Bernardi Asset Management, LLC (hereafter "we," "us," "our" and "BAM") is an SEC registered investment advisor. BAM was formed in 2000 as a subsidiary of Bernardi Securities, Inc. (BSI), a registered broker-dealer which was formed in 1984.
Types of Services BAM Offers: FIXED INCOME MANAGEMENT BAM offers separate account fixed-income management with a specialization in municipal bonds. BAM manages portfolios for taxable and tax-free accounts.
BAM believes our clients' bond portfolios represent the "bedrock" of their investment portfolio with the primary objective of capital preservation. BAM seeks to add value through active management relying on market expertise to capitalize on market inefficiencies and opportunities. BAM seeks to increase net after-tax return in a manner consistent with a client's investment parameters.
BAM utilizes a separate account framework to develop customized portfolios to meet each client's specific needs. Clients and advisors have the option of investing in BAM's tax-exempt or taxable strategies or creating a customized portfolio. Portfolio parameters are created in consultation with the client and/or their advisor. Portfolio management documents are required and serve as the basis for portfolio investments.
Additionally, BAM offers investment advice on corporate debt securities; certificates of deposit; taxable municipal securities; United States government and agency securities; and money market funds.
Effective June 2020, BAM offers only discretionary management with limited trading authority. All discretionary activity is directed by pre-established investment guidelines approved by client. Discretionary clients grant BAM discretion to manage the portfolio based upon investment strategy guidelines. BAM will have the authority and discretion to buy, sell, exchange, redeem, or otherwise effect transactions for the client's account consistent with these guidelines without prior notice to or consent from the client. Legacy non-discretionary clients are contacted before purchase or sale is made and the client must authorize transactions before execution. Recommendations are made pursuant to the investment strategy guidelines.
ASSET ALLOCATION PROGRAM BAM offers an Asset Allocation Program. In general, the strategies consist of varying proportions of fixed income, equity, and alternative investments. A Risk Tolerance Questionnaire is available to help clients in determining which strategy is most appropriate for them, if not otherwise directed by the client. The fixed income allocation is designed in accordance with what we believe are fundamental, long- term financial principles generally intended to control risk and generate cash flow over a complete market cycle. Exposure to equity and alternative investments provide clients with both passive and active exposure to these markets.
The strategies offered include:
•The Growth Objective – The investment objective of this strategy is capital appreciation. The 4 growth strategy is suitable for investors with a higher

risk tolerance with an investment objective of capital appreciation who have little to no need for investment income.
•Balanced Objective – The investment objective of this strategy is a blend of capital appreciation and income generation. The balanced objective strategy is suitable for investors with an average tolerance for risk with an investment objective of capital appreciation and income.
•Income Objective – The investment objective of this strategy is income generation and capital preservation. The income objective strategy is suitable for investors with a low risk tolerance and an investment objective of income and capital preservation. Asset Allocation Committee The Asset Allocation Committee is responsible for developing the strategies and selecting the securities that will be used for each asset class. There is no set minimum or maximum number of positions that will be held for an account or specific frequency that account positions will be traded.
All assets under the Asset Allocation Program are managed on a discretionary basis. BAM retains the discretion to revise the Asset Allocation Program of each strategy cited above, the investment allocation, or other characteristics of a Portfolio. IRA 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"). 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.
BAM Total Assets under Management (as of 09/30/2023) Discretionary: $338,820,937 Non-Discretionary: $9,666,182 5