Since This Brochure provides an overview of the investment advisory services provided by Quent
Capital, LLC (“Quent Capital”). Quent Capital is an independent investment adviser registered with
the U.S. Securities and Exchange Commission. The firm was founded in 2018 by Gregg S. Fisher. He
is the firm’s principal owner, along with the Gregg S. Fisher 2017 Descendants Trusts.
Quent Capital provides discretionary investment advisory services on a fee basis. Quent Capital’s
annual investment advisory fee shall include investment management and advisory services.
As of December 31, 2023, Quent Capital managed approximately $1,377,379,064 of assets on a
discretionary basis.
Investment Advisory Clients: To commence the investment advisory process, Quent Capital will
ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with
the client’s designated investment objective(s). Once allocated, Quent Capital provides ongoing
supervision of the account(s). Before engaging Quent Capital to provide investment advisory
services, clients are required to enter into an Investment Advisory Agreement with Quent Capital
setting forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the fee that is due from the client. Quent Capital primarily
recommends that clients allocate investment assets among various individual equity (stocks), mutual
funds and/or exchange traded funds (“ETFs”) in accordance with the client’s designated investment
objective(s). Once allocated, Quent Capital provides ongoing monitoring and review of account
performance, asset allocation and client investment objectives.
Quent Capital may provide financial planning and related consulting services matters such as estate
planning, tax planning, insurance, etc. Please Note: We do not serve as an attorney, accountant, or
insurance agency, and no portion of our services should be construed as same. Accordingly, we do
not prepare estate planning documents, tax returns or other similar documents.
Affiliated Private Fund. Quent Capital and/or its owners are affiliated with, and provide investment
management services to, a private investment fund known as the Quent Long Short Global Small Cap
Fund, LP (the “Fund”), which is a private investment fund relying on an exemption from registration
under the Investment Company Act of 1940, as amended, the complete description of which (the
terms, conditions, risks, conflicts and fees, including incentive compensation) is set forth in the
Fund’s offering documents. Quent Capital, on a non-discretionary basis, may recommend that
qualified clients consider allocating a portion of their investment assets to the Fund. If a client
determines to become an affiliated private fund investor, unless indicated to the contrary, in writing,
by Quent Capital, the amount of assets invested in the fund(s)will be included as part of our
regulatory assets under management, however, such Fund assets will not be included for purposes
of Quent Capital calculating its investment advisory fee per Item 5 below. Quent Capital’s clients are
under absolutely no obligation to consider or make an investment in a private investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not
limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a
complete discussion of which is set forth in each fund’s offering documents, which will be provided
to each client for review and consideration. Unlike liquid investments that a client may own, private
investment funds do not provide daily liquidity or pricing. Each prospective client investor will be
required to complete a Subscription Agreement, pursuant to which the client shall establish that
he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors
that are associated with such an investment.
Please Also Note: Conflict Of Interest. Because Quent Capital and/or its affiliates can earn
compensation from the Fund (i.e., management fees, incentive compensation, etc.) that could
generally exceed the fee that Quent Capital would earn under its standard asset-based fee schedule
referenced in Item 5 below, the recommendation that a client become a Fund investor presents a
conflict of interest. No client is under any obligation to become a Fund investor. Given the conflict of
interest, Quent Capital advises that clients consider seeking advice from independent professionals
(i.e., attorney, accountant, adviser, etc.) of their choosing prior to becoming a Fund investor. No
client is under absolutely any obligation to become a Fund investor. ANY QUESTIONS: Quent Capital’s
Chief Compliance Officer, Joshua Seward, remains available to address any questions regarding this
conflict of interest.
Miscellaneous. To the extent specifically requested, and engaged, by the client to do so, Quent
Capital may provide financial planning and or related consulting services regarding matters such as
tax and estate planning, insurance, etc. per the terms and conditions of a separate agreement and a
separate fee as discussed at Item 5 below, the fee for which shall generally be based upon the
individual providing the service and the scope of the services to be provided. Prior to engaging
Quent Capital to provide planning or consulting services, clients are generally required to enter into
a Financial Planning and Consulting Agreement with us setting forth the terms and conditions of the
engagement (including termination), describing the scope of the services to be provided, and the
portion of the fee that is due from the client prior to Quent Capital commencing services.
