FAMR is a SEC-registered investment adviser with its
principal place of business located in Nebraska.
FAMR began conducting business in June 2003.
Listed below are the firm's principal shareholders
(i.e., those individuals and/or entities controlling
25% or more of this company).
• Stephen J Lococo, President
FAMR offers the following advisory services to our
clients:
INVESTMENT SUPERVISORY SERVICES ("ISS")
INDIVIDUAL PORTFOLIO MANAGEMENT
Our firm provides continuous advice to a client
regarding the investment of client funds based on
our Risk Managed Model Portfolios and Absolute
Value. We thoroughly discuss our philosophies with
prospects to ensure that their selection of portfolio
management style of investing is in alignment with
their investment objectives and risk tolerance for
the assets to be invested. Regardless of philosophy
selected, risk and volatility are inherent in investing,
and loss of capital may result. We manage advisory
accounts on a discretionary basis. Account
supervision is guided by each client’s selection of
investment philosophy. Tax considerations are
taken on an individual basis. It is our belief that if a
client's portfolio is generating capital gains, the
client should use those gains to pay for the tax
liability they created. Realizing a capital loss from a
current position may destroy more value than
paying taxes on realized gains.
Our styles of investing are focused on long term (3 -
5 years minimum) wealth creation and accounts
with FAMR should be treated as investment
accounts. Clients are encouraged to utilize funds
outside of their FAMR account(s) for on-going cash
requirements.
Our investment recommendations are not limited to
any specific product or service offered by a broker-
dealer or insurance company and will generally
include advice regarding the following securities:
• Exchange-listed securities (stocks and ETFs)
• Securities traded over the counter
• Foreign issuers
• Corporate debt securities (other than commercial
paper)
• Covered call option contracts on securities
• Mutual Funds
Because some types of investments involve certain
additional degrees of risk, prospects should
thoroughly understand our investment philosophy
prior to investing with FAMR. Clients not investing
for the long term should not invest their assets with
FAMR. Individual portfolio tailoring is done by
exception on a client-by-client basis and is restricted
to our Separately Managed Account (SMA) offering.
As of December 31, 2022, FAMR managed
$31,980,228 in assets.
5 | P a g e
IRA Rollover Recommendation Disclosure
A plan participant leaving an employer sponsored
savings plan such as a 401(k) typically has four
options (and may engage in a combination of these
options):
• leave the money in his former
employer’s plan, if permitted.
• roll over the assets to his new
employer’s plan if one is available and
rollovers are permitted.
• roll over to an IRA; or
• cash out the account value.
Each choice offers advantages and disadvantages,
depending on desired investment options and
services, fees and expenses, withdrawal options,
required minimum distributions, tax treatment, and
the investor’s unique financial needs and retirement
plans. As a fiduciary we have an obligation to
evaluate these advantages and disadvantages,
disclose any conflicts of interest, and together with
you, the client, develop a strategy that is in your
best interest.
Considerations
We as your advisor have fiduciary responsibilities
when recommending a rollover or transfer of assets
in an employer-sponsored retirement plan to an
Individual Retirement Account (IRA) to be managed
by us.
Accordingly, a recommendation to roll over plan
assets to an IRA rather than keeping assets in a
previous employer’s plan or rolling over to a new
employer’s plan, should reflect consideration of
various factors, the importance of which will depend
on the client’s individual needs and
circumstances. Some of the factors include:
Investment Options:
An IRA is an alternative to leaving your retirement
funds in your employer’s plan. An IRA often enables
you to select from a broader range of investment
options than a plan. The importance of this factor
will depend in part on how satisfied you are with the
options available under the plan under
consideration.
Services:
You may wish to consider the different levels of
service available under each option, including the
availability of investment advice, financial planning,
and related services.
Fees and Expenses:
Both plans and IRAs typically involve (i) investment-
related expenses and (ii) plan or account fees.
