Advisory Services: Corinthian Partners Asset Management LLC (CPAM) provides comprehensive investment management
services to individuals, corporations, trust estates and pension fund clients. No publication or report is
issued for a fee. CPAM is a wholly owned subsidiary of Corinthian Holdings LLC and is affiliated through
common ownership by Corinthian Holdings, LLC with Corinthian Partners, LLC (CP) a full-service
registered Broker-Dealer offering securities brokerage, investment banking and servicing individual and
institutional investors. CP is a member of FINRA and clears through RBC Capital Markets / RBC
Correspondent Services. CPAM had been conducting business as a registered state investment advisor for
16 years prior to becoming a federally registered investment advisor on July 01, 2019. Principal executive
officers are Mitchell Manoff, CEO of Corinthian Partners, LLC for the last 16 years and Richard Calabrese
President/Chairman of Corinthian Partners, LLC for last 16 years.
CPAM offers a variety of investment management styles, including fixed income, balanced and equity
strategies. CPAM will purchase or sell securities for client accounts using strategies and methods such as
charting, fundamental and technical.
Corinthian Partners Financial Planning Service is designed as a long-term, ongoing financial planning
relationship to help you achieve your financial goal. You will work with your financial advisor to define
your goals while adhering to the six-step financial planning process defined by the Certified Financial
Planner Board of Standards, Inc.as follows:
* Establishing and defining the client-planner relationship,
* Gathering client data including goals,
* Analyzing and evaluation the client’s current financial status,
* Developing and presenting recommendations and/or alternatives
* Implementing the financial planning recommendation(s)
* Monitoring the recommendations.
Financial planning subject areas are as follows:
* Financial statement preparation and analysis (including cash flow analysis/planning and budgeting),
* Insurance planning and risk management,
* Employee benefits planning,
* Investment planning,
* Retirement planning,
* Estate planning.
Financial Planning and Consulting Services:
Financial planning is a comprehensive evaluation of a Client’s current and future financial state by using
currently known variables to predict futur
e cash flows, asset values and withdrawal plans. The key defining
aspect of financial planning is that through the financial planning process, all questions, information and
analysis will be considered as they impact and are impacted by the entire financial and life situation of the
Client. Clients purchasing this service will receive a written report, providing the Client with a detailed
financial plan designed to achieve his or her stated financial goals and objectives
Implementation of financial plan recommendations is entirely at the Client’s discretion. Our investment
and financial planning recommendations are not limited to any specific product or service offered by any
broker dealer or insurance company, including our affiliates.
CPAM also provides various consulting services to Clients on an ad hoc basis pursuant to a separate
agreement.
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CPAM provides comprehensive investment management services to individuals, corporations, trust
estates and pension funds.
CPAM offers a variety of investment management styles, including fixed income, balanced and equity
strategies. CPAM will purchase or sell securities for client accounts using strategies and methods
described in Part 2A 4. Fees are based on the market value of the accounts quarterly appraisal and are
payable in advance. Corinthian investment services provide negotiable fees but are typically structured up
to 2.0% of assets. Asset-based Program fees are calculated as a percentage of the account value including
the full value of any assets purchased on margin. Fees are generally payable in advance on a quarterly
basis and are calculated based on our appraisal of the market value of the billable assets in the account as
of the last business day of the preceding calendar quarter or based on the value provided by the custodian.
Currently CPAM does not compensate anyone for client referrals however CPAM has the option to
compensate certain representatives by paying a percentage of the advisory fee received. These agreements
do not increase cost to the client and have no impact on advisory fees. Representatives are required to
comply with all SEC, state and federal laws for client referrals.
Financial planning services are charged as a separate fee and are negotiated on either a fixed rate basis or
by the hour depending on the level of service needed and agreed upon by the Client.
CPAM may pay referral fees of up to 50% of quarterly fees. This payment will be absorbed by CPAM, not
the client. This payment will likewise have no effect on the account’s NAV. Any solicitation/referral
arrangements and solicitor referral fees must be in writing, reviewed and approved by the designated officer
and/or management, meet regulatory requirements and appropriate records maintained.
The advisory contract may be terminated by either party at any time. Such termination requires written
notice. Management fees will be prorated from the date that the termination request is received.
CPAM manages approximately $1,100,531.00 in client assets as of December 2019 on a non-discretionary
basis and $27,783,277.00 in client assets on a discretionary basis.
