Altrius Capital Management, Inc. (“Altrius”) is an SEC-registered investment adviser based in New Bern, North
Carolina. Our firm was founded in 1997 and is organized as a Subchapter S-corporation under the laws of the
State of North Carolina. We have been providing investment advisory services since 2004. James M. Russo
is our principal owner. We have been delivering global balanced investment management services to a broad
range of clientele for more than a decade and seek to provide diversified investment management services
utilizing our fundamentally based, value oriented, and risk managed investment management process. With
an economics underpinning and a value-based philosophy, our investment management process is focused
on finding the best solutions for investors across markets in an effort to deliver risk managed out performance
over the short and long term.
As used in this Brochure, the words "we", "our" and "us" refer to Altrius 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.
Investment Management Services
We provide discretionary investment management services in accordance with your individual investment
objectives. In the event you decide to engage our firm to provide investment management services (which
may include certain financial planning and/or consulting services), you will be required to enter into a written
agreement with us setting forth the terms and conditions of the engagement, describing the scope of the
services to be provided, and the fees to be paid.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. This authorization includes deciding which securities to buy
and sell, when to buy and sell, and in what amounts, in accordance with your investment program, without
obtaining your prior consent or approval for each transaction. Discretionary authority is typically granted by the
investment advisory agreement you sign with our firm, a power of attorney, and/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.
Account supervision is guided by your stated objectives (balanced, conservative balanced, and equity tilted
balanced). We will assist you with identifying your investment objectives by assessing your risk tolerance
based upon your age, income, need for cash flows, investment goals, and emotional tolerance for volatility.
Strategies are then developed and implemented through an optimal combination of investments. When
constructing portfolios, we will determine how to allocate funds across different assets classes and securities.
Refer to the Other Financial Industry Activities and Affiliations section below for disclosures on investments in
our affiliated mutual fund(s).
We will also provide you with reports, at least quarterly, that generally include relevant account and/or market-
related information such as an inventory and appraisal of account holdings, and investment performance. We
may provide additional reports at your request. We encourage you to reconcile our reports with those received
from the qualified custodian. If you find your holdings differ between these two statements, call our main office
number located on the cover page of this Brochure.
In providing the contracted services, we are not required to verify any information we receive from you or from
your other professionals (e.g., attorney, accountant, etc.) and we are expressly authorized to rely on the
information you provide. You must promptly notify our firm if your financial situation, goals, objectives, or needs
change of if you wish to impose or change any reasonable restrictions on our management of your account(s).
Financial Planning
Financial planning defined services will typically involve providing a variety of services, principally advisory in
nature, to you regarding the management of your financial resources based upon an analysis of your individual
needs. At the inception of the client relationship, we will establish your objectives by collecting data and
reviewing your financial information and circumstances. Once such information has been reviewed and
analyzed, written reports designed to achieve your stated financial goals and objectives will be produced and
presented to you. The primary objective of this process is to allow us to assist you in developing a strategy for
the successful management of income, assets and liabilities in meeting your financial goals and objectives.
Financial plans may incorporate recommendations with respect to cash flow, assets and liabilities, asset
allocation, insurance analysis, education funding, retirement planning, estate planning, tax strategies, asset
protection, real estate, charitable giving, equity compensation, and small business planning. Additionally,
financial planning services include periodic reviews and assistance to you in implementing the plan as mutually
agreed upon. Financial plans are based on your financial situation at the time the plan is presented and are
based on the financial information disclosed by you to us. You are advised that certain assumptions may be
made with respect to interest and inflation rates and the use of past trends and performance of the market and
economy. Past performance is in no way an indication of future performance. We cannot offer any guarantees
or promises that your financial goals and objectives will be met. As your financial situation, goals, objectives,
or needs change, you must notify us promptly. Financial planning is offered through an ongoing relationship,
or, in narrowly defined circumstances, a limited scope defined service relationship.
Advisory Consulting Services
Some clients may need general consulting services on specific securities and non-securities related
investments. Such services may include some modular financial planning functions, or more general advice.
We do not offer legal or tax counsel. At your request, we will provide professional references in these and
associated areas.
Consulting services may include, but are not limited to, risk assessment/management, education funding, or
financial decision making/negotiation. Through this limited engagement, you agree to hold our firm and our
Associated Persons harmless from any liability arising out of any area(s) that we were not expressly contracted
to review and/or analyze. Fees and fee-paying arrangements for general consulting services are negotiated
on a case-by-case basis. In the event you decide to engage our firm for advisory consulting services, you will
be required
to enter into a written engagement letter with us describing the scope of the services to be provided
and the fees to be paid.
