Firm Description HCM was established as a New York limited liability company in April 2000
and approved as a SEC registered investment adviser on October 6, 2017.
HCM was formerly a New York State registered investment adviser. The
Investment Adviser’s principal business and occupation is to provide financial
management and advisory services to individuals, corporations, and other
institutional clients throughout the world.
Principal Owners Hideji Horiko owns 99% of the HCM.
Types of Advisory Services HCM serves as investment manager for 3 private investment funds. In
particular, HCM provides investment advice to investment vehicles formed as
a domestic entity (a limited partnership) and a foreign entity (a Cayman Island
exempt company and Unit Trust). HCM also provides discretionary
investment advice to other domestic and foreign institutional clients, including
high net worth individuals. As investment manager, HCM offers investment
advice and management in the following types of securities:
- US and Non-US Equity and equity related securities
- Event arbitrage activities involving US and Non-US companies
- Fixed and adjustable rate US Government and Agency bonds, US Treasury
Notes and US Treasury Bills
- Debt Securities and instruments issued by US and Non-US corporations
- Futures contracts, foreign exchange commitments, leverage contracts,
currencies
- Commodities and commodity interests
As of DECEMBER 31, 2019, HCM manages $202,727,637 in assets for 3
investment vehicles and 1 high net worth individuals on a discretionary basis.
Tailored Relationships The goals and objectives for each client are documented in the investment
management agreement with each client. Investment policy statements are
created that reflect the stated goals and objective. The investment
management agreement may impose restrictions on investing in certain
securities or types of securities.
Agreements may not be assigned without client consent.
Types of Agreements The following agreements define the typical client relationships.
Investment Management Agreement HCM provides discretionary investment advisory services as an investment
manager for its clients pursuant to various investment management
agreements, limited partnership agreements and operating agreements.
HCM's investment management fees are determined by, among other factors,
the strategy, the type of assets to be managed, the intensity of the analysis
required, and the size of the pool of the assets. HCM may also provide
financial planning services to its individual clients. The base annual fee
schedule typically ranges between 1.0% and 3.0% of assets under
management.
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Description HCM bases its fees on a percentage of assets under management.
Customary base fee schedule is as follows:
Assets Fee (Annually)
$100,000 - $499,999 3.0%
$500,000 - $999,999 2.5%
$1,000,000 - $4,999,999 2.0%
$5,000,000 - $9,999,999 1.5%
$10,000,000 + 1.0%
Investment Management Fees are negotiated with each client, and HCM may,
in its sole discretion, waive a portion of its customary base fees. Investment
Management fees are prorated for partial periods. Additionally, HCM may
also receive fees resulting from early redemptions from certain funds which
have a minimum investment period. These fees are up to 2%.
Investment Advice or consulting services may also be provided irrespective of
AUM. Such advice is subject to a fee of up to $500/hour PLUS expenses
including reimbursable expenses.
Fee Billing Investment management fees are payable in arrears, daily, monthly, quarterly
or annually depending on the type of account. Fees may be deducted from a
designated client account to facilitate billing. The client must consent in
advance to direct debiting of their investment account.
Other Fees Custodians may charge transaction fees on purchases or sales of certain
investment vehicles. These transaction charges are usually small and
incidental to the purchase or sale of a security. The selection of the security
is more important than the nominal fee that the custodian charges to buy or
sell the security.
HCM, in its sole discretion, may waive its customary base minimum fee
and/or charge a lesser investment advisory fee based upon certain criteria
(e.g., historical relationship, type of assets, anticipated future earning
capacity, anticipated future additional assets, dollar amounts of assets to be
managed, related accounts, account composition, negotiations with clients,
etc.).
Past Due Accounts and Termination of Agreement HCM reserves the right to stop work on any account that is more than 30
days overdue.
Performance-Based Fees Sharing of Capital Gains HCM may receive performance-based compensation in addition to investment
management fees. Performance-based compensation is 20% and is paid
annually or quarterly in arrears based on increases in an account's or
investment vehicle's net asset value. Performance-based compensation is
prorated for partial periods.
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Description HCM's current investment management clients are either corporations,
partnerships, high net worth individuals or accounts that have been
established by a group of investors. For each such fund or account, HCM has
been appointed investment manager pursuant to an investment management
agreement or limited partnership agreement with each fund or account.
