The firm’s advisory business was founded in 1984. Oppenheimer + Close, LLC, a
Delaware limited liability company (“Oppenheimer + Close”), is a registered investment
adviser. Oppvest LLC, a Delaware limited liability company (“Oppvest”), is an affiliated
registered investment adviser owned and managed by the owners and managers of
Oppenheimer + Close. Prior to September 2013 the firm’s business was conducted
through Oppenheimer + Close, Inc., a New York corporation. The firm’s principal owner
is Carl K. Oppenheimer.
Advisory services for individually managed accounts
Our focus is on “value” investing, and our horizon is long term. The majority of our
research is conducted internally. Our primary focus is on exchange-listed or over-the-
counter equity securities, both domestic and foreign. We use insured bank deposits and
short-term Treasury issues for uninvested reserves. While we have not done so recently,
we are not precluded from investing in warrants, corporate debt, municipal securities,
exchange-traded funds, or money market funds if we perceive opportunity for profit at
appropriate risk. We meet with and speak to clients regularly, and portfolios are tailored
to the needs of individual clients. In general, clients will have the same portfolio
holdings. Weightings may vary based on liquidity needs, timing of purchase, or other
factors including risk tolerance and investment objectives. We generally attempt to
accommodate investment restrictions imposed by clients (for example: an aversion to
tobacco or casino companies).
We obtain certain information from clients to determine financial condition and
investment objectives. In the process of obtaining the information, we may provide
ancillary financial planning and consultative services including asset allocation, risk
management and income planning. Such financial planning and consultative services are
intended to better design an investment portfolio consistent with long-term needs and
goals.
Clients are responsible for notifying us of any updates regarding financial situation, risk
tolerance or investment objectives including modifications to existing investment
restrictions; however we contact clients regularly to discuss any changes or updates that
would alter investment objectives.
Advisory Services for ERISA plans
We provide an additional service for accounts held away from our primary custodian.
These are primarily 401(k) accounts, 403(b)s, and other assets through an arrangement
with Pontera Solutions Inc.
Clients who engage us to provide asset management services for their ERISA plan wish
to have an investment manager select their investments from among the Plan’s available
investment options and manage their accounts for them. When determining asset
allocation in a participant’s account we consider the participant’s investment options
offered by the plan, retirement timeframe, life stages, risk tolerance and overall financial
picture, including assets held outside the Plan.
We strongly advise clients to review the Subscription Agreement, Terms & Conditions,
and Privacy Policy of Pontera Advisors Solutions, Inc to understand the scope of
contractual obligations.
Retirement Plan Rollover Recommendations
When Oppenheimer + Close provides investment advice regarding a retirement plan
account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue
Code (the “Code”), as applicable, which are laws governing retirement accounts. The
way Oppenheimer + Close makes money creates some conflicts with the interest of
clients, so Oppenheimer + Close operates under a special rule that requires us to act in
such client’s best interest and not put our interest ahead of such client’s. Under this
special rule’s provisions, Oppenheimer + Close must:
1) Meet a professional standard of care when making investment recommendations (give
prudent advice);
2) Never put our financial interests ahead of clients when making recommendations (give
loyal advice);
3) Avoid misleading statements about conflicts of interest, fees, and investments;
4) Follow policies and procedures designed to ensure that we give advice that is in the
clients best interest;
5) Charge no more than is reasonable for our services; and
6) Give clients basic information about conflicts of interest.
A conflict of interest arises when we make a rollover recommendation because it may
result in compensation that we would not have received absent the recommendation. We
can earn increased investment advisory
fees by recommending that clients roll over their
account at the retirement plan to an IRA managed by Oppenheimer + Close and we will
earn fewer investment advisory fees if clients do not roll over the funds in the retirement
account.
We have taken steps to manage this conflict of interest. We have adopted an impartial
conduct standard whereby our investment adviser representatives will (i) provide
investment advice to a retirement plan participant regarding a rollover of funds from the
retirement plan in accordance with the fiduciary status described below, (ii) not
recommend investments which result in Oppenheimer + Close receiving unreasonable
compensation related to the rollover of funds from the retirement plan to an IRA, and (iii)
fully disclose compensation received by Oppenheimer + Close and our supervised
persons and any material conflicts of interest related to recommending the rollover of
funds from the retirement plan to an IRA and refrain from making any materially
misleading statements regarding such rollover.
When providing advice to clients regarding a retirement plan account or IRA, our
investment advisor representatives will act with the care, skill, prudence, and diligence
under the circumstances then prevailing that a prudent person acting in a like capacity
and familiar with such matters would use in the conduct of an enterprise of a like
character and with like aims, based on the investment objectives, risk, tolerance, financial
circumstances, and a client’s needs, without regard to the financial or other interests of
Oppenheimer + Close.
Advisory services for pooled investment vehicles
Oppvest manages three limited partnerships (two are hedged). Following is a brief
description of each.
P. Oppenheimer Investment Partnership, LP invests in undervalued securities and in
securities issued by special-situation companies.
Oppenheimer-Spence Financial Services Partnership, LP focuses its investment
activities on publicly traded issuers in the financial services industry, including, but not
limited to, banks, savings and loan associations, securities brokerage firms, mutual fund
management companies, insurance companies, credit unions, mortgage origination and
service companies.
Oppenheimer-Close Investment Partnership, LP invests opportunistically without
focusing on any particular industry or geographic region, but limits investment in the
financial services industry to no more than 7.5% of assets at the time of purchase. There
is the same 7.5% restriction for investments in non-public companies and alternative
assets.
Subadvisors
P. Oppenheimer Investment Partnership has engaged SCSP Capital Advisors to manage a
segregated account capped at $1,000,000 established for the sole purpose of acquiring
shares of a specific security. SCSP Capital Advisors has the power to manage the
account for the limited purpose of purchasing, selling, exchanging, converting, and
entering into trades or otherwise effecting transactions in the shares on behalf of the P.
Oppenheimer Investment Partnership, LP.
Brokerage services
With few exceptions, our clients, including the pooled investment vehicles we manage,
use the brokerage services of Pershing Advisor Solutions LLC, an affiliate of The Bank
of New York Mellon Corp. Pershing Advisor Solutions LLC is an introducing broker-
dealer that clears its transactions on a fully disclosed basis through Pershing LLC, an
affiliate of Pershing Advisor Solutions LLC. Pershing LLC also acts as qualified
custodian. Clients with individually managed accounts may elect to have their assets
held at Pershing LLC or at the custodian of their choice.
Participation in Wrap Fee Programs
A wrap-fee program is defined as any advisory program under which a specified fee or
fees not based directly upon transactions in a client’s account is charged for investment
advisory services (which include portfolio management and/or advice concerning the
selection of other investment advisers) and the execution of client transactions. We do
not offer or participate in wrap-fee programs. All our services are provided on a non-
wrap fee basis which means fees and expenses for execution of client transactions
charged by your broker/dealer and/or custodian are billed directly to the account
separately from our advisory fees.
We do not publish research reports or sell newsletters. We conduct no other business.
As of December 31, 2023, our assets under management were $216,797,433, of which
$213,152,674 were assets managed on a discretionary basis and $3,644,759 were assets
managed on a non-discretionary basis.