BPS Capital Management, Inc. was founded in 1983 and is an independent and privately- owned investment advisory firm. C. Mike McLaren (CEO/President) and Gary Walen (VP/CCO/CFO) are the shareholders.

BPS Capital Management, Inc. is registered with the Securities & Exchange Commission and currently manages over $3.1 billion. BPS Capital Management, Inc. provides discretionary and nondiscretionary investment advisory services to its clients.

For our discretionary clients, BPS Capital generally manages the clients' portfolios and makes investment decisions without consultation with the client. This includes deciding when to trade and changes to asset allocation within the constraints of the client's investment policy statement. In addition, BPS votes proxies for discretionary clients' securities.

For our nondiscretionary clients, services offered include the following: - Liaison between clients and dealer community. - Acting as buying/selling agent for clients (primarily financial institutions). - Assistance with formulation of comprehensive investment strategies tailored to clients’ unique circumstances. - Assistance with formulation of comprehensive policies and structures to facilitate implementation. - Assistance with collection of pertinent market and security information. - Analysis of transactions executed or proposed for clients.

Nondiscretionary: Since our customers will be mostly small- to medium-sized financial institutions, the securities portfolio will be managed as an integral part of the total balance sheet. Within this framework, securities will be bought and sold in accordance with the following priority goals: 1) liquidity adequacy, 2) overall assessed quality, and 3) after-tax income maximization. Assets will be almost solely composed of fixed income securities chosen to reflect the above prioritized goals. Maturity lengths will normally be short to intermediate (i.e. 15 yrs or less). Security types will be primarily U.S. treasury, government agency, general obligation and revenue obligations of municipalities and money market instruments. Securities will be sold before maturity as opportunities in the market arise to maximize the clients' after tax income within the liquidity and quality parameters set forth by clients. Implicit in recommended strategies will be the notion that investment strategy must be integrated to a very high degree into the strategy and constraints of the individual client. please register to get more info

The discretionary accounts are billed in arrears, on a quarterly basis. Fees for investment advisory services are generally a percentage of assets under management. In the event of termination, pro-rata billing applies and the client will be billed for the amount due. Agreements may be terminated by either party with thirty (30) days written notice.

Nondiscretionary fee schedule: A negotiable percentage (%) of adjusted par value, expressed in basis points, or a negotiated fixed fee based on assets under management. 1/12th of projected annual fee is due each month based on adjusted par value indicated at previous month end. Contract termination requires 60 day notification and is effective at the month end following this 60-day term. Refund policy: not applicable. please register to get more info

BPS Capital Management, Inc. does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). please register to get more info

BPS Capital Management, Inc. provides portfolio management services to individuals, high net worth individuals (clients with at least $1 million of investment assets), banking institutions, corporations, pension and profit-sharing plans, charitable institutions, foundations, endowments and non-profit organizations. please register to get more info

Nondiscretionary: Since our customers will be relatively small- to medium-sized financial institutions, the securities portfolio will be managed as a residual asset. Within this framework, securities will be bought and sold in accordance with the following priority goals: 1) Liquidity adequacy 2) Overall assessed quality 3) Capital considerations 4) Asset/Liability mix 5) After-tax income maximization

Assets will be almost solely composed of fixed income securities chosen to reflect above prioritized goals. Maturity lengths will normally be short to intermediate (i.e. 15 yrs or less) with overall durations in the 2- to 7-year area. Security types will be primarily U.S. treasury, government agency, general obligation and revenue obligations of municipalities and money market instruments. Portfolios will be managed on a proactive basis which allows for taking advantage of opportunities in the market as they present themselves. This management style will always keep the stated objectives of the client, the investment policies, and the stated goals as the priorities. Although BPS Capital cannot insure against risk of loss of principal, the investment philosophy of BPS Capital is to minimize this risk to the greatest extent possible. Implicit in recommended strategies will be the notion that investment strategy must be integrated to a very high degree into the strategy and constraints of the individual client.

