A. Ownership Information Nardis Advisors LLC (hereinafter referred to as "Nardis," the "Registrant" or the "Firm") was founded in August of 2009 as an independent registered investment adviser. Nardis is registered with the Securities and Exchange Commission (hereinafter referred to as the "SEC"). The Firm is 100% owned by Norman H. Chait, CFA, its Managing Principal.
B. Advisory Services Ofered Nardis' investment advisory services are limited to the discretionary or non-discretionary management of investment portfolios in accordance with the investment objectives of the client. We do not provide fnancial planning services.
C. Types of Advisory Services Tailored Investment Advisory Services Nardis will tailor its investment advisory services to the individual needs of clients. Nardis nonetheless generally advises similarly-situated clients in a similar manner. Nardis will accept reasonable investment restrictions to be imposed on the management of client accounts.
We primarily allocate our clients' investment management assets on a discretionary and/or a non-discretionary basis among exchange traded funds and individual debt and/or equity securities in accordance with the investment objectives of each client.
Nardis focuses upon the creation of personalized and customized investment portfolio solutions for each client. Each client portfolio is based on:
•a review of the personal needs, goals and specifc circumstances of each client
•an assessment of each client's risk tolerance Nardis' client engagement contract includes a schedule which lists each client's:
•level of wealth and annual income;
•years of investment experience in various asset classes;
•investment time horizon;
•level of annual income needs; investment goals (in terms of the balance between capital preservation and capital appreciation); and
•level of portfolio and market volatility the client is willing to withstand. Nardis may also render non-discretionary investment management services to clients relative to: (1) variable life/annuity products that they may own, and/or (2) their individual employer-sponsored retirement plans. In so doing, the Firm either directs or recommends the allocation of client assets among the various mutual fund subdivisions that comprise the variable life/annuity product or the retirement plan. The client's assets shall be maintained at either the specifc insurance company that issued the variable life/annuity 4 product, or at the custodian designated by the sponsor of the client's retirement plan. Nardis does not sell insurance or annuities and does not receive a commission when the client purchases these products.
Nardis may recommend that clients invest in private placement securities, which requires that the client be an "accredited investors," as defned under Rule 501 of the Securities Act of 1933. These private placement securities may include debt, equity and/or pooled investment vehicles, when consistent with the client's investment objectives. When we recommend that the client invest in private placement securities, Nardis shall receive no additional compensation, but shall continue to receive applicable investment advisory fees on the client's assets under management.
The Firm may also provide advice about exchange traded funds (hereinafter "ETFs") and any type of investment held in a client's portfolio at the beginning of the advisory relationship.
Nardis may recommend that clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers, based upon the stated investment objectives of the client. We will continue to render services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers as well as the monitoring and review of account performance and client investment objectives.
When recommending or selecting an Independent Manager for a client, we shall review information about the Independent Manager, such as its disclosure statement and/or material supplied by the Independent Manager or independent third parties, for a description of the Independent Manager's investment strategies, past performance and risk results to the extent available.
Consulting Services Nardis may provide consulting services (which may or may not include non-investment related matters). The Firm's Advisory Afliates may also provide expert testimony in trials and arbitrations as part of our consulting services.
Nardis may charge a separate fee for these services which shall be agreed upon prior to rendering the services. We anticipate that approximately fve (5%) of our time will be devoted to such services.
In performing the aforementioned services, we shall not be required to verify any information received from the client or from the client's other professionals (e.g., attorney, accountant, etc.) and are expressly authorized to rely on such information. Nardis may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a confict of interest exists if Nardis recommends its own services. The client is under no obligation to act upon any of the recommendations made by Nardis under a consulting engagement and/or engage the services of any such recommended professional, including the Firm itself. The client retains absolute discretion over all such decisions and is free to accept or reject any of our recommendations. Moreover, clients are advised that it remains their responsibility to promptly notify the Firm if there is ever any change in their fnancial situation or investment objectives for the purpose of reviewing, evaluating or revising Nardis' previous recommendations or services.
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clients to whom Nardis provides consulting services will receive reports from the Firm summarizing its analysis and conclusions, as requested by the client, or otherwise agreed to in writing. Prior to engaging Nardis to provide consulting services, the client will be required to enter into a written agreement with us, setting forth the terms and conditions of the engagement and describing the scope of the services to be provided and the portion of the fee that is due from the client prior to the commencing of services. For hourly fees, we generally require a portion of the consulting fee (estimated hourly), payable upon the commencement of the written agreement. The balance is commonly due upon completion of the agreed upon services. For retainer clients, Nardis charges its fee monthly in arrears.
Either party may terminate the agreement by written notice to the other. In the event the client terminates Nardis' consulting services, the balance of the Firm's unearned fees, if any, shall be refunded to the client. If termination occurs within fve business days of entering into the agreement for such services, the client shall be entitled to a full refund.
Clients may impose reasonable investment restrictions, including restrictions on particular securities or types of investments, subject to our agreement. Nardis requires that any requests for investment limitations or restrictions be made in writing. Clients should be aware that performance of restricted portfolios may difer from performance of portfolios without such restrictions, which may afect overall returns.
Socially Responsible Proprietary Investment Models We ofer two model portfolios based on socially responsible indices. These Investment Models are managed by Nardis through its advisors, using model portfolios provided by third-party investment advisers/portfolio managers that we select. The model portfolios are provided to us by agreement from the third-party providers and are based on socially responsible investment strategies rather than the fnancial situation or investment need of any specifc individual. Nardis will develop an asset allocation strategy designed to meet the investment needs and risk tolerances of clients and will employ these models to implement the strategy. Nardis may deviate from the instructions in certain circumstances, such as when a Client imposes a restriction or is soon to be withdrawing money from the Account. It can also replace a third-party investment manager after providing notice to client.
Selection of Third-Party Money Manager We may recommend that you utilize the services of a third-party money manager ("TPMM") to manage a portion of or your entire portfolio. After gathering your Suitability Information, we will make recommendations regarding the suitability of investing with a TPMM.
Upon selection of a TPMM, we will monitor the performance of the TPMM to ensure their performance and investment style remains aligned with your investment goals and objectives. You may be required to sign an agreement directly with the TPMM selected. You, our Firm, or the TPMM, in accordance with the provisions of those agreements, may terminate the advisory relationship. 6 Types of Investments We primarily ofer advice on Equities, Fixed Income, and Alternative investments. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specifc fnancial situation, the investment advice we provide to you may be diferent or conficting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conficts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our fnancial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conficts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conficts of interest. We beneft fnancially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fduciary, we only recommend a rollover when we believe it is in your best interest.
D. Wrap Programs Nardis does not have a wrap fee program. E. Amount of Assets Under Management As of December 31, 2023, Nardis advised $118,809,442 in discretionary assets and $7,253,726 in non-discretionary assets, for a total $126,063,168 of assets under management.
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