Certain employers may pay for some of all of the
plan’s administrative expenses, whereas IRA
custodians may not charge, or may waive,
administrative expenses. Investment-related
6 | P a g e
expenses may include sales loads, commissions, the
expenses of any mutual funds in which assets are
invested and investment advisory fees.
Penalty-Free Withdrawals:
If you leave your job between age 55 and 59½, you
may be able to take penalty-free withdrawals from a
plan. In contrast, penalty free withdrawals generally
may not be made from an IRA until age 59½, with a
few exceptions. You may also be able to borrow
from a plan.
Protection from Creditors and Legal
Judgments:
Generally speaking, plan assets have unlimited
protection from creditors under federal law, while
IRA assets are protected in bankruptcy proceedings
only. State laws vary in the protection of IRA assets
in lawsuits.
Required Minimum Distributions:
Once you reach age 72, the rules for both plans and
IRAs require the periodic withdrawal of certain
minimum amounts, known as the required minimum
distribution. If you are still working at age 72,
however, you generally are not required to make
required minimum distributions from your current
employer’s plan. This may be advantageous if you
plan to work into your 70s.
Employer Stock:
If you hold significantly appreciated employer stock
in a plan you should consider the negative tax
consequences of rolling the stock to an IRA. If
employer stock is transferred in-kind to an IRA,
stock appreciation may be taxed as ordinary income
upon distribution. The tax advantages of retaining
employer stock in a non-qualified account should be
balanced with the possibility that you may be
excessively concentrated in employer stock. It can
be risky to have too much employer stock in one’s
retirement account; for some investors, it may be
advisable to liquidate the holdings and roll over the
value to an IRA, even if it means losing long-term
capital gains treatment on the stock’s appreciation.
Conflicts of Interest:
A recommendation that you roll over plan assets to
an IRA into a managed account includes an implicit
conflict of interest as we will earn a management fee
for managing the assets. In contrast, a
recommendation that you leave your plan assets
with your old employer or roll the assets to a plan
sponsored by a new employer likely results in little
or no compensation for us. This conflict must be
disclosed to you and your evaluation of the conflict
is one of the factors that must be evaluated in
making the recommendation.
7 | P a g e
Pricing of Securities
FAMR has adopted the provisions of SFAS No. 157,
“Fair Value Measurements” (SFAS No. 157), that
became effective January 1, 2008. Under SFAS No.
157, fair value is defined as the price that would be
received to sell an asset or paid to transfer a liability
(i.e., the “exit price”) in an orderly transaction
between market participants at the measurement
date. Although FAS 157 specifies a measurement or
valuation date, it does presume the asset/liability’s
exposure to the market for a certain period to allow
for usual and customary market activities.
In determining fair value, FAMR uses various
valuation approaches. SFAS No. 157 establishes a
fair value hierarchy for inputs used in measuring fair
value that maximizes the use of observable inputs
and minimizes the use of unobservable inputs by
requiring that the most observable inputs be used
when available. Observable inputs are those that
market participants would use in pricing the asset or
liability based on market data obtained from sources
independent of FAMR. Market participants are
buyers and sellers who are independent,
knowledgeable, willing, and able to transact for the
subject asset or liability in its principal or most
advantageous market. Unobservable inputs reflect
FAMR’s assumption about the inputs market
participants would use in pricing the asset or liability
developed based on the best information available in
the circumstances.
The fair value hierarchy is categorized into three
levels based on the inputs as follows:
Level 1 - Valuations based on unadjusted quoted
prices in active markets for identical assets or
liabilities that FAMR has the ability to access.
Valuation adjustments and block discounts are not
applied to Level 1 securities. Since valuations are
based on quoted prices that are readily and
regularly available in an active market, valuation of
these securities does not entail a significant degree
of judgment.
Level 2 - Valuations based on quoted prices in
markets that are not active or for which all
significant inputs are observable, either directly or
indirectly. Level 2 inputs include:
A. Quoted prices for similar assets or liabilities in
active markets
B. Quoted prices for identical/similar securities in
markets that are not active, i.e., in which there
are few transactions for the security, the prices
are not current, or price quotations vary over
time or among market makers (some brokered
markets), or in which little information is released
publicly (a principal-to-principal market).
