an incentive for BPBI to recommend the Custodians and to increase assets at the Custodians in
order to decrease its expenses and receive other benefits. BPBI does not recommend a particular
custodian, broker, or service provider to receive research or other economic benefits. Clients are
not obligated to use the services of Bank of New York, PAS, Pershing or Fidelity and may select
a different Qualified Custodian provided that it meets BPBI’s due diligence and other
requirements.
GenTrust, LLC
BPBI has entered into a sub advisory and service agreement with GenTrust, an unaffiliated SEC
registered investment advisor. The agreement with BPBI is material to our business. The
arrangement provides BPBI with access to customized portfolios, and access to its custodian and
clearing platforms, research, marketing material, administrative benefits and office space. BPBI
believes that this arrangement is beneficial to its business and its clients. Pursuant to this
agreement, a portion of the total fee paid to BPBI for advisory services is allocated to GenTrust
for investment management, administrative and operational support services. BPBI may be
incentivized to recommend GenTrust in order to receive economic benefits. We manage this
potential conflict through disclosure, so that clients can make an informed decision and through
policies and procedures which require us to act in the client’s best interests.
please register to get more info
BPBI’s fiduciary duty to our clients is the underlying principle for our Firm’s Code of Ethics, which
includes procedures for personal securities transaction and insider trading. As a fiduciary, it is
BPBI’s responsibility to provide fair and full disclosure of all material facts and to act in the best
interest of our clients at all times. BPBI requires all employees and Access Persons to conduct
business with high ethical standards and to comply with all federal and state securities laws. BPBI
and its employees/Access Persons must conduct business in an honest, ethical, and fair manner
and avoid all circumstances that might negatively affect or appear to affect our duty of complete
loyalty to all clients. Upon employment with our Firm, and at least annually thereafter, all BPBI
employees and Access Persons are required to acknowledge receipt, understanding and
compliance with BPBI’s Code of Ethics.
BPBI recognizes that the personal investment transactions of our employees and Access Persons
demands the application of a Code of Ethics with high standards and requires that all such
transactions be carried out in a way that does not endanger the interest of any client. At the same
time, BPBI also believes that if investment goals are similar for clients and for our employees and
Access Persons, it is logical, and even desirable, that there be common ownership of some
securities.
In order to prevent conflicts of interest, BPBI has established procedures for transactions effected
by our employees and Access Persons for their personal accounts. In order to monitor compliance
with our personal trading policy, BPBI has pre-clearance requirements for certain types of
transactions and a quarterly and annual securities transaction reporting requirement for all of our
employees and Access Persons and accounts of their immediate family members (spouses and
children or other family members residing in the same household).
Neither BPBI nor any employees or Access Persons may recommend, buy or sell for client
accounts, securities in which BPBI or an employee or Access Person has a material financial
interest without prior disclosure to the client.
BPBI employees and Access Persons may buy or sell securities and other investments that we
also recommended to clients. In order to minimize this conflict of interest, our employees and
Access Persons are required place client interests ahead of their own interests and adhere to our
Firm’s Code of Ethics. The Code of Ethics provides that at all times Access Persons must act in
the client’s best interests and client orders must always take precedence. Failure to abide by the
Code of Ethics may subject the Access Person to sanctions including termination of employment.
This disclosure is provided to give all clients a summary of our Code of Ethics. If a client or a
potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly
upon request by contacting us at the number listed on the cover of this Brochure.
please register to get more info
BPBI will generally use the Custodian’s brokers to execute securities transactions. BPBI believes
that using the Custodian’s broker relationships will be in the best interest of its clients. BPBI has
found the using the custodian’s broker relationships is consistent with its obligation to seek best
execution and the fees and other charges and commissions charged are reasonable in relation
to the value of services provided. The executing brokers may act on an agency or riskless principal
basis for a variety of securities and other investments. Although BPBI will seek to obtain
competitive rates, to the benefit of all clients, BPBI may not necessarily obtain the lowest possible
commission rates for specific client account transactions. Client may pay a fee or commissions
that is higher than another broker may charge to effect the same transaction.
In selecting third party brokers, BPBI may consider research among many other factors. In such
cases, clients may pay higher commissions or mark-ups/markdowns than if BPBI selected a
broker that does not provide research. BPBI may have an incentive to select the broker providing
research, instead of obtaining the most favorable price, or lowest commission for Clients. To the
extent BPBI receives research; BPBI will use it to benefit all clients.
In seeking best execution, the determinative factor is not the lowest possible cost, but whether
the transaction represents the best qualitative execution, taking into consideration the full range
of the executing broker’s services, including the institution’s financial strength, reputation,
soundness, execution capability, commission rates, and responsiveness. BPBI will periodically
evaluate the quality and cost of services received. As part of its evaluation, BPBI will consider the
quality and cost of services available from alternative brokers, as well as the institution’s
capabilities, financial strength, reputation, soundness and responsiveness.
Soft Dollars
BPBI does not direct client transactions to a particular broker in return for soft dollar benefits.