For purposes of managing our client’s assets, CPAM will offer the option to open a securities account
with CP for the purpose of executing securities transactions. Clients are also provided the option of
designating any other Broker-Dealer to execute transactions for their account. Clients electing to designate
CP as their executing Broker-Dealer agree that their account will be serviced by an investment adviser
representative acting in the capacity of a Registered Representative of Corinthian Partners, LLC.
The client will be responsible for paying CP execution service fees. No portion of such charges paid to CP
will be paid to the investment adviser representative.
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CPAM provides investment advisory services to individuals, trusts, estates, charitable organizations,
business and corporations, and pension and profit-sharing plans. CPAM requires a minimum investment
of $50,000 for new accounts. This minimum is at the discretion of management. CPAM will not accept
an investor as a client if such investor's investment objectives are inconsistent with the CPAM philosophy
and investment approach.
Your financial advisor will assign an overall complexity to your case based on your personal financial
circumstances and financial planning needs. CPAM minimum fee is $500.
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CPAM interviews and updates their risk tolerance and investment objectives prior to making any
recommendations to the clients. CPAM methods of security analysis include technical analysis, charting
and using fundamentals. CPAM sources of information that are referred to for investment advice include
research material prepared by outside sources, corporate rating services and annual reports and other
corporate disclosure documents, prospectuses, filings with the Securities and Exchange Commission.
CPAM investment strategies used to implement investment advice given to our clients include long term,
short term purchases. Depending upon client’s needs, long term and short-term strategies are taken into
account. While investing involves market risk the investment vehicles that are used do not have unusual
risk. Investing in securities involves risk of loss that clients should be prepared to bear.
Methods of Analysis and Investment Strategies:
CPAM’s methods of analysis include technical analysis, cyclical analysis, quantitative
analysis and modern portfolio theory.
Technical analysis involves the analysis of past market data; primarily price and volume.
Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or
selling a security.
Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such
as the character of management or the state of employee morale, such as the value of assets, the cost of
capital, historical projections of sales, and so on.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for
a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by
carefully choosing the proportions of various asset.
CPAM uses long term trading, short term trading, short sales and options trading (including covered options,
uncovered options, or spreading strategies).
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
Material Risks Involved
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then a
prediction can be made. The risk is that markets do not always follow patterns and relying solely on this
method may not take into account new patterns that emerge over time.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged
to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat
cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very
cycles these investors are trying to exploit.
Quantitative Model Risk: Investment strategies using quantitative models may perform differently than
expected as a result of, among other things, the factors used in the models, the weight placed on each factor,
changes from the factors’ historical trends, and technical issues in the construction and implementation of
the models.
Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that
offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on
increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher
expected returns must accept more risk. The exact trade-off will be the same for all investors, but different
investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a
rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected
return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns.
Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done,
can affect investment performance, particularly through increased brokerage and other transaction costs and
taxes.
Short term trading, short sales, margin transactions, and options writing generally hold greater risk and
clients should be aware that there is a material risk of loss using any of those strategies.
Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized
CPAM's use of short sales and options trading generally holds greater risk of capital loss. Clients should be
aware that there is a material risk of loss using any investment strategy. The investment types listed below
(leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the
FDIC or any other government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money
investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of
bond “fixed income” nature (lower risk) or stock “equity” nature.
Equity investment generally refers to buying shares of stocks in return for receiving a future payment of
dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate
in response to specific situations for each company, industry conditions and the general economic
environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments
can vary. This type of investment can include corporate and government debt securities, leveraged loans,
high yield, and investment grade debt and structured products, such as mortgage and other asset-backed
securities, although individual bonds may be the best-known type of fixed income security. In general, the
fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise,
bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.)
Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both
issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is
dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of
losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also
include the general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to
stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock
holding bankruptcy). Areas of concern include the lack of transparency in products and increasing
complexity, conflicts of interest and the possibility of inadequate regulatory compliance.
Annuities are a retirement product for those who may have the ability to pay a premium now and want to
guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are
contracts issued by a life insurance company designed to meet requirement or other long-term goals. An
annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet
retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals
because substantial taxes and insurance company charges may apply if you withdraw your money early.
Variable annuities also involve investment risks, just as mutual funds do.
Options are contracts to purchase a security at a given price, risking that an option may expire out of the
money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed
by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not
unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail
buying and selling multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve
risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk,
political/regulatory risk, inflation (purchasing power) risk and interest rate risk.
Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social
unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public
information available.
Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
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A. 1. There has not been a criminal or civil action in a domestic, foreign or military court of competent
jurisdiction in which the firm or a management person was; convicted of or plead guilty or nolo contendere
to any felony, a misdemeanor that involved investments or an investment-related business, fraud, false
statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion or
conspiracy to commit any of these offenses.