We may recommend the services of other professionals for non-investment implementation
purposes (i.e. attorneys, accountants, insurance, etc.) including Quent Capital ’s representative as a
licensed insurance agent or our affiliated tax service (under common control ), Gerstein Tax Service
(“Tax Service”), for tax preparation and accounting-related services. The client is under no obligation
to engage the services of any such recommended professional. Please Note-Conflict of Interest: The
recommendation that a client purchase an insurance commission product from Quent Capital’s
representative in his capacity as an insurance agent, presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend insurance products based on commissions to
be received, rather than on a particular client’s need. The fees charged and compensation derived
from the sale of such insurance are separate from, and in addition to, Quent Capital’s investment
advisory fee. No client is under any obligation to purchase any insurance commission products from
Quent Capital’s representative. Clients are reminded that they may purchase insurance products
recommended by Quent Capital’s representative through other, non-affiliated, insurance agents.
Further, If a client determines to engage Tax Service, he/she does so per the terms and conditions of
a separate written agreement between Tax Service and the client, to which Quent Capital is not a
party. There is no fee-sharing arrangement between the Tax Service and Quent Capital. The
recommendation by Quent Capital that a client engage Tax Service for tax preparation and/or
accounting-related services, presents a conflict of interest because Quent Capital’s affiliate will
derive additional compensation from such engagement. No client or prospective client is obligated
to engage Tax Service. Clients are reminded that they may engage other non-affiliated, providers.
Quent Capital will work with the tax professional of the client’s choosing. ANY QUESTIONS: Quent
Capital ’s Chief Compliance Officer, Joshua Seward, remains available to address any questions that a
client or prospective client may have regarding the above conflicts of interest.
If the client engages any recommended unaffiliated professional, and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged licensed professional(s), (i.e. attorney, accountant,
insurance agent, etc.), and not Quent Capital, shall be responsible for the quality and competency of
the services provided. It remains the client’s responsibility to promptly notify Quent Capital if there
is ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising Quent Capital’s previous recommendations and/or services.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an
employer typically has four options regarding an existing retirement plan (and may engage in a
combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii)
roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). If Quent Capital recommends
that a client roll over their retirement plan assets into an account to be managed by Quent Capital,
such a recommendation creates a conflict of interest if Quent Capital will earn new (or increase its
current) compensation as a result of the rollover. If Quent Capital provides a recommendation as to
whether a client should engage
in a rollover or not (whether it is from an employer’s plan or an
existing IRA), Quent Capital is acting as 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. No client is under any obligation to roll over retirement plan assets
to an account managed by Quent Capital, whether it is from an employer’s plan or an existing IRA.
Quent Capital’s Chief Compliance Officer, Joshua Seward, remains available to address any questions
that a client or prospective client may have regarding the potential for conflict of interest presented
by such rollover recommendation.
Portfolio Activity. Quent Capital has a fiduciary duty to provide services consistent with the client’s
best interest. Quent Capital will review client portfolios on an ongoing basis to determine if any
changes are necessary based upon various factors, including, but not limited to, investment
performance, market conditions, fund manager tenure, style drift, account additions/withdrawals,
and/or a change in the client’s investment objective. Based upon these factors, there may be
extended periods of time when Quent Capital determines that changes to a client’s portfolio are
neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during
periods of account inactivity.
Independent Managers. Quent Capital may allocate a portion of the client’s investment assets
among unaffiliated independent investment managers in accordance with the client’s designated
investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day
responsibility for the active discretionary management of the allocated assets. Quent Capital shall
continue to render investment supervisory services to the client relative to the ongoing monitoring
and review of account performance, asset allocation and client investment objectives. Factors that
Quent Capital shall consider in recommending Independent Manager[s] include the client’s
designated investment objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research. Please Note: The investment management fee charged by the
Independent Manager[s] is separate from, and in addition to, Quent Capital’s investment advisory
fee disclosed at Item 5 below. Please also note: Quent Capital retains the authority to terminate the
independent manager. ANY QUESTIONS: Quent Capital’s Chief Compliance Officer, Joshua Seward,
remains available to address any questions that a client or prospective client may have regarding the
allocation of account assets to an Independent Manager(s), including the specific additional fee to
be charged by such Independent Manager(s).
