Description of Services and Fees Conrad Capital Management, Inc. is a registered investment adviser based in Hauppauge, New York. We are organized as a corporation under the laws of the State of New York. We have been providing investment advisory services since 1997. Donald E. Conrad is our principal owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Money Management Services
•Concierge Services
•Financial Planning Services
•Selection of Third Party Managers
•Pension Consulting Services
•Seminars The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to Conrad Capital Management, Inc. and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Money Management Services We offer discretionary and non-discretionary money management services billed quarterly. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for money management services, we will require that you complete an Investor Profile, Risk Tolerance, and Suitability questionnaire (collectively, "Client Questionnaires"), which is intended to measure your investment objectives, time horizons, and risk parameters. In establishing a portfolio for you, we consider the information contained in the Client Questionnaires, including your stated investment objectives, risk tolerance, and other pertinent investment considerations. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
You are responsible for promptly bringing any change in your investment objectives or financial condition to our attention. Although we will remind you to confirm your investment goals at least annually to aid in the communication of material changes, it is your responsibility to make us aware of any changes.
If you participate in our discretionary money management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Under certain circumstances, you may provide us with written instructions to manage your account on a discretionary basis based on certain specific guidelines and time frames that you establish.
4 ©2017 National Compliance Services 800-800-3204 In general, we offer advice on mutual funds, exchange traded funds, equity securities, warrants, corporate debt securities, commercial paper, certificates of deposits, municipal securities, US Government securities and initial public offerings ("IPO"s). Individual securities comprise a portion of the equity exposure, depending on the client's investment profile. We utilize a top-down approach to the investment process, demographically driven and filtering down to specific companies. It is in accordance with our philosophy to invest for the long term. We seek to acquire companies that will be held for at least a year in order to capitalize on the more favorable long-term capital gains tax treatment. We have proprietary investment strategies. Occasionally, we may participate in the IPO market.The securities involved in IPOs are often subject to greater and more unpredictable price changes than more established stocks. For this reason before being added to our IPO list, all clients are called individually and explained in detail the risks associated and minimum holding time required (a month and a day) to make absolutely sure they understand the process. In a few cases clients have asked to be contacted first and this has been noted on their account and our IPO list.
Equity Approach: Allocation is achieved by investing primarily in Mutual Funds, Exchange Traded Funds and Index Funds. We accommodate individual securities, they comprise a portion of the equity exposure, depending on the client's investment profile. We utilize a top-down approach to the investment process, demographically driven and filtering down to specific companies. It is in accordance with our philosophy to invest for the long-term. We seek to acquire companies that will be held for at least a year in order to capitalize on the more favorable long-term capital gains tax treatment. We have proprietary investment strategies. Occasionally, we may participate in the IPO market. The securities involved in IPOs are often subject to greater and more unpredictable price changes than more established stocks. For this reason before being added to our IPO list, all clients are called individually and explained in detail the risks associated and the minimum holding time required (a month and a day) to make absolutely sure they understand the process. In a few cases clients have asked to be contact first and this has been noted on their account and our IPO list. Fixed-Income Approach: Allocation is achieved by investing primarily in Mutual Funds, Exchange Traded Funds and Index Funds. CCM generally recommends municipal bonds in taxable accounts and investment grade quality corporate bonds and/or treasuries in tax-deferred accounts to maximize after- tax returns. Occasionally, preferred stocks are selected as a surrogate to a fixed income portfolio. CCM seeks to reduce volatility by acquiring fixed income products that have staggered or laddered maturities. Specific fixed income sectors are emphasized based on relative attractiveness. The portfolio mix of corporate, government, foreign sovereign, high yield, TIPs, CDO, mortgage and asset- backed securities will be adjusted to reflect changing spread, inflation expectations, momentary policies and economic activities. Typically, a significant position of assets is not held as cash unless there is a need for liquidity, such as a withdrawal.
Mutual Fund and Exchange Traded Fund Approach: Both open and closed end Mutual Funds, ETFs and Index Funds comprise the largest portion of investment portfolios at CCM the majority being no-load or load-waived. To ensure adequate diversification, 10-30% exposure in the international and small cap areas will be maintained. In addition, exposure to other sectors is achieved through fund investments as well. When appropriate, CCM will use internally leveraged mutual funds.