2. There has not been a criminal or civil action in a domestic, foreign or military court of competent
jurisdiction in which the firm or a management person was; named the subject of a pending criminal
proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery counterfeiting, extortion, or a conspiracy to commit any of
these offenses
3. There has not been a criminal or civil action in a domestic, foreign or military court of competent
jurisdiction in which the firm or a management person was; found to have been involved in a violation of
an investment-related statute or regulation.
4. There has not been a criminal or civil action in a domestic, foreign or military court of competent
jurisdiction in which the firm or a management person was; the subject of any order, judgment, or decree
permanently or temporarily enjoining, or otherwise limiting, the firm or a management person from
engaging in any investment-related activity, or from violating any investment-related statute, rule or order.
B. 1. There has not been an administrative proceeding before the SEC, any other federal regulatory agency,
any state regulatory agency or any foreign financial regulatory authority in which the firm or a
management person; was found to have caused an investment-related business to lose its authorization to
do business.
2. There has not been an administrative proceeding before the SEC, any other federal regulatory agency,
any state regulatory agency or any foreign financial regulatory authority in which the firm or a
management person was found to have been involved in a violation of an investment-related statute or
regulation and was the subject of an order by the agency or authority for any of the following:
a. denying, suspending, or revoking the authorization of our firm or a management person to act in an
investment-related business.
b. barring or suspending our firm’s or a management person’s association with an investment-related
business
c. otherwise significantly limiting our firm’s or a management person’s investment-related activities
d. imposing a civil money penalty of more than $2,500 on our firm or a management person.
C. 1. There has not been a self-regulatory organization proceeding in which our firm or a management person was found to have caused an investment – related business to lose its authorization to do business;
2. There has been a self-regulatory action involving a violation of the SRO’s rules whereby Mr. Manoff
and Mr. Calabrese were fined in an amount greater than $2,500.00 each.
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Affiliations: A. Corinthian Partners Asset Management is a wholly owned subsidiary of Corinthian Holdings LLC and
is affiliated through common ownership by Corinthian Holdings, LLC with Corinthian Partners, LLC a
full-service registered Broker-Dealer offering securities, brokerage services and investment banking.
Corinthian partners LLC services individuals, retirement accounts as well as corporations and institutional
investors. Corinthian Partners, LLC is a member of FINRA.
B. Neither the firm nor its management persons are registered or have an application pending to register
as a futures commission merchant, commodity pool operator or a commodity trading advisor, or an
associated person of the foregoing entities.
C. The following describes the nature of any relationship to our business or to our clients that the firm or
any management person has with any related person.
1. Broker-dealer, municipal securities dealer, government securities dealer or broker: As reflected
above Corinthian Partners Asset Management is a wholly-owned subsidiary of Corinthian
Holdings LLC and is affiliated through common ownership by Corinthian Holdings, LLC with
Corinthian Partners, LLC a full service registered Broker-Dealer offering securities brokerage,
investment banking and servicing individual and institutional investors Corinthian Partners, LLC
is a member of FINRA.
2. Insurance company or agency; Corinthian Partners Asset Management is a wholly-owned
subsidiary of Corinthian Holdings LLC and is affiliated through common ownership by
Corinthian Holdings, LLC with Corinthian Partners, LLC which offers health and life insurance
as well as fixed and variable annuities.
3. Pension consultant; no relationship
4. Real estate broker or dealer; no relationship
5. Sponsor or syndicator of limited partnerships; no relationship
D. We do not recommend or have business relationships with any investment advisors for our clients.
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CPAM complies with The Insider Trading and Securities Fraud Enforcement Act of 1988. CPAM
monitors the personal securities transactions of all access persons. In addition, CPAM has adopted a
written Code of Ethics in compliance with SEC Rule 204A-1. This Code is based on the principle that the
officers, directors, and employees (or persons having similar status or function) of CPAM have a
fiduciary duty to place the interests of the clients ahead of their own interests. The Code applies to all
supervised persons and focuses principally on monitoring and reporting of personal transactions in
securities. Supervised persons must avoid activities, interests and relationships that might interfere with
making decisions in the best interests of clients. CPAM adheres to the following principles:
- We are fiduciaries. Our duty is at all times to place the interests of our clients first. Supervised
persons must avoid putting their own personal interests ahead of the interests of our clients. A
supervised person may not induce or cause a client to take action, or not to take action, for personal
benefit, rather than for the benefit of the client.
- All personal securities transactions will be conducted in such a manner as to be consistent with the
Code of Ethics and to avoid any actual or potential conflict of interest or any abuse of a supervised
person's position of trust and responsibility.
