LCRWM provides investment advisory and supervisory services on a discretionary basis for a broad
base of clients, including individuals, families, trusts, institutions, and retirement plans. Services may
include defining investment objectives, asset allocation among types of securities, and portfolio
management of equity and income-oriented accounts.
In providing its services, the sole standard of care imposed upon LCRWM shall be to act with the care,
skill, prudence, and diligence under the circumstances then prevailing that a prudent investment advisor
acting in a like capacity and familiar with such matters would use in the conduct of a like character with
like aims. In addition, LCRWM assumes no responsibility for the accuracy of information furnished to
LCRWM by a client or a client’s agent. With respect to investing in certain investment products, such
as mutual funds, ETFs, closed-end funds, and private funds, the client in effect will be paying two
management fees, one to LCRWM and one to the mutual fund advisor.
LCRWM was granted registration on March 12, 2021 as an investment advisor pursuant to Section 36b-
6 of the Connecticut General Statutes and transitioned its registration to the SEC on June 30, 2021. LCR
Capital Partners LLC (“LCRCP”) is the majority owner of LCRWM. Thomas Garvey is the principal
member and the president of LCRWM and has been engaged in the business of providing investment
services to investment clientele since 2003.
A client’s account is handled by Mr. Garvey. To provide its hallmark of high quality and hands-on
service to its clients, LCRWM restricts portfolio management to a limited number of sizable accounts.
LCRWM may direct clients to third-party investment advisers. Before selecting other advisers for
clients, LCRWM will verify that all recommended advisers are properly licensed, notice filed, or exempt
in the states where LCRWM is recommending the adviser to clients.
As of October 16, 2023, LCRWM has $114,315,556 in discretionary assets under management.
Iron Pillar Fund II US Access, LP
LCRWM acts as the investment manager of a venture capital fund, Iron Pillar Fund II US Access, LP
(the “Fund”). LCRWM engages in a broad spectrum of activities including financial advisory services,
investment management activities, sponsoring and managing the Fund, among other activities. In the
ordinary course of its business, LCRWM therefore engages in activities where LCRWM’s interests may
conflict with the interests of its clients, including the Fund. Please refer to the Fund’s operating
documents and to Item 10 of this Brochure for a more complete discussion of the Fund, its conditions,
risks, and related factors prior to investing in the Fund. LCRWM can give no assurance that conflicts of
interest will be resolved in favor of its clients or the Fund, however, LCRWM strives to ensure that
investments are made solely in the clients’ best interests and that all clients are treated fairly and
equitably.
Model Portfolios
LCRWM operates a model portfolio program currently consisting of 100% equity model portfolios (the
“Model Portfolios”) for a range of investment objectives, risk tolerances, and investment themes that
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can be accessed through the normal advisory practice and procedures. LCRWM’s model portfolios are
not tailored to the individual needs of clients. Suitability for the model portfolio program is determined
by one of LCRWM’s investment advisor representatives (“Advisor Representatives”). LCRWM Advisor
Representatives obtain the necessary financial data from the
client, assists the client in determining the
suitability of the program and assists the client in setting an appropriate investment objective. The
Advisor Representative provides ongoing advice on the selection or replacement of a Model Portfolio
based on the client’s individual needs. The Advisor Representatives obtain this information by having
the client complete a questionnaire (a “Client Questionnaire”) which is a part of the client’s investment
management agreement. LCRWM asks clients to communicate if there have been any changes in the
client’s financial situation or investment objective or if they wish to impose any reasonable restrictions
on the management of the account or reasonably modify existing restrictions.
LCRWM may apply discretion to deviate from the Model Portfolios in smaller accounts, in which it is
not possible or impractical to be invested in all of a Model Portfolio’s holdings. LCRWM is responsible
for rebalancing accounts in accordance with the allocations in the Model Portfolio(s). LCRWM will
review an account to determine if rebalancing is appropriate based on the frequency selected by the client
at account opening or as altered by the client or the Advisor Representative from time to time. The
choices for frequency of rebalancing review are semiannually (two times per year) or annually (once per
year). At each rebalancing review date, LCRWM will rebalance the account only if at least one security
position is outside a predetermined range, subject to a minimum transaction amount established by
LCRWM in its discretion. In addition, LCRWM will review an account for rebalancing in the event that
the investment professional changes the allocation targets.
LCRWM requires a minimum asset value for a program account to be managed. The minimums vary
depending on the Model Portfolio(s) selected and the account’s allocation amongst Model Portfolios.
The lowest minimum for a Model Portfolio is $100,000. In certain instances, LCRWM will permit a
lower minimum for a Model Portfolio. Note that an account will not be invested according to a Model
Portfolio or Portfolios until the applicable minimum for the Portfolio(s) and allocation has been reached.
Clients should understand that the investment objective selected for the program in the Client
Questionnaire is an overall objective for the entire account and may be inconsistent with a Model
Portfolio in the account, a particular holding and the account’s performance at any time. Clients also
should be aware that achievement of the stated investment objective is a long-term goal for the account.
LCR Capital Partners LLC
LCRCP is the majority owner of LCRWM. LCRCP is an investment firm whose primary focus is
connecting global investors with EB-5 Visa eligible investments. LCRCP has in the past and may in the
future refer investors seeking advisory management services to LCRWM. LCRCP is not compensated
for its introduction of investors to LCRWM. However, LCRCP has an incentive to recommend
LCRWM’s advisory services to investors due to the financial and other benefits it may receive as
LCRWM’s majority owner, even if another person or firm is more qualified to provide advisory service
and/or can provide them at a lesser cost. Unlike LCRWM, LCRCP is not an investment adviser and does
not have a fiduciary relationship with the EB-5 investors. LCRWM does not refer clients to LCRCP nor
does it recommend LCRCP investments to its clients. LCRWM always acts in the best interests of its
clients consistent with its fiduciary duties.
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