CATAMOUNT MANAGEMENT GROUP, LLC, DBA Catamount Wealth Management (hereinafter
referred to as CWM), provides investment advisory services to clients. CWM offers this service to
high net worth individuals and small businesses (including retirement account(s), pension and
profit sharing plans, trusts, estates, charitable organizations, partnerships and corporations).
CWM’s investment strategy is preservation of capital—to protect first, then grow. We are a
strategic, active manager constantly monitoring market cycles and trends. We emphasize stock
selection particularly in the Large/ Mid Cap Growth sectors.
A. CWM has been in business since 2003 and the Principal Owner, Managing Partner, Louis
Albanese, has been in the financial industry for 35 years. Laurie Stefanowicz joined the
firm in 2008 and became Managing Partner in 2015.
B. CWM provides investment advice only. CWM does not sell any products. Investment
recommendations made by CWM are not limited to but generally include the following
vehicles:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign ADR’s (American Depository Receipts)
• Certificates of deposit
• Mutual fund shares
• United States governmental securities
• Corporate and municipal bonds
• Exchange traded funds
C. In general clients have similar combinations of stocks (growth & dividends), bonds, and
cash) but with modifications based on the client’s needs, objectives, risk tolerances and
tax situation. Clients may in writing, at any time, impose restrictions on investing in certain
securities, or types of securities, such as “sin stocks” (i.e. tobacco).
D. We do not participate in a wrap fee program—please see below Item 5 regarding Fees
and Compensation.
E. CWM utilizes Fidelity Investments as our main custodian. This provides our clients with
immediate access and complete control over their assets at all times. CWM offers two
different advisory arrangements for investment services clients:
1. Discretionary account with CWM’s main custodian, Fidelity Investments (or)
2. Discretionary account with client-selected custodian.
*Under this agreement (2), clients can select the custodian/ broker-dealer to be
used to implement recommended transactions. Clients will be charged separate
and typical commissions, mark-ups, and mark-downs by their broker-dealer.
CWM traditionally does not accept non-discretionary accounts however CWM does have non-
discretionary legacy accounts that are an exception. As of December 31, 2018, CWM has
$232,244,583 in assets under management. $223,316,416 is on a discretionary basis and
$8,928,167 is on a non-discretionary basis.
SEMINARS: CWM sponsors educational seminars on various investment topics including portfolio analysis.
The investment information provided under this service does not purport to meet the objectives
or needs of each individual client. The seminars will provide participants with discussions on
asset allocation strategies, estate and retirement planning, and general educational topics.
CWM seminars are free and open to the public.
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CWM is a fee only registered investment advisor with the fiduciary responsibility to act in their
clients’ best interest. We do not accept any fees or compensation based on product sales. We
have no conflicts of interest and do provide comprehensive advice.
A. The annual management fee charged by CWM for investment advisory services
(excluding a ticket charge) ranges from .625% to 1.75%. The exact fee to be charged to
a client is based on the size and complexity of a client’s portfolio and is disclosed to the
client prior to the client entering into an investment advisory agreement with CWM.
Under certain circumstances, fees may be negotiable. CWM may group certain related
client accounts for the purposes of achieving the minimum account size requirements
and determining the annualized fee. Discounts not generally available to advisory clients
of CWM may be offered to family members and friends of associated persons of the firm.
B. Clients are invoiced in advance (at the beginning of each quarter) based upon the
closing value of the client’s account of the immediately preceding calendar quarter, or
as of the date and value reported on the client’s brokerage statement. The “value” of a
client’s portfolio is determined by the market value of the client’s account as reported by
the custodian.
The Client has two choices of how to arrange payment of fees:
1) CWM is authorized to deduct directly for its fees (or)
2) CWM is authorized to invoice Client directly for the payment of its fees. Any such
payment shall be made to CWM by separate check, and under no circumstance shall
any fee be deducted from amounts held in the Account. All checks are made payable
to Fidelity Investments.
C. For households with $1million or greater in assets, Fidelity charges $4.95. For households
with less than $1million in assets, when enrolled in e-delivery, Fidelity charges $4.95 per
trade, otherwise $7.95 per trade. Fees separate from the investment advisory fees i.e.
fund related expenses charged directly by money market funds and mutual funds, which
may be included within an investment advisory client’s account. A complete
explanation of expenses charged by mutual funds is contained in each mutual fund’s
prospectus.
D. Clients will be invoiced in advance (at the beginning of each quarter) based upon the
closing value of the client’s account of the immediately preceding calendar quarter, or
as of the date and value reported on the client’s brokerage statement. The “value” of a
client’s portfolio is determined by the market value of the securities held in the client’s
account as reported by the custodian. If client terminates the Advisory Agreement, fees
will be refunded by CWM to the client, on a pro-rata basis, based on the number of days
remaining in the calendar quarter when notice of termination was received.