- Access persons must regularly submit reports to CPAM disclosing their beneficial ownership of
securities and the acquisition and disposition of such beneficially owned securities. These reports
shall detail the (i) title and type of security; (ii) exchange ticker symbol or CUSIP number as
applicable; (iii) number of shares; (iv) principal amount of each security; (v) name of any broker,
dealer, or bank with which the access person maintains an account in which any securities are held
for the access person's direct or indirect benefit; (vi) date that the access person submits the report;
(vii) nature of the transaction (i.e., purchase, sale, or other type of acquisition or disposition); (viii)
price of the security at which the transaction was affected; (ix) name of the broker, dealer, or bank
with or through which the transaction was affected; (ix) name of the broker, dealer, or bank with
or through which the transaction was effected; and (x) date the access person submits the report,
as applicable.
- All trading by supervised persons must give preference to client portfolios. Specifically, no
supervised person may (i) purchase securities for himself or an account over which he has control
or a beneficial interest in until all CPAM client accounts to which such security has been
recommended have acquired all sought positions, or (ii) sell for himself or an account over which
he has control or a beneficial interest in until all CPAM client accounts for which such security
has been recommended to sell have sold such security.
- All supervised persons must; promptly, completely, and truthfully answer client inquiries;
maintain the confidentiality of all information that our clients have entrusted to CPAM concerning
its clients even if they leave CPAM; fully comply with all federal laws, rules, and regulations
governing the provision of investment advisory services to clients; and promptly report any
circumstances which appear to be or could be a violation of this Code to CPAM’S Chief
Compliance Officer.
Employees of CPAM or related persons thereof may have a position in certain securities which have been
recommended to clients. No officer or employee of CPAM or related persons will be allowed to trade
ahead of any client (front running is prohibited).
The Chief Compliance Officer of CPAM carries out all compliance-related mandates as set forth by the
Code of Ethics. A copy of the firm's Code of Ethics is available upon request by all clients and
prospective clients.
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Corinthian Partners, LLC conducts transactions in bonds on a principal basis. Such transactions are
executed in compliance with FINRA guidelines for markups/markdowns. Proper information appears on
clients’ confirmations of such transactions stating the executed price and the amount of
markup/markdown. Best execution is strictly enforced. CPAM does not act as a principal.
For purposes of managing client assets, CPAM offers the option to open a securities account with CP.
Clients electing to designate CP as the executing Broker-Dealer agree that the account will be serviced by
their investment manager acting in the capacity of a Registered Representative of CP.
The client will be responsible for paying CP execution service at commission rates which will be
negotiated between the client and CP. It is further understood that no portion of such charges paid to CP
will be paid to the investment adviser representative in consideration of his/her role as the registered
representative. To date, all trades have been executed through CP.
Employees of CPAM or related persons may have a position in securities being recommended to clients.
No officer of employee of CPAM or related persons, will be allowed to trade ahead of any client (front
running is prohibited).
CPAM recommends CP as broker-dealer and RBC Correspondent Services as custodian for client
accounts.
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The President/Chairman and CEO of CPAM is Richard Calabrese and Mitchell Manoff, respectively. The
two review client accounts periodically for suitability and significant changes in assets. We provide
quarterly statements to clients. However, statements are provided monthly by RBC Correspondent
Services if there is any activity. Statements include asset value, change from previous period, income and
individual assets. CPAM reviews the holdings of institutional and individual accounts. Clients may also
request a review by CPAM of their objectives and holdings on an off-cycle basis. Any development
affecting a client's holdings will trigger a review and appropriate advice being given.
Client will receive prompt notification from RBC Correspondent Services “Trade Confirmation” of any
investment made for the client's portfolio as well a monthly or quarterly statement (as applicable) showing
client's portfolio and a review of all transactions occurring during the applicable period.
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Neither Corinthian Partners, LLC or Corinthian Partners Asset Management, LLC holds client funds or
securities. They are held by RBC Capital Markets / RBC Correspondence Services.
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We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common
stock or mutual funds, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event
we were to receive any written or electronic proxy materials, we would forward them directly to you by
mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would
forward any electronic solicitation to vote proxies.
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Our firm does not have any financial conditions or impairments that would prevent us from meeting our
contractual commitments to you. We do not take physical custody of client funds or securities, or serve as
trustee or signatory for client accounts, we do not require the prepayment of fees six or more months in
advance and in excess of $1200. Therefore, we are not required to include a financial statement with this
brochure.
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Open Brochure from SEC website