Grace Capital Management, LLC is dedicated to providing individuals and other types of clients with
a wide array of investment advisory services. We specialize in offering Comprehensive Portfolio
Management and Selection of Third-Party Advisory services to our clients. Our firm is a limited
liability company formed in the State of Texas. We have been in business as an investment adviser
since 2009 and are one hundred percent (100%) owned by Mr. George Duff, Managing Member and
Chief Compliance Officer.
Types of Advisory Services Offered
Comprehensive Portfolio Management:
Our Comprehensive Portfolio Management service encompasses asset management as well as
providing financial planning/financial consulting, and pension consulting services to individual plan
participants and clients. It is designed to assist clients in meeting their financial goals through the use
of financial investments. We conduct at least one, but sometimes more than one meeting (in person,
if possible, otherwise via telephone conference) with clients in order to understand their current
financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn,
we propose an investment approach to the client. We may propose an investment portfolio,
consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities.
Upon the client’s agreement to the proposed investment plan, we work with the client to establish or
transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts
are under our management, we review such accounts on a regular basis and at least quarterly. We
may periodically rebalance or adjust client accounts under our management. If the client experiences
any significant changes to his/her financial or personal circumstances, the client must notify us so
that we can consider such information in managing the client’s investments.
Financial Planning and Consulting Services:
Financial Planning Services include, but are not limited to, a thorough review of Cash Flow,
Businesses, Wills, Estate Plan/Trusts, Investments, Taxes, and Insurance. Services are determined
based on the nature of the services provided and the complexity of each client’s circumstances. All
fees are agreed upon prior to the commencement of any services and will include entering into a
contract (the “Client Agreement”) with the client. Prior to the planning process, the client will be
provided with an estimated plan fee. Payment is required to be provided prior to service.
Selection of Third-Party Advisory Services:
We may utilize Third-Party Advisor Services, where we may design an investment portfolio and
provide ongoing corresponding asset management services on a fee-only basis for a percentage of
assets in conjunction with another investment advisory firm. Before selecting other advisers, we
make sure that the other advisers are properly licensed or registered.
In order to assist the Client in the selection of a Third-Party Advisory Service, we will typically gather
information from the Clients about the Client’s financial situation, investment objectives, and reasonable
ADV Part 2A – Firm Brochure Page 5 Grace Capital Management, LLC
restrictions the Client wants imposed on the management of the account. We will not offer advice on any
specific securities or other investments in connection with this service.
We will periodically review reports provided to the Clients, but no less often than on a quarterly basis.
The Investment Advisory Representatives of our firm will contact the Client periodically, as agreed to
with the Clients, in order to review the Client’s financial situation and objectives; communicate
information to the Third-Party Advisors managing the account as warranted; and assist the Clients in
understanding
and evaluating the services provided by the Third-Party Advisory Service. Clients will be
expected to notify us of any changes in their financial situation, investment objectives, or account
restrictions. Clients may also contact the Third-Party Advisors directly managing the account or
sponsoring the program.
IRA Rollover Recommendations:
For the purpose of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-
02"), when applicable, we are providing the following acknowledgment to clients. When we provide
investment advice to clients regarding their retirement plan account or individual retirement account,
we are a fiduciary 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 conflicts with client interests. We operate under an exemption that requires
we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under
this exemption, we must:
• meet a professional standard of care when making investment recommendations (give
prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making
recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice
that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest.
We benefit financially from the rollover of the clients’ 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 fiduciary, we only recommend a rollover when our and
our employees believe it is in the clients’ best interest.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing our firm’s Comprehensive Portfolio
Management service. Additionally, we offer general investment advice to clients utilizing our firm’s
Selection of Third-Party Advisory Service.
We usually do not allow clients to impose restrictions on investing in certain securities or types of
securities due to the level of difficulty this would entail in managing their account. In the rare instance
that we allow restrictions, it would be limited to our firm’s Comprehensive Portfolio Management
service.
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Participation in Wrap Fee Program
We sponsor and act as portfolio managers of a wrap fee program as further described in Part 2A,
Appendix 1 (the “Wrap Fee Program Brochure”). Clients participating in a wrap fee arrangement pay
a single fee for advisory, brokerage and custodial services. Clients’ portfolio transactions will be
executed without commissions charge in a wrap fee arrangement.
The overall cost you will incur if you participate in our wrap fee program may be higher or lower
than you might incur by paying transaction costs separately with another advisor. To compare the
cost of the wrap fee program with non-wrap fee portfolio management services, you should consider
the frequency of trading activity associated with our investment strategies, the brokerage
commissions charged by broker/dealers, and the advisory fees charged by investment advisers. We
will review with clients any separate program fees that may be charged to clients.
Regulatory Assets Under Management
We managed $109,475,469 on a discretionary basis and $30,540,749 on a non-discretionary basis as
of March 15, 2024.