Cybersecurity Risk: The information technology systems and networks that Registrant and its third-
party service providers use to provide services to Registrant’s clients employ various controls, which
are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions
that could cause significant interruptions in Registrant’s operations and result in the unauthorized
acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant
are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to
incur losses, including for example: financial losses, cost and reputational damage to respond to
regulatory obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established its systems to reduce the risk of
cybersecurity incidents from coming to fruition, there is no guarantee that these efforts will always
be successful, especially considering that Registrant does not directly control the cybersecurity
measures and policies employed by third-party service providers. Clients could incur similar adverse
consequences resulting from cybersecurity incidents that more directly affect issuers of securities in
which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial institutions.
Account Aggregation Platforms: Quent Capital may provide its clients with access to one or more
online account aggregation platforms (the “Platforms”).The Platforms allow a client to view their
complete asset allocation, including those assets that Quent Capital does not manage (the “Excluded
Assets”). Quent Capital does not provide investment management, monitoring, or implementation
services for the Excluded Assets. Unless otherwise specifically agreed to, in writing, Quent Capital’s
service relative to the Excluded Assets is limited to reporting only. Therefore, Quent Capital shall not
be responsible for the investment performance of the Excluded Assets. Rather, the client and/or
their adviser(s) that maintain management authority for the Excluded Assets, and not Quent Capital,
shall be exclusively responsible for such investment performance. Without limiting the above, Quent
Capital shall not be responsible for any implementation error (timing, trading, etc.) relative to the
Excluded Assets. The client may choose to engage Quent Capital to manage some or all of the
Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement
between Quent Capital and the client. Certain of these Platforms also provide access to other types
of information and applications including financial planning concepts and functionality, which should
not, in any manner whatsoever, be construed as services, advice, or recommendations provided by
Quent Capital. Finally, Quent Capital shall not be held responsible for any adverse results a client
may experience if the client engages in financial planning or other functions available on the
Platforms without Quent Capital’s assistance or oversight.
Quent Capital may purchase structured notes for client accounts. A structured note is a financial
instrument that combines two elements, a debt security and exposure to an underlying asset or
assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the
note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or
commodities). It is this latter feature that makes structured products unique, as the payout can be
used to provide some degree of principal protection, leveraged returns (but usually with some cap
on the maximum return), and be tailored to a specific market or economic view. In addition,
investors may receive long-term capital gains tax treatment if certain underlying conditions are met
and the note is held for more than one year. Finally, structured notes may also have liquidity
constraints, such that the sale thereof before maturity may be limited. See additional disclosure at
Item 8 below. In the event that the client seeks to prohibit or limit the purchase of structured
notes for the client’s account, the client can do so, in writing, addressed to Quent Capital’s Chief
Compliance Officer.
Cash Positions. Quent Capital continues to treat cash as an asset class. As such, unless determined
to the contrary by Quent Capital, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of calculating Quent Capital’s advisory
fee. At any specific point in time, depending upon perceived or anticipated market conditions/events
(there being no guarantee that such anticipated market conditions/events will occur), Quent Capital
may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time,
Quent Capital’s advisory fee could exceed the interest paid by the client’s money market fund.
Investment Risk. Different types of investments involve varying degrees of risk, and it should not be
assumed that future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by Quent Capital) will be
profitable or equal any specific performance level(s).
Client Obligations. In performing its services, Quent Capital shall not be required to verify any
information received from the client or from the client’s other professionals and is expressly
authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Quent
Capital if there is ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/evaluating/revising our previous recommendations and/or services.
Disclosure Statement. A copy of Quent Capital’s written Brochure and Client Relationship Summary,
as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior
to the execution of any advisory agreement.
Quent Capital shall provide investment advisory services specific to the needs of each client. Prior to
providing investment advisory services, an investment adviser representative will ascertain each
client’s investment objective(s). Thereafter, Quent Capital shall allocate and/or recommend that the
client allocate investment assets consistent with the designated investment objective(s). The client
may, at any time, impose reasonable restrictions, in writing, on Quent Capital’s services.
Quent Capital does not participate in a wrap fee program.