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CWM provides investment advisory services to individuals and small businesses including
retirement account(s), pension and profit sharing plans, trusts, estates, charitable organizations,
and corporations. CWM requires a minimum of $500,000 of assets to be placed under
management. This minimum amount may be negotiable under certain circumstances. Clients
include but not are not limited to physicians, attorneys, business executives, other professionals
and retirees.
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Our investment strategy is conservative and sensible, geared to building wealth over the long
term. We look to grow our clients’ assets over time by compounding returns, not over days or
months, but over a complete market cycle. This is how we implement our strategy.
Identify Market Trends
Understanding overall market trends is a key element in investing. After that, it is finding the
balance between participating in a rising market and preserving your capital in a declining
market. We do not limit ourselves to a “buy and hold” mentality but rather adapt to market
conditions and invest accordingly.
Establishing Parameters
We employ stop-loss protection in order to limit our downside risk and preserve principal. The
understanding is that the discipline of selling is just as important as buying. In addition, such
strategy takes the emotion out of investing which also prevents major losses.
Risk vs. Reward
When evaluating an investment, it is important to understand the concept of risk vs. reward. In
the simplest terms, the higher the reward, the greater the risk. We work closely with our clients to
tailor investment portfolios that align with their goals and objectives but more importantly match
their expectations.
Diversification
A diversified portfolio is essential to protecting and managing risk. Diversification can be
achieved typically through different positions which represent multiple industry sectors. We build
portfolios of complementary investments, typically a mixture of growth stocks, dividend equities
and bonds, both domestic and international.
Building Wealth
Once we have established a solid foundation, we focus on providing clients with superior returns
and less volatility. Our investment plan is simple—a plan steeped in a philosophy adhering to a
long term, disciplined strategy; one that is flexible with its expectations and rigid with its rules of
investing. We focus on our client’s goals and objectives so that they can maintain their lifestyle.
At CWM we continuously assess our investments in terms of current market conditions and
opportunities. We monitor our positions and evaluate them against our stringent screening
criteria. We stay agile, adjusting as necessary in order to optimize profitability. Tactics that
support our strategy for long-term wealth management include:
Monitoring Macroeconomic Trends
We pay close attention to the myriad of influences on the financial markets. Factors include the
political landscape, monetary and fiscal policy, economic data and forecasts, foreign markets
and exchange rates, inflation trends, interest rates, investor sentiment, etc.
Modifying Positions
We manage portfolios pro-actively. We consistently adjust and upgrade clients’ portfolios to
combat the ever-changing investment environment by identifying the newest leaders, sectors
and industries. Such management aims toward maximizing gains and mitigating losses
Extensive Research
Research is key to our investment philosophy. William O’Neil, a prominent third party research
firm, is a main source of our research. There are thousands of publicly traded companies across
hundreds of industry groups. We identify and select top performing companies based on:
• Key Fundamental analytics including:
• Financial strength, cash flow, earnings acceleration
• Management quality, dedication and experience
• Top quality, innovative products, strong pipeline
• Market share, competition
• Key Technical analytics including:
• Top sectors
• Trading range and volume
• Liquidity
• Best of breed
*Past performance does not guarantee future results. As with all investing there are inherent risks.
CWM tries mitigating risks by utilizing a stop loss strategy and constantly monitoring the market
conditions.
Stringent Selection Process
When choosing equities, we select companies that are market leaders based on their
competitive advantage and their proven ability to innovate. These companies tend to enjoy
commanding market share, giving them pricing leverage which is a key component for reliable
profitability.
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A. CWM has adopted a Code of Ethics (“Code”) to comply with Rule 204A-1 under the
Investment Advisers Act of 1940 (“Advisers Act”). A full copy of the Code of Ethics
can be distributed upon request. The Code establishes rules of conduct for all
employees of CWM and is designed to, among other things; govern personal
securities trading activities in the accounts of employees, their immediate
family/household accounts and accounts in which an employee has a beneficial
interest. The Code is based upon the principle that CWM and its employees owe a
fiduciary duty to CWM’s clients to conduct their affairs, including their personal
securities transactions, in such a manner as to avoid (i) serving their own personal
interests ahead of clients, (ii) taking inappropriate advantage of their position with
CWM and (iii) any actual or potential conflicts of interest or any abuse of their
position of trust and responsibility. The Code is designed to ensure that the high
ethical standards long maintained by CWM continue to be applied. The purpose of
the Code is to preclude activities which may lead to or give the appearance of
conflicts of interest, insider trading and other forms of prohibited or unethical business
conduct. CWM is prohibited from engaging in fraudulent, deceptive or manipulative
conduct. Compliance with this section involves more than acting with honesty and
good faith alone. It means that CWM has an affirmative duty of utmost good faith to
act solely in the best interest of its clients.