Discretionary: Investing in securities involves risk of loss that clients should be prepared to bear. BPS Capital Management, Inc. manages the risk inherent in the financial markets through asset allocation and security selection. Different asset classes perform well or poorly in varied market environments. Including a broad array of asset classes can reduce risk while producing more stable returns over time. BPS’s asset allocation approach includes domestic & international equities and taxable & non-taxable fixed income as well as alternatives such as commodities, precious metals, real estate and, where appropriate, hedge funds. Our fixed income style is centered around sector analysis as well as yield curve management. The percentages invested in each asset class will vary from client to client. Each client’s asset allocation is tailored to his/her stated risk tolerance as well as his/her investment time horizon and the goals for a particular portfolio. All of this information is documented in an investment policy statement (IPS) designed specifically for each client. Each client’s IPS is reviewed with the client at each meeting and adjusted as client’s needs change. please register to get more info

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of BPS Capital Management, Inc. or the integrity of BPS Capital Management, Inc.’s management.

BPS Capital Management, Inc. has no information applicable to this item. please register to get more info

BPS employees do not hold any active securities, insurance, or other licenses with or away from BPS. We are not affiliated with any broker/dealer or with any custodian. Our employees have no relationships with any futures, commodity pool, commodity trading or anyone associated with such organizations. As part of its fiduciary duties to clients, BPS Capital endeavors at all times to put the interest of its clients first. BPS Capital acknowledges its duty to seek best execution of trades for client accounts. please register to get more info

BPS Capital has adopted a Code of Ethics which describes the standards of business, fiduciary and ethical conduct we require of our employees. Among other things, the Code of Ethics requires employees to comply with all applicable laws, prohibits misuse of material non-public information, and regulates personal securities trading by employees. The Code requires all employees to periodically submit, and the Chief Compliance Officer to review, their securities holdings and transactions. Employees are required to report any violations of the Code to the Chief Compliance Officer.

BPS Capital Management, Inc.’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Gary Walen.

Individuals associated with BPS Capital may buy or sell securities, specifically mutual funds or ETFs, identical to those recommended to clients. Individuals associated with BPS Capital may hold interest or positions in mutual fund families which may also be recommended.

BPS Capital Management, Inc., as a firm, does not engage in securities transactions for its own account. However, our officers, employees and members of their families will, at times, purchase or sell the same securities for their own accounts which we purchase and sell for our clients. In the event that an employee desires to purchase or sell a security that is owned by BPS clients, he/she cannot do so without written authorization from a BPS officer prior to execution of any trades for his/her account. All questions arising in connection with personal securities trading are resolved in favor of the client even at the expense of the interests of employees.

The Chief Compliance Officer may grant exceptions to certain provisions contained in the Code only in those situations when it is clear beyond dispute that the interests of our clients will not be adversely affected or compromised. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts, the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons at BPS Capital Management, Inc. must acknowledge the terms of the Code of Ethics upon accepting employment and annually, or as amended, thereafter. please register to get more info

For nondiscretionary accounts, the applicant places orders for client accounts within the guidelines established at the time the Investment Advisory Agreement is negotiated. Commissions are not paid, and dealers are selected on the basis of the lowest net cost to the client. Exceptions occur only when a client specifically directs the applicant to or from specific broker/dealers.

BPS Capital manages accounts on a discretionary basis subject to certain client-imposed limitations and client-established goals. The firm usually determines which securities are to be bought or sold and the amount of securities to bought or sold.

BPS will determine the broker/dealer to be used and the commission rates paid. In all cases, primary consideration is given to a broker/dealer's ability to execute an order on a timely and advantageous basis.