HCM may also provide financial planning services as part of its asset
management to individual clients. Client relationships vary in scope and
length of service.
Account Minimums
The minimum initial investment amount is $100,000 USD although HCM has
discretion to accept lesser amounts. HCM may also raise the minimum
investment amount at any time, in its sole discretion.
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Methods of Analysis and Investment Strategies The investment strategy of HCM is to invest primarily in common stocks of
companies that HCM believes are undervalued in the securities markets. HCM’s
strategy also include investments in fixed income securities and from time to time,
holding significant amounts of cash, money-market funds, U.S. Government
bonds, commercial paper or similar securities.
To select equity securities for the client, HCM seeks to identify companies that it
understands well and that possess one or more of the following characteristics:
⚫ Positive (or projected positive) revenue or profit trends;
⚫ Healthy balance sheet, characterized by ample cash relative to debt, efficient
working capital management, high or increasing liquidity, or other metrics that
the Investment Adviser believes indicate the company’s ability to withstand
unexpected shocks, reinvest in the business, and improve its business
prospects and circumstances;
⚫ Strong free cash flow generation;
⚫ Powerful and sustainable competitive advantages;
⚫ Management team that: a) operates the business well and has a sound strategy
to build it over time; b) allocates capital wisely to enhance shareholder value;
and c) has high integrity; and
⚫ Policies (e.g., compensation structures) that do not significantly dilute
shareholders’ ownership.
Most importantly, HCM seeks to identify companies whose stocks are trading, in
the opinion of HCM, at a substantial discount to their intrinsic value. In
determining discount to intrinsic value, HCM considers the following factors:
⚫ Substantial discount from a price at which the securities of comparable
businesses have been sold in arms’ length transactions between parties judged
to be competent businesspersons;
⚫ Substantial discount to the value of the business determined by cash flow
analysis and qualitative strengths; and/or
⚫ Substantial discount from asset value based on the total value of the company’s
individual parts and assets, less the present value of its liabilities.
When selecting short candidates for inclusion in the client’s portfolio, HCM’s
objective is to identify companies with one or more of the following
characteristics:
⚫ Prospects of at least 35% downside in valuation;
⚫ Flawed business strategies and product positioning;
⚫ Declining fundamentals;
⚫ Unexpected changes in management;
⚫ Accounting irregularities or aggressive practices.
HCM intends to take short positions in the stock of these companies following
indications of problems in such company’s fundamentals. HCM intends to cover
these short positions when HCM believes the fundamentals have stopped
deteriorating.
HCM also intends to invest in “special situations” to achieve its objective. A
special situation arises when, in the opinion of HCM, securities of a company will,
within a reasonably estimated time, appreciate in value due to developments
particularly or uniquely applicable to that company without regard to general
business conditions or movements of the market as a whole. Such developments
and situations include, but are not limited to, liquidations, reorganizations,
recapitalizations or mergers. To identify companies and securities meeting the
client’s criteria, HCM generally employs fundamental analysis to determine the
value of a company and its securities and then compares those results to current
market values. Securities trading at significant discounts to perceived values are
candidates for investment.
HCM’s fixed income strategy includes investing in a wide range of securities
including US corporate debt, non-US corporate debt, bank debt, US government
and agency debt, shot-term debt obligation of foreign governments and foreign
money market instruments, convertible bonds and other convertible securities
without regard to maturity or the rating of the issuer of the security, and in lower-
rated securities believed mis-rated by the market. The strategy pursues a positive
absolute return using investments in fixed income that focus on income,
appreciation and capital preservation.
There can be no assurance that HCM will achieve its objectives.
Risk of Loss All investment programs have certain risks that are borne by the investor.
Prospective clients should give careful consideration to the following risk
factors in evaluating the merits and suitability of an investment. The following
does not purport to be a comprehensive summary of all the risks associated
with an investment. Rather, the following are only certain particular risks to
which the investment is subject;
• Interest-rate Risk: Fluctuations in interest rates may cause investment
prices to fluctuate. For example, when interest rates rise, yields on
existing bonds become less attractive, causing their market values to
decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of
risk is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social
conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will
not buy as much as a dollar next year, because purchasing power is
eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the
value of the dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from
investments may have to be reinvested at a potentially lower rate of
return (i.e. interest rate). This primarily relates to fixed income
securities.
