Registration Status – Registered with the SEC on October 11, 2
0021
Principal Owners – Kent R. Seymour and Tracey S. Seymour
Assets Under Management – Discretionary Assets – $ 283,261,076
(As of December 2023) Non-discretionary Assets – 0
ADVISORY SERVICES
Menlo Advisors LLC (“Menlo”) is a California limited liability company that provides
investment management and limited financial planning services to its clients. Menlo’s
investment management services may include, among others, financial goal setting, risk
assessment, strategic asset allocation and the selection and management of securities and
investments. Securities transactions are supervised on a continuous basis and each client’s
portfolio holdings and asset allocations are monitored on a periodic basis.
The Firm is also the general partner and investment advisor to a pooled investment fund
named Skyline Partners, LP a Delaware limited partnership (“Skyline Partners” or the “Fund”).
Individually managed Client Accounts
The investment management services we provide are based on each individual client’s
financial circumstances and investment objectives. Our portfolio managers meet with each
client to discuss the client’s current financial condition and to review the client’s current
investment holdings. Based upon each client’s circumstances, we determine an
appropriate asset allocation for the client’s investment portfolio, in accordance with the
client’s specific financial objectives and risk tolerance and in consideration of other factors,
including the client’s time horizon (education funding, home purchase, retirement, legacy
planning), liquidity needs, and other available resources (including external retirement
plans, projected social security, outside investments, real estate, and insurance). Clients
may identify any investment restrictions to be placed on their account. Each client’s
financial objectives, risk tolerance, and liquidity needs, along with a recommended asset
allocation, are incorporated into an investment portfolio that is customized for the client.
A client may make additions to and withdrawals from the client’s portfolio account at any
time, subject to the Firm’s right to terminate an account if the amount of assets drops below
our account size minimum. Clients may withdraw account assets with notice to the Firm,
subject to the usual and customary securities settlement procedures. However, we design
client portfolios as long-term investments and caution our clients that asset withdrawals may
impair the achievement of the client’s investment objectives.
Additions to an account may be in cash or securities provided that we may decline to
accept particular securities into a client’s account or may recommend that the security be
liquidated if it is inconsistent with the Firm’s investment strategy or the client’s investment
objectives. Clients are advised that when transferred securities are liquidated, they may be-
subject to transaction fees, fees assessed at the mutual fund level (i.e. sales charge) and/or
tax ramifications.
1 “Registration” means only that the Firm meets the minimum requirements for registration as an
investment advisor and does not imply that the SEC guarantees the quality of our services or
recommends them.
Menlo may refer our clients to other professionals such as attorneys or accountants for estate
planning, real estate consultations, corporate counsel, tax or other matters. Menlo does not
accept fees for such referrals. Neither the Firm nor its principal/employees are affiliated with
any law or accountancy firm and we do not supervise or otherwise warrant such third-party
services.
FINANCIAL PLANNING AND FINANCIAL CONSULTATION SERVICES
Menlo includes limited financial consultations with its investment management services.
Such services may include a financial review
and analysis of some or all of the following
areas:
− Determining Financial Goals And Objectives
− Asset Allocation Review
− Retirement Plan Analysis
− Employee Stock Option Analysis
− Current Portfolio Review
− Education Funding Analysis
− Cost Audit of Current Investments
− Cash Flow Management Review
− Review of Insurance Needs
− Mortgage and Refinance Evaluation
− Estate Plan Review or Development
− Charitable (or social capital) Planning
− Opinion on Current Investment Strategy/Advisors
− Other financial or investment analysis
Financial consultation services not included with investment management services may be
provided pursuant to a separate agreement.
GENERAL NOTICE
In performing its services, Menlo relies upon the information received from its client or from
their other professional legal and accounting advisors and is not required to independently
verify such information. Clients must promptly notify us of any change in their financial
situation or investment objectives that would necessitate a review or revision by our advisors
of the client’s portfolio and/or financial plan.
FIDUCIARY STATUS
When Menlo Advisors provides investment advice to you regarding your investment
accounts, including your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of certain state and federal laws such as the Employee
Retirement Income Security Act and/or the Internal Revenue Code and the regulations of
the U.S. Securities and Exchange Commission, as applicable. These regulations require us to
act in your best interest and not put our interests ahead of yours.
SERVICES TO SKYLINE PARTNERS, LP
Menlo Advisors is also the general partner and investment manager to Skyline Partners, LP
which was established to provide a “fund of funds” investment vehicle for those clients of
Menlo Advisors that qualify as investors for other private investment companies and for
which such investments are deemed suitable. As the general partner of the Fund, Menlo
Advisors has a proprietary interest in the Fund and is entitled to certain fees and the
reimbursement of expenses, if any are assessed, in accordance with the terms of the Skyline
Partners private placement memorandum and investor subscription agreements entered
into with its investors. The Fund operates as a pooled investment vehicle intended to provide
diversification, management expertise and other advantages to qualifying clients. In order
to invest in the Fund, an investor must meet certain requirements, including qualifying as a
“qualified client” (as defined in SEC Rule 205-3(d)(1) under the Investment Advisors Act of
1940) and an “accredited investor” (as defined in Rule 501(a) of Regulation D under the
Securities Act of 1933).
PURCHASER REPRESENTATIVE SERVICES
Menlo occasionally acts as purchaser representative for unaccredited investors that want
to invest in private placements or limited offerings. A purchaser representative is typically
retained as a part of a merger or acquisition transaction wherein private stock in the merged
entity or the acquiring entity is offered to prospective shareholders that do not meet the
income or net worth requirements of an “accredited investor” under the regulations for
private placements or limited offerings. In such cases, Menlo is retained by the issuer of the
stock to advise such unaccredited potential investors on the merits and risks of the
prospective investment.
TERMINATION OF AGREEMENT
Clients may terminate their investment management agreement at any time upon written
notice to the Firm. Any prepaid fees owed to the client will be refunded on a pro rata basis
determined on the amount of time expired in the calendar quarter.
Menlo Advisors may only be terminated as the investment manager of Skyline Partners as
provided in the Fund’s limited partnership agreement, a copy of which is provided to each
prospective investor in the Fund.