BPBI currently has no formal soft dollar arrangements.
Directed Brokerage
Clients may direct BPBI in writing to use a particular broker or financial institution to execute some
or all transactions for the client. Client directed brokerage may cost clients more money and
under such arrangements, BPBI may be unable to achieve the most favorable execution of client
transactions. For example, in a directed brokerage arrangement, clients may pay higher
brokerage commissions because BPBI may not be able to aggregate orders to reduce transaction
costs, or clients may receive less favorable prices.
Trade Aggregation and Allocation
If practicable, BPBI may aggregate transactions for execution in order to facilitate best execution
and allow for the negotiation of more favorable brokerage commissions.
In such cases, client portfolio orders for the same security will be combined or aggregated and
executed as a block transaction and the average execution price on all of the purchases and sales
that are aggregated will be used for all accounts. A partial fill will be allocated randomly among
client accounts, or in a manner that is fair to all clients. This practice may not always affect or
otherwise reduce fees, commissions or other costs charged to clients, or provide price
improvement. In any given situation, BPBI attempts to allocate trade executions in the most
equitable manner possible, taking into consideration client objectives, current asset allocation and
availability of funds using price averaging, proration and consistently non-arbitrary methods of
allocation.
Principal and Cross Trades BPBI does not engage in principal trades, or effect agency cross transactions for client accounts.
Any cross transactions between client accounts would be done on an exception basis, in
accordance with applicable rules and only if it is in the best interests of the clients involved.
Errors BPBI seeks to identify and rectify errors as quickly as possible. BPBI has a trade error procedure
that requires supervisory personnel to review and approve trade corrections.
please register to get more info
Our advisory personnel reviews client accounts at least on a quarterly basis. The nature of these
reviews is to learn whether client accounts are in line with their investment objectives,
appropriately positioned based on market conditions, and investment policies, if applicable. BPBI
may review client accounts more frequently than described above. Among the factors which may
trigger a more often reviews are major market or economic events, the client’s life events, client
meetings, requests by the client and other factors.
BPBI may provide written reports to clients, upon request. Verbal reports to clients generally take
place at least a quarterly basis.
please register to get more info
Referral Fees
BPBI has not entered into solicitor or referral agreements with independent solicitors, for the
referral of clients to our Firm, but may do so at any time in accordance with the provisions in Rule
206 (4)-3 of the “Advisers Act and applicable state laws. Any clients referred by solicitors to BPBI
will be given full written disclosure describing the terms and fee arrangements between BPBI and
the solicitor(s). This arrangement will not result in higher costs to the referred client. In cases
where state law requires licensure of solicitors, BPBI shall ensure that no solicitation fees are paid
unless the solicitor is registered as an investment advisor representative in that state.
please register to get more info
BPBI does not maintain physical custody of client assets. Client assets must be maintained by
the Bank of New York, the Custodians or Financial Institutions that are Qualified Custodians. The
limited ability for BPBI to instruct the Client’s custodian to deduct our advisory fees results in BPBI
being deemed to exercise custody over client assets.
The Custodians have agreed to send statements to the client, at least quarterly, indicating all
amounts disbursed from the account including the amount of investment advisory fees paid
directly to BPBI and/or to the Independent Manager(s). We urge Clients to carefully review the
statements received from the custodians and to promptly notify us of any inconsistencies, or if
they have not received their account statements.
If BPBI sends supplemental reports to clients, clients are urged to compare the account
statements received from the Qualified Custodian with those reports received from our Firm and
inform us of any errors or discrepancies. Clients are encouraged to raise any questions with us
about the custody, safety or security of their assets.
please register to get more info
Clients have the option of providing BPBI with investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. By granting investment discretion, BPBI is
authorized to execute securities transactions, determine which securities are bought and sold,
and the total amount to be bought and sold. Limitations may be imposed by the client in the form
of specific constraints on any of these areas of discretion with our Firm’s written
acknowledgement.
please register to get more info
As a matter of general policy BPBI does not vote proxies for its clients. Clients will receive their
proxies and other solicitations directly from the issuer or a third party assigned by the issuer as
instructed by the custodian that holds the security.
BPBI will not vote or provide advice on other corporate actions, or tender offers, which do not
require a proxy, or are not solicited via a proxy. BPBI will not vote or provide any advice about the
voting of proxies solicited by, or with respect to, legal proceedings, including bankruptcies and
class actions, or their issuers, except to the extent required by law. Correspondence related to
class action lawsuits, legal proceedings, bankruptcies and proceedings involving an issuer whose
equity or debt securities are held in client accounts will be mailed directly to the client and remains
the responsibility of the client.
Clients may request a copy of our written policies and procedures regarding proxy voting by
contacting us at the number listed on the cover of this Brochure.
please register to get more info
BPBI has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients. Also, BPBI has not been the subject of any bankruptcy proceedings.
Item 19: Requirements for State-Registered Advisors This item is not applicable.
please register to get more info
Open Brochure from SEC website