CWM is subject to the following specific fiduciary obligations when dealing with clients:
• The duty to have a reasonable, independent basis for the investment advice provided;
• The duty to obtain best execution for a client’s transactions where the Firm is in a
position to direct brokerage transactions for the client;
• The duty to ensure that investment advice is suitable to meeting the client’s individual
objectives, needs and circumstances; and
• A duty to be loyal to clients.
CWM expects every employee to demonstrate the highest standards of ethical conduct for
continued employment, and employees understand that a material breach of the provisions
of the Code may constitute grounds for disciplinary action, including termination of
employment with CWM.
B. No principal or employee of CWM may buy or sell securities for his/her personal
portfolio(s) where his/her decision are a result of information received as a result of
his/her employment, unless the information is also available to the investing public.
C. CWM and/or individuals associated with CWM may buy and sell for their personal
accounts the same underlying securities as clients and may therefore have an interest in
the same securities owned by or recommended to CWM’s clients. CWM has adopted
procedures relating to personal securities transactions, insider trading and internal
trading that are designed to prevent client harm resulting from this conflict of interest. In
addition, CWM’s Code of Ethics requires, among other things, that employees submit
their personal and related trading accounts to the Chief Compliance Officer for review.
CWM has also adopted supervisory procedures that are designed to detect front-
running, or trading ahead of or opposite clients.
D. CWM maintains a list of all reportable securities holdings for CWM and anyone
associated with this advisory practice that has access to advisory recommendations
("access person"). These holdings are reviewed on a regular basis by CWM‘s Chief
Compliance Officer or by her designee.
E. CWM has established procedures for the maintenance of all required books and records.
F. Clients can decline to implement any advice rendered, except in situations where CWM
is granted discretionary authority.
G. All principals and employees of CWM must act in accordance with all applicable
Federal and State regulations governing registered investment advisory practices.
H. Delivery and acknowledgement of the Code of Ethics is required by each supervised
person of CWM.
I. CWM has established policies requiring the reporting of Code of Ethics violations to its
senior management.
J. Any individual who violates any of the above restrictions may be subject to termination.
K. No principal or employee of CWM may put his or her own interest above the interest of
an advisory client.
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CWM has an arrangement with Fidelity Investments as its primary custodian but the client has
the choice of custodian.
Fidelity provides services to CWM which include, brokerage, custody, and managing and
administering clients' accounts which includes (i) provide access to client account data (such as
trade confirmations and account statements); (ii) facilitate trade execution and allocate
aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other
market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-
office functions, recordkeeping and client reporting.
CWM routinely recommends Fidelity Investments as a custodian, but clients have the option to
use the custodian of choice. CWM reserves the right to decline acceptance of any client
account for which the client directs the use of a broker other than Fidelity Investments if we
believe that this choice would hinder our fiduciary duty to the client and/or our ability to service
the account. In directing the use of a broker other than Fidelity Investments, it should be
understood that CWM will not have authority to negotiate commissions or to necessarily obtain
volume discounts, and best execution may not be achieved. In addition, a disparity in
commission charges may exist between the commissions charged to the client and those
charged to other clients who may direct the use of another broker.
CWM does not receive any compensation or soft dollars for recommendations. But please note,
if client chooses to work with another custodian, the client must negotiate terms and
arrangement for the account that broker or custodian and CWM will not seek better execution
services or prices from other brokers or be able to “batch” client transactions for execution. As a
result, client may pay higher commissions or other transactional costs or greater spreads or
receive less favorable net prices on transactions for the account than would otherwise be the
case.
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A. The underlying securities within individual portfolio management services accounts are
continually monitored, Accounts are reviewed in the context of each client's stated
investment objectives and guidelines. More frequent reviews may be triggered by
material changes in variables, such as the client's individual circumstances or the market,
political or economic environment. Daily reviews of client accounts are conducted by
Louis Albanese, President, and Laurie Stefanowicz, Vice President of CWM.
B. Clients receive monthly statements and trade confirmations from Fidelity Investments, or
their designated custodian, quarterly reports are provided by CWM summarizing
account performance, balances, and holdings. CWM utilizes Black Diamond software
and services for the purpose of account reconciliation and to calculate quarterly
performance reports.
C. Clients receive a written Quarterly report and newsletter as well as several verbal reports
throughout the year.
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It is CWM’s policy not to engage solicitors or to pay related or non-related persons for referring
potential clients to our firm.
It is CWM’s policy not to accept or allow our related persons to accept any form of
compensation, including cash, sales awards or other prizes, from a non-client in conjunction with
the advisory services we provide to our clients.
