Separate Account I nvestment Management Services
Ardent Capital Management, Inc. was first established in 1993 as Chartwell Advisors. Chartwell
Advisors transitioned to Winston Advisors, Inc., then Winston Investment Management, Inc., and later
becoming Ardent Capital Management, Inc. Ardent provides discretionary investment management
services to clients. The firm was founded by Charles A. and Christopher J. Donabedian. After
developing a client's personal investment objectives through discussions about goals and objectives,
risk tolerance, income needs, liquidity needs and tax considerations, a written investment advisory
agreement is executed between the client and Ardent. All client accounts will be managed in
accordance with their respective investment objectives.
Portfolios may consist of one or more of the following securities:
•equities, both common and preferred
•U.S. government securities, municipal and corporate debt
•options and warrants
•certificates of deposit,
•mutual funds.
•Any other securities appropriate and consistent with the client goals, risk tolerance and
objectives.
Ardent Capital Management, Inc. manages two accounts on a non-discretionary basis. One of those
accounts holds a concentration of one or more securities in which Ardent Capital Management, Inc.
employs a derivative overlay strategy to optimize income and returns. The fees for these non-
discretionary services are negotiable.
We offer advice on equity securities, warrants, corporate debt securities (other than commercial
paper), commercial paper, certificates of deposit, municipal securities, variable life insurance, variable
annuities, and United States government securities. We may invest in mutual funds that use alternative
strategies that utilize futures or options on futures.
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.
Private Fund
We serve as Investment Manager to the ACM Opportunity Fund LLC (the "Fund"), which seeks long-
term growth of capital via both income and capital gains. By
the nature of the assets in which it invests,
the Fund is aggressive in its orientation and will experience volatility in the price of underlying
securities. Investment in the Fund is only offered to a limited number of accredited investors via a
Private Offering Memorandum.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), 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.
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When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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 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 financial interests ahead of yours when making recommendations (give loyal
advice);
•Avoid misleading statements about conflicts 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 conflicts of interest.
We benefit financially 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 fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $247,089,746 in client
assets on a discretionary basis, and $46,959,725 in client assets on a non-discretionary basis.