• Business Risk: These risks are associated with a particular industry or
a particular company within an industry. For example, oil-drilling
companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from
a steady stream of customers who buy electricity no matter what the
economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment
into cash. Generally, assets are more liquid if many traders are
interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
• Cyber Risk: The information and technology systems of HCM and of
key service providers to HCM and its clients may be vulnerable to
potential damage or interruption from computer viruses, network
failures, computer and telecommunication failures, infiltration by
unauthorized persons and security breaches, usage errors by their
respective professionals, power outages and catastrophic events such
as fires, tornadoes, floods, and hurricanes. If HCM’s systems are
compromised, become inoperable for extended periods of time, or
cease to function properly, significant interruptions could occur in the
operations of HCM or its client Accounts and may result in a failure to
maintain the security, confidentiality or privacy of sensitive data,
including personal information.
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Legal and Disciplinary The firm and its employees have NOT been involved in legal or disciplinary
events related to past or present investment clients.
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Neither HCM nor its representatives are registered as, or have pending
applications to become, a broker/dealer or a representative of a broker/dealer.
Neither HCM nor its representatives are registered as or have pending
applications to become either a Futures Commission Merchant, Commodity
Pool Operator, or Commodity Trading Advisor or an associated person of the
foregoing entities.
Affiliations HCM is a General Partner of a pooled investment vehicle. This is a conflict of
interest. HCM earns management fees and performance fees as a General
Partner. To mitigate this conflict of interest HCM acts as a fiduciary and
makes investment recommendations in the best interests of the client. HCM
also waives its advisory management fee as the client’s registered investment
adviser and only earns fees as the investment manager to the pooled
investment vehicle.
HCM does not direct clients to third party money managers.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of HCM have committed to a Code of Ethics that is available
for review by clients and prospective clients upon request. The firm will
provide a copy of the Code of Ethics to any client or prospective client upon
request.
Participation or Interest in Client Transactions and Personal Trading From time to time, HCM may recommend securities that HCM is a General
Partners of a pooled investment vehicle.
Employees of HCM may buy or sell securities that HCM recommends to, or
trades for, clients. Such transactions are monitored by HCM and governed by
CFA Institute's Code of Ethics and Standards of Professional Conduct. The
Codes impose certain obligations regarding personal trading and establish
internal monitoring procedures for HCM.
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Selecting Brokerage Firms HCM generally has investment discretion to place portfolio transactions and
select brokers without the prior approval of clients. HCM seeks to obtain the
most favorable net results for clients including price, execution quality,
services and commissions. Although HCM seeks competitive commission
rates, it may at times pay commissions on behalf of clients which may be
higher than those available from other brokers in order to achieve superior
execution or services. HCM may enter into such transactions so long as it
determines in good faith that the amount of commission paid was reasonable
in relation to the value of the brokerage and research services provided by
the broker. HCM does not have any affiliation with product sales firms. HCM
does NOT receive Soft Dollar Benefits.
HCM maintains the ability to block trade purchases and sales across
accounts. Block trades may be used if it is advantageous to client accounts in
achieving best execution in a purchase or sale of a security. Block trading
may not be utilized if it is determined that it will not result in best execution for
client accounts.
HCM does not allow directed brokerage. HCM requires the use of the prime
broker for execution of client transactions. Not all advisers require clients to
use a specific custodian.
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Periodic Reviews All accounts are reviewed continuously by one reviewer, Erik J. Doran, Chief
Compliance Officer of HCM. Hideji Horiko, President & CEO of HCM bears
the ultimate responsibility for capital commitment and risk management. All
trades executed for an account will be reviewed and approved by the
president. Computer systems have been created which enable HCM to
continuously monitor the position and market risk of each account. Each fund
also retains a public accounting firm that reviews pricing annually and in so
doing must look at the monthly prices. The accounting firm independently
verifies security prices in the portfolio either through broker quotes, internal
models or through an outside pricing service.
Review Triggers Other conditions that may trigger a review are changes in the tax laws, new
investment information, and changes in a client's own situation.
Regular Reports Clients receive periodic communications on at least quarterly basis. The
written updates may include a net worth statement, portfolio statement, tax
related document (annually), and a summary of objectives and progress
towards meeting those objectives.