BPS Capital Management, Inc. does not participle in any “soft dollar” arrangements or contracts. please register to get more info

For our discretionary accounts, we typically review at least every 4 months, and, in most cases, accounts are reviewed more frequently. Account reviews would be triggered by date, excess cash, overdrawn status, client reviews, changes in client circumstances, and significant changes in market conditions and/or our investment strategies. Reviews are performed by a portfolio manager, and each portfolio manager handles as many clients as they can while continuing to maintain a high level of personal attention. For nondiscretionary accounts, no more than 100 clients will be assigned to any single manager. For our discretionary accounts, reports are typically furnished on an as-needed basis. The reports generally include performance, portfolio holdings, transaction summary, realized gains and losses, and financial statement (net worth). For nondiscretionary accounts, the following information is provided monthly: executive summary, security inventory, maturity distribution, asset allocation, accounting reports, and asset/liability reports. Asset/liability reports and call report data are also supplied quarterly. Additionally, miscellaneous portfolio analysis reports are furnished on an as- needed basis. please register to get more info

If a BPS Capital Management, Inc. client, employee or affiliate refers a new customer, that client, employee or affiliate may be compensated with a referral fee. please register to get more info

Discretionary clients should receive, at a minimum, quarterly statements from the broker/dealer, bank or other qualified custodian that holds and maintains the clients’ investment assets. BPS Capital Management, Inc. urges you to carefully review such statements and compare such official custodial records to the account statements that we provide to you on at least a quarterly basis. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.

BPS reconciles your accounts with your custodial statements on a periodic basis - at a minimum, quarterly. Clients should carefully review both the custodial statements and the BPS appraisals provided quarterly with your billing statement. please register to get more info

BPS Capital Management, Inc. receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. A client may limit such discretion by informing BPS in writing of any securities that it does/does not want to purchase or sell. Such limitations will be documented in the client’s personalized investment policy statement, which is usually reviewed at each client meeting. Clients may also direct that their accounts be held away from BPS- recommended custodians or brokers. The client will advise BPS in writing as to their wishes. When selecting securities and determining amounts, BPS Capital Management, Inc. observes the investment policy statements, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to BPS Capital Management, Inc. in writing, and they are reviewed, at a minimum, on an annual basis with the client. please register to get more info

BPS Capital Management, Inc. forwards proxies to clients for their execution. please register to get more info

BPS Capital Management, Inc. has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. Item 19 Requirements for State-Registered Advisers: BPS Capital Management, Inc. is registered with the Securities & Exchange Commission. General Business Experience Related to the Investment Area: C. Michael McLaren (1947). Springfield Jr. College, AA General Business. University of Illinois, BS Finance Business. Executive Director, P.E.R.A., 10/1979 to 9/1984. Institutional Bond Broker, M.H. Novick, 5/85 to 9/87. Portfolio Manager, BPS Associates, Inc., 9/1987 to 3/2002. President & CEO, BPS Capital Management, Inc., 3/2002 to present.

Gary Walen (1954). Augsburg College, BA Business Administration and Economics. Advertising Sales, MSP Publications, 2/1977 to 6/1983. Institutional Fixed Income Sales, Dougherty, Dawkins, Strand & Yost, 7/1983 to 12/1986. Portfolio Manager, BPS Associates, Inc., 1/1987 to 3/2002. Vice President & CFO, BPS Capital Management, Inc., 03/2002 to present.

Eric Swanson, CFA (1988). Bethel University, BA Economics and Finance. CFA Institute, Chartered Financial Analyst.1 Portfolio Manager & Fixed Income Analyst, BPS Capital Management, Inc., 6/2011 to present.

Erin Swanson, CFA (1982). Bethel University, BA Mathematics. CFA Institute, Chartered Financial Analyst.1 Medical Records Specialist, Allina Hospitals and Clinics, 8/2004 to 10/2009. Fixed Income Analyst, BPS Capital Management, Inc., 8/2012 to present.

Judson McLaren (1988). Union University, BA Business Administration & Management. Inside Sales Representative, Pioneer Pipe, 8/2015 to 8/2019. Vice President of Business Development, BPS Capital Management, Inc., 8/2019 to Present.

1The Chartered Financial Analyst (CFA) charter is a globally respected, graduate level investment credential established in 1962 and awarded by CFA Institute, the largest global association of investment professionals. There are currently more than 107,000 CFA charterholders working in 135 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations, 2) have at least four years of qualified professional investment experience, 3) join CFA institute as members, and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standard of Professional Conduct. please register to get more info