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As a matter of policy and practice, CWM does not permit employees or the firm to accept or
maintain custody of client assets. CWM does not accept, hold, directly or indirectly, client funds
or securities, or have any authority to obtain possession of them. CWM will not take custody of
client cash or securities.
If CWM receives inadvertently from a client any funds or securities, these assets shall be returned
to the client promptly and within three business days of receipt. No employee or supervised
person of CWM shall knowingly accept actual possession of any client funds or securities.
Persons receiving a request from a client to deposit assets with a qualified custodian may assist
the client to complete necessary forms and/or mailings, but shall not take actual possession of
the funds or securities.
We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our
firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required to
send to the client a statement showing all transactions within the account during the reporting
period.
Because the custodian does not calculate the amount of the fee to be deducted, it is important
for clients to carefully review their custodial statements to verify the accuracy of the calculation,
among other things. Clients should contact us directly if they believe that there may be an error
in their statement.
In addition to the monthly statements that clients receive directly from their custodians, we also
send performance reports directly to our clients on a quarterly basis. We urge our clients to
carefully compare the information provided on these statements to ensure that all account
transactions, holdings and values are correct and current.
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CWM accepts discretionary authority to manage accounts on behalf of clients only with the
written consent of said client
1. Written consent to manage individual accounts and fee
agreements are given by clients in the form of an Investment Advisory Agreement. All Advisory
Agreements are signed by Louis Albanese, Principal Owner, Managing Partner, as well as all
account owners, before any activity occurs in the account on behalf of CWM.
1 CWM has a small number of legacy accounts that are managed on a non- discretionary basis.
The Investment Advisory Agreement will continue in effect until terminated by either party by
written notice to the other. Termination of this Agreement will not affect (a) the validity of any
action previously taken by CWM under this Agreement; (b) liabilities or obligations of the parties
from transactions initiated before termination of this Agreement; or (c) Client’s obligation to pay
advisory fees (prorated through the date of termination). On the termination of this Agreement,
CWM will have no obligation to recommend or take any action with regard to the securities,
cash or other investments in the Account. No Advisory Agreement may be assigned by either
party without the written consent of the other.
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Catamount Wealth Management (CWM) believes that proxy voting and corporate
governance, in general, are important elements of the portfolio management services provided
to advisory clients. CWM’s intention with proxy voting is to make decisions that (i) maximize a
company's shareholder value and (ii) are not influenced by conflicts of interest.
A client may authorize CWM to vote proxies and may obtain a summary report relating to their
account by contacting our office. A client may also obtain a copy of our complete proxy voting
policies and procedures upon request.
Proxy Voting Procedures CWM has adopted these procedures with the premise that portfolio management personnel
base their determinations of whether to invest in a particular company on a variety of factors,
and while corporate governance is one such factor, it may not be the primary consideration.
If the client grants permission, CWM will vote proxies for securities held in the Account. CWM is
authorized and directed to instruct the Custodian to forward promptly to CWM copies of all
proxies and shareholder communications relating to securities held in the Account (other than
materials relating to Legal Proceedings). Upon receipt of proxy voting materials CWM will log
onto proxyvote.com and enter the proxies assigned control numbers. CWM’s policy is to vote in
favor of the recommendation by the Board and submit the voted shares accordingly. All proxy
voting materials are saved electronically and logged with date and decision record.
Client agrees that CWM will not be responsible or liable for failing to vote any proxies where it
has not received such proxies or related shareholder communications on a timely basis.
Client Direction Clients may choose to vote proxies themselves, in which case they must arrange for their
custodians to send proxy materials directly to them. If clients choose to receive proxies directly,
CWM is available to answer any questions or concerns regarding said materials.
Abstaining from Voting Certain Proxies CWM shall at no time ignore or neglect their proxy voting responsibilities. However, there may
be times when refraining from voting is in the Client’s best interest, such as when CWM’s analysis
of a particular proxy issue reveals that the cost of voting the proxy may exceed the expected
benefit to the Client. Such proxies may be voted on a best-efforts basis. These issues may
include, but are not limited to restrictions for share blocking countries, untimely notice of
shareholder meetings, and requirements to vote proxies in person.
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Under no circumstances does CWM require or solicit payment of fees in excess of $1,200 per
client six or more months in advance of services rendered. Therefore, CWM is not required to
include a financial statement in its Brochure.
As an advisory firm that maintains discretionary authority for client accounts, CWM is also
required to disclose any financial condition that is reasonably likely to impair its ability to meet its
contractual obligations. CWM has no additional financial circumstances to report.
CWM has not been the subject of a bankruptcy petition at any time.
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Open Brochure from SEC website