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Incoming Referrals HCM has been fortunate to receive many client referrals over the years. The
referrals came from current clients, estate planning attorneys, accountants,
employees, personal friends of employees and other similar sources. The
firm does not compensate referring parties for these referrals.
Referrals Out HCM does not accept referral fees or any form of remuneration from other
professionals when a prospect or client is referred to it.
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Account Statements All assets are held at qualified custodians, which means the custodians
provide account statements directly to clients at their address of record at
least quarterly.
HCM is the General Partner of a pooled investment vehicle. HCM follows the
Rules of custody as required of pooled investment vehicles by having a
financial statement audit conducted with copies of the financial statement
audit provided to limited partners of the pooled investment vehicle.
Performance Reports Clients are urged to compare the account statements received directly from
their custodians to the performance report statements provided by HCM.
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Discretionary Authority for Trading HCM accepts discretionary authority to manage securities accounts on behalf
of clients. HCM has the authority to determine, without obtaining specific
client consent, the securities to be bought or sold, and the amount of the
securities to be bought or sold. For each fund or account, HCM has been
appointed investment manager pursuant to an investment management
agreement or limited partnership agreement with each fund or account.
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Proxy Votes HCM does not vote proxies on securities. Clients are expected to vote their
own proxies. When assistance on voting proxies is requested, HCM will
provide recommendations to the Client. If a conflict of interest exists, it will be
disclosed to the Client.
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Financial Condition HCM does NOT have any financial impairment that will preclude the firm from
meeting contractual commitments to clients.
A balance sheet is NOT required to be provided because HCM does NOT
serve as a custodian for client funds or securities, and does NOT require
prepayment of fees of more than $1200 per client, and six months or more in
advance.
Information Security Program Information Security HCM maintains an information security program to reduce the risk that your
personal and confidential information may be breached.
Privacy Notice HCM is committed to maintaining the confidentiality, integrity and security of
the personal information that is entrusted to us.
The categories of nonpublic information that we collect from you may include
information about your personal finances, information about your health to the
extent that it is needed for the financial planning process, information about
transactions between you and third parties, and information from consumer
reporting agencies, e.g., credit reports. We use this information to help you
meet your personal financial goals.
With your permission, we disclose limited information to attorneys,
accountants, and mortgage lenders with whom you have established a
relationship. You may opt out from our sharing information with these
nonaffiliated third parties by notifying us at any time by telephone, mail, fax,
email, or in person. With your permission, we share a limited amount of
information about you with your brokerage firm in order to execute securities
transactions on your behalf.
We maintain a secure office to ensure that your information is not placed at
unreasonable risk. We employ a firewall barrier, secure data encryption
techniques and authentication procedures in our computer environment.
We do not provide your personal information to mailing list vendors or
solicitors. We require strict confidentiality in our agreements with unaffiliated
third parties that require access to your personal information, including
financial service companies, consultants, and auditors. Federal and state
securities regulators may review our Company records and your personal
records as permitted by law.
Personally identifiable information about you will be maintained while you are
a client, and for the required period thereafter that records are required to be
maintained by federal and state securities laws. After that time, information
may be destroyed.
We will notify you in advance if our privacy policy is expected to change. We
are required by law to deliver this
Privacy Notice to you annually, in writing.
Brochure Supplement (Part 2B of Form ADV) HIDEJI HORIKO, President and CEO Date of birth: 9/18/1965
Education: Kwansei Gakuin University - B.A. Economics (1988)
Stern School of Business, New York University - M.B.A. Finance (2000)
Business Background:
- President and CEO of HORIKO CAPITAL MANAGEMENT LLC,
responsible for all financial and operational aspects. (2000-Present)
- Foreign Exchange Trader and Vice President of Bank of Tokyo-Mitsubishi,
New York Branch (1988-1999).
Disciplinary Information: None
Other Business Activities: A member of the General Partner of a pooled
investment vehicle.
Additional Compensation: None
Supervision:
HIDEJI HORIKO is the President & CEO of Horiko Capital Management
LLC and has the responsibility for supervising supervised persons,
himself included. HIDEJI HORIKO agreed to abide by HCM Employee
Handbook and by CFA Institute's Code of Ethics and Standards of
Professional Conduct
SUPERVISOR’S contact information:
347-284-6751
[email protected]
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