Alternative Investment Approach: Alternatives are an important portion of client portfolios at our firm. Alternatives include, but are not limited to precious metals, energy, commodities, currencies, traded REITs, options. These areas of investment are usually accessed through no-load mutual funds and exchange traded funds. For accredited investors, private investments are also considered. These include limited partnerships, non-traded REITs, BDCs, closed-end funds, venture capital, private equity, private investments, hedge funds, and hedge fund of funds investments as well. 5 ©2017 National Compliance Services 800-800-3204 Concierge Services We may offer non-investment advisory consulting services ("Concierge Services") to our advisory clients. Concierge Services may include, but is not limited to, one or more of the following services: Estate Planning: Introduction to attorneys First time consultation set up for free (up to a $500 value) Liaison with attorneys to handle legal issues (setting up of will, health care proxy, etc.) Accounting Services: Introduction to accountants Working with current/new accountants and/or tax preparers on taxes, preparing reports, etc.
Helping with tax planning issues Business Services: Assistance in the sale and/or purchase of a business Strategy & financial consulting Financial Services: Comprehensive service around any financial related situations (i.e. car purchase v. lease, new home purchase, real estate sale, assistance with negotiation in certain vendor situations, insurance services, etc.) Financial Planning Services We offer

modular and consultative financial planning services to clients who require advice on specific aspects of their finances. Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Selection of Third Party Managers We may recommend that you utilize outside professional money managers to gain adequate diversification and asset allocation for larger plans i.e., retirement, endowment, foundations and similar organizations. All money managers that we recommend to our clients must be registered as investment advisers with either the Securities and Exchange Commission or with the appropriate state authority(ies) unless otherwise exempt from registration.
After gathering information about your financial situation and objectives, we may make recommendations regarding the suitability of a money manager or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the money manager's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the money manager(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
6 ©2017 National Compliance Services 800-800-3204 Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, money management services, investment performance monitoring, ongoing consulting, and/or communication and education services where our firm will assist the plan sponsor in providing meaningful information regarding the retirement plan to its participants.
We may have agreements with third party administrators ("TPA") to provide these services as part of the TPA's agreement with the plan. In these instances, the TPA may pay to our firm a portion of it charges to the plan. In other instances, we may be introduced to a plan through a TPA and will provide service directly to the plan.
We may hold educational seminars for the plan employees and provide information on the plan specifics and allocation choices. We may also meet with individual plan participants and offer personalized information based on their individual objectives. General - Advisory Services to Retirement Plans and Plan Participants As disclosed above, we offer various levels of advisory and consulting services to employee benefit plans ("Plan") and to the participants of such plans ("Participants"). The services are designed to assist plan sponsors in meeting their management and fiduciary obligations to Participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status (which is described below). The services we provide to your Plan are described above, and in the service agreement that you have previously signed. Our compensation for these services is described below, at Item 5, and also in the service agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such compensation and the payer of such compensation to you. Status In providing services to the Plan and Participants, our status is that of an investment adviser registered under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under Section 411 of ERISA. In performing fiduciary services, we are acting either as a non-discretionary fiduciary of the Plan as defined in Section 3(21) under ERISA, or as a discretionary fiduciary of the plan as defined in Section 3(38) under ERISA. Seminars We provide free seminars to the public on general and educational financial and investment matters. Presentations may focus on issues relating to asset management, qualified plans, and/or financial planning, and are impersonal in nature. We will not provide individualized advice to participants unless the participant engages our firm separately as an advisory client.
7 ©2017 National Compliance Services 800-800-3204 Types of Investments We generally offer advice on mutual funds, exchange traded funds, equity securities, warrants, corporate debt securities, commercial paper, certificates of deposit, municipal securities, variable life insurance, variable annuities, U.S. Government securities, options contracts on securities, initial public offerings ("IPO"s), and interests in pooled investment vehicles. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
Assets Under Management As of January 31, 2023, we provide continuous management services for $60,752,702 in client assets on a discretionary basis, and $16,510,626 in client assets on a non-discretionary basis. 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. 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.
Please Note : 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 the Registrant recommends that a client roll over their retirement plan assets into an account to be managed by the Registrant, such a recommendation creates a conflict of interest if the Registrant will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by Registrant. Registrant's Chief Compliance Officer, Donald Conrad, 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. 8 ©2017 National Compliance Services 800-800-3204