C. Observable inputs other than quoted prices for
the security (e.g., interest rates and yield curves
observable at commonly quoted intervals,
volatilities, prepayment speeds, loss severities,
credit risks, and default rates).
8 | P a g e
D. Inputs that are derived principally from or
corroborated by observable market data by
correlation or other means (market-corroborated
inputs).
Level 3 - Valuations based on inputs that are
unobservable and significant to the overall fair value
measurement.
The availability of valuation techniques and
observable inputs can vary from security to security
and is affected by a wide variety of factors, including
the type of security, whether the security is new and
not yet established in the marketplace, and other
characteristics particular to the transaction. To the
extent that valuation is based on models or inputs
that are less observable or unobservable in the
market, the determination of fair value requires
more judgment. Those estimated values do not
necessarily represent the amounts that may be
ultimately realized due to the occurrence of future
circumstances that cannot be reasonably
determined. Because of the inherent uncertainty of
valuation, those estimated values may be materially
higher or lower than the values that would have
been used had a ready market for the securities
existed. Accordingly, the degree of judgment
exercised by FAMR in determining fair value is
greatest for securities categorized in Level 3. In
certain cases, the inputs used to measure fair value
may fall into different levels of the fair value
hierarchy. In such cases, for disclosure purposes,
the level in the fair value hierarchy within which the
fair value measurement falls in its entirety is
determined by the lowest level input that is
significant to the fair value measurement.
Fair value is a market-based measure considered
from the perspective of a market participant rather
than an entity-specific measure. Market participants
are buyers and sellers who are independent,
knowledgeable, willing, and able to transact for the
subject asset or liability in its principal or most
advantageous market. Therefore, even when
market assumptions are not readily available,
FAMR’s own assumptions are set to reflect those
that market participants would use in pricing the
asset or liability at the measurement date. FAMR
uses prices and inputs that are current as of the
measurement date, including during periods of
market dislocation. In periods of market dislocation,
the observable prices and inputs may be reduced for
many securities. This condition could cause a
security to be reclassified to a lower level within the
fair value hierarchy.
Procedures
Valuation Techniques
FAMR has outsourced portfolio accounting to Black
Diamond (BD), a subsidiary of SSC/Advent. Black
Diamond values all securities held in client accounts
daily utilizing pricing services including but not
limited to Interactive Data Exchange.
9 | P a g e
BD values investments in securities and securities
sold short that are freely tradable and are listed on a
national securities exchange or reported on the
NASDAQ national market. These are categorized as
Level 1 securities.
The fair value of corporate bonds is estimated using
recently executed transactions, market price
quotations (where observable), or dealer market
bid-ask inputs. Corporate bonds may be categorized
as Level 1 or 2 securities. In instances where
significant inputs are unobservable, they are
categorized as Level 3 securities.
CMBS and ABS are estimated using recently
executed transactions, market price quotations
(where observable), or dealer market bid-ask
inputs. CMBS and ABS are categorized as Level 2
securities when external pricing data is observable
and as Level 3 when external pricing data is
unobservable.
Dealer Market Inputs
Certain securities (those in dealer markets) use
inputs based on bid and ask prices that can be
observed in the marketplace. The bid prices reflect
the highest price that the marketplace participants
are willing to pay for an asset. Ask prices represent
the lowest price that the marketplace participants
are willing to accept for an asset. For securities
whose inputs are based on bid-ask prices, FAMR’s
valuation policies require that fair value be within
the bid-ask range. For those securities valued by
using a broker’s quote, FAMR will determine whether
the quote or price is based on actual transactions,
reflects the willingness of the broker to trade at that
price, or is based on a model or another
methodology. When the information is based on
other than actual transactions, FAMR will periodically
go back and compare the actual prices realized on
any sale to the fair values used. Then, determine
the reasons for any wide gaps and implement
improvements in pricing processes.