Intrepid Capital Management, Inc. ("Intrepid Capital," the "Adviser," "we," "us" or "our") incorporated in
Florida in 1994 and is a wholly owned subsidiary of Intrepid Capital Corporation, incorporated in Delaware
in 1998. Intrepid Capital is an investment management firm focused on finding value in equity and
fixed income markets for institutional, corporate, and high net worth investors. With over 25 years of
investment experience, the Adviser has a strong focus on partnering with clients to ensure their
investment goals are realized. We differentiate ourselves by managing concentrated portfolios with low
turnover, seeking absolute returns, and co-investing with our clients.
We believe that our investment style allows us to pursue the best value we can find in the markets with
the goal of achieving superior risk-adjusted returns. We also believe that sound strategies, executed
consistently, are the keys to long-term success.
WRITTEN ACKNOWLEDGEMENT OF FIDUCIARY STATUS
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title 1 of the Employee Retirement Income
Act (ERISA) and 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 out 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 a level fee that is reasonable for our services; and
- Give you basic information about conflicts of interest.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, we were actively managing $747,134,470 on a discretionary basis and
$15,382,607 on a non-discretionary basis.
INVESTMENT MANAGEMENT SERVICES
We offer the following investment advisory and related services to our clients:
We offer a separately managed account (a "SMA") investment option, which is administered through the
client's custodian. The program includes the following:
a. Investor Profile: We consult with the client to obtain detailed financial information and other
pertinent data on an Investor Profile Questionnaire to enable the client to determine the
appropriate investment guidelines, risk tolerance, net worth, net income and other factors that
will assist in ascertaining the suitability of a SMA.
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b. Investment Policy Statement: We prepare an investment policy statement ("IPS") for the
client and, subject to the client's approval, including investment objectives, policies, and
constraints consistent with the client's requirements and requirements under applicable law,
and provide a periodic review of the IPS.
c. Investment Recommendations: We recommend, for consideration and approval by the client,
(i) asset allocation target-date or risk-based model portfolios for the client, and (ii) funds from
the line-up of investment options chosen by the client to include in such model portfolios. We
manage the implementation of the model portfolios for the client's account, with full discretion
to make purchase and sale decisions for the account. We review the client's investments and
recommend investments in pooled investment vehicles that are not registered under the
Investment Company Act of 1940 (a "Private Fund" and, collectively, "Private Funds"),
consistent with the requirements of the client's IPS as adopted by the client.
d. Portfolio Management: We manage the client's portfolio using, but not limited to stocks,
bonds, mutual funds, exchange traded funds, US Treasury bonds and money market
instruments. We manage the client's account on an individual basis. Further restrictions and
guidelines imposed by clients affect the composition and performance of portfolios. For these
reasons, performance of portfolios within the same investment objective may differ. Therefore,
clients should not expect that the performance of their portfolios will be identical with our
average client. We also offer different investment strategies for our clients, and, in
implementing these strategies, we employ model portfolios.
e. Performance Evaluation and Monitoring Services: We perform ongoing monitoring of
investment options in relation to the criteria provided by the client and make recommendations
accordingly. We furnish performance measurement services to our clients, provide d by the
custodian and through internally generated reports, in the form of quarterly performance
evaluation reports. The internal reports are intended to inform clients as to how their
investments have performed for the selected period of time. We schedule regularly recurring
review meetings, with the number of meetings varying based on the account size.
f. Discretionary Authority: We generally have discretionary authority to buy and sell
securities. The client may also elect to have their accounts managed on a non-
discretionary basis. The client's custodian may charge a transaction fee or commission on
any transaction. We review the client's investments and recommend investment
manager(s) and investment(s) consistent with the requirements of the client's IPS as
adopted by the client. We have full discretion of the selection of investment managers and
investment replacements if an existing manager or investment is no longer suitable. We are
authorized to direct any firm designated in writing by the client to reallocate assets among
different investment strategies offered by the designated firm. We are authorized to direct any
designated firm to sell or purchase any particular security that is a permissible investment
for any investment strategy in which the client is invested.
g. Custodian Commissions: The custodian has the responsibility to disclose its commission
charges to the client. For accounts managed on a discretionary basis, the client grants us sole
discretion to purchase, sell, exchange, convert and otherwise trade securities and other
investments
in the client's account. This trading authorization is continuing in nature and
remains in effect until terminated by the client or us.