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, plan-level advice regarding fund selection and investment
options, and/or education services to plan participants regarding risk tolerance and investment choices.
Advisory Services to Retirement Plans
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 Security Act (“ERISA”). Pursuant to adopted regulations of the U.S. Department of Labor
under ERISA Section 408(b)(2), 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, potential conflicts of interest, the compensation we receive for providing
those services, and our status (which is described below).
The services we provide to your Plan and related compensation are described below in Item 5, and in the
service agreement that you have previously signed with our firm. We do not reasonably expect to receive any
other compensation, direct or indirect, for the services we provide to the Plan or Participants. Nonetheless, if
we receive any other compensation for such services, we will (i) offset the compensation against our stated
fees, and (ii) promptly disclose the amount of such compensation, the services rendered for such
compensation and the payer of such compensation to you.
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 as a fiduciary of the Plan as defined in Section 3(21) under
ERISA, only. In all cases, our status as a fiduciary under ERISA is clearly disclosed in the agreement you
previously signed. If there is any discrepancy between the disclosures in this paragraph and the agreement,
the agreement shall govern.
For purposes of complying with the U.S Department of Labor’s (“DOL”) Prohibited Transaction Exemption
2020-02 (“PTE 2020-02”) where applicable, Altrius acts a fiduciary within the meaning of Title I of ERISA
and/or the Internal Revenue Code (“IRC”), as applicable, in providing investment advice to a client regarding
a client’s retirement plan account or individual retirement account. The way Altrius makes money creates
some conflicts with client interests, so Altrius operates under a special rule that requires Altrius to act in the
client’s best interest and not put our interests ahead of the client’s interests.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put Altrius’ financial interests ahead of the client’s 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 the client’s best
interest;
• Charge no more than is reasonable for Altrius’ services; and
• Give the client basic information about conflicts of interest.
Altrius benefits financially from the rollover of client assets from a retirement account to an account that Altrius
manages or provides investment advice, because the assets increase Altrius’ assets under management and,
in turn, Altrius’ advisory fees. As a fiduciary, Altrius only recommends a rollover when we believe it is in the
client’s best interest.
At the opening of a rollover IRA account, Altrius shall conduct a fiduciary review of the client’s current
retirement plan account to consider if the rollover is in the client’s best interest. Considerations shall include
fees and expenses, available services, investment options, RMD deferral options, penalty-free withdrawal,
and loan provisions.
Sub-Advisory Services Offered to Other Registered Investment Advisers
We may act as a sub-adviser to other registered investment advisers (the “Principal Adviser”) who wish to
engage us to manage all, or a portion of, their clients’ portfolios. Both our firm and the Principal Adviser may be
granted dual trading authority. Under certain arrangements, we will have discretionary authority over a portion
of the assets to buy and sell based on the client’s individual needs. Typically, the Principal Adviser will have
discretionary trading authority over the client's account and will be responsible for supervising the
management of the account. Accordingly, the Principal Adviser will monitor the investment management
activity conducted on behalf of the account by our firm. Fees will be deducted from the account(s) held at an
unaffiliated, qualified custodian. Our firm and the Principal Adviser will share in the fee collected. This fee
sharing arrangement does not increase the client's advisory fee.
Currently, Altrius serves as sub-adviser to Altrius Global Dividend ETF (the “Fund”). From time to time, Altrius
may recommend to clients who do not meet the minimum to participate in a managed discretionary
relationship, that they invest in the fund. This presents a conflict of interest as Altrius receives a fee for
providing sub-advisory services to the fund. Clients are provided with this disclosure when presented with the
recommendation.
Types of Investments
Accounts are normally managed using individual common stocks and bonds, exchange traded funds (“ETFs”),
master limited partnerships and real estate investment trusts on an asset allocation basis. Additionally, we
may recommend other types of investments since each client has different needs and different tolerances for
risk. We may also advise you on any type of investment held in your portfolio at the inception of our advisory
relationship, or on specific types of investments at your request.
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 February 29, 2024, we provide continuous management services on $571,008,074 in discretionary
assets and $15,511,085 in non-discretionary assets where we may make recommendations and have the
authority to make purchases or sales.