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MUTUAL FUNDS
a. We serve as the investment adviser to the Intrepid Capital Management Funds Trust ("ICFT"),
a series of open-end mutual funds. The ICFT currently consists of four no-load funds: (1) the
Intrepid Capital Fund - currently offering both Investor Class and Institutional Class shares;
(2) the Intrepid Small Cap Fund - currently offering both Investor Class and Institutional Class
shares; and (3) the Intrepid Income Fund - currently offering only Institutional Class shares
(collectively, the "Funds"). As such, we furnish continuous investment advisory services to
the Funds and are primarily responsible for the day-to-day management of the investment
portfolio of the Funds.
b. Please review the Funds' Prospectus and Statement of Additional Information for further
information regarding the investment strategies, restrictions and risks related to the Funds.
WEALTH MANAGEMENT SERVICES
We offer the following wealth management services, each as agreed to with the specific client (so,
wealth management clients receive all services listed under Investment Management Services and only
those services identified below that are contractually agreed to by them):
a. We perform ongoing monitoring of investment options in the client's 401(k) in relation to the
criteria provided by the client and make recommendations accordingly. We review the client's
investments and recommend investments in pooled investment vehicles that are not registered
under the Investment Company Act of 1940 (a "Private Fund" and, collectively, "Private
Funds"), consistent with the requirements of the client's IPS as adopted by the client. We
perform due diligence regarding Private Funds and monitor the performance of Private Funds.
b. We provide financial planning services, which are defined as a comprehensive evaluation of the
client's current and future financial state. We make this evaluation after gathering all known
facts through personal interviews, analysis of financial statements and written investor profile.
See the discussion on "Financial Planning Services" below.
c. The client should refer to its wealth management agreement for a full understanding of our
wealth management services and obligations.
FINANCIAL PLANNING SERVICES
a. For clients who do not receive full wealth management services, we provide financial planning
on an "as needed" basis. We generally intend to provide these services to persons with an
investable net worth of $1,000,000 or more. However, we may, in our discretion, prepare a
financial plan for a client with a net worth less than $1,000,000. The nature of the services to
these clients is based on information provided by the client and documented in the client's
Financial Planning Agreement. The Financial Planning Agreement will terminate upon delivery
of the financial plan, except for the client's obligation to pay the agreed-upon fee per the
agreement, the limitation on liability and the arbitration provision described in the agreement.
However, some clients may contact us for a plan update, and such an update will be a new
engagement with a separate fee.
b. The written financial plan is based on documentation provided by the client as set forth in the
Financial Planning Agreement, including a Planning Questionnaire, and the client is made
aware that a failure to provide accurate and current information may adversely affect the quality
of the financial plan.
c. The client should refer to the Financial Planning Agreement for a full understanding of our
financial planning services and obligations.
PRIVATE FUND
The Intrepid Capital L.P. (the "Partnership") is an investment partnership designed to allow qualified
investors to participate in a professionally managed, diversified investment program, which primarily
invests in publicly traded equity securities by holding both long and short positions, and corporate debt.
The Partnership does not hold any securities short that are being held long in other strategies or client
accounts.
a. We act as the General Partner of the Partnership and have sole responsibility for the
management of the Partnership's business and investments. We also have discretionary
authority to select investments in trading activities on behalf of the partnership.
b. The minimum investment in the Partnership is $500,000 unless we allow a smaller investment;
provided, however, that each investor has a minimum $1,000,000 under management with us
or more than $2,100,000 net worth exclusive of the value of the investor's principal residence.
Please refer to the Private Offering Memorandum and Subscription Agreement for additional
details and instructions. Clients who invest in the Partnership should also refer to the Private
Offering Memorandum for, among other things, additional disclosure about the risks in
investing in the Partnership and our relations hip with the Partnership.
GENERAL CONSIDERATIONS
a. We may from time to time determine that an investment in a product or service offered by us
or by a company affiliated with us is consistent with a client's financial situation or the
recommendations contained in the client financial plan. In addition, a client may decide, at the
client's own independent discretion, to purchase financial products offered by or through us or
an affiliated company. In such circumstances, we receive investment advisory fees as the
adviser to such products, like the ICFT.
b. We may recommend or take action in the performance of our duties for one client that differ
from the recommendations or advice given to another client. Differences include, but are not
limited to, the timing and nature of the recommendation or action taken. We are not required
to recommend for purchase or sale any securities or other investments to a client, even though
we may purchase or sell or recommend for purchase or sale such securities for our accounts
or for the account of any of other clients.
c. We and our employees may make personal investments in securities and other financial
products that we also recommend to our clients.
1400 Marsh Landing Parkway, Suite106 I Jacksonville, Florida 32250 I 904.246.3433 I www.intrepidcapital.net
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