Description of Services and Fees
Glovista is a registered investment adviser with offices in New Jersey and Florida. We are
organized as a limited liability company under the laws of the State of Delaware. We have
been providing investment advisory services since 2007. Carlos Asilis and Darshan Bhatt are
our majority beneficial owners. A minority ownership interest is held by Spouting Rock Asset
Management, LLC (“SRAM”), an SEC registered investment adviser.
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 needs. As used in this Brochure, the words "we", "our" and "us" refer to
Glovista 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.
Portfolio Management Services
Glovista provides investment management services to clients through a) separately managed
accounts (“SMAs”), and b) privately offered pooled investment vehicles (“Private Funds”). The
SMAs and Private Funds are hereafter referred to as the Firm’s “Clients”. Your investment in
any Client is referred to herein as your “Account”. Interests in the Private Funds are exempt
from registration under the Securities Act of 1933, as amended, and exempt from registration
under the Investment Company Act of 1940, as amended. As such, Private Funds are only
offered via a “private offering” and are intended only for investment by “accredited investors.”
The investment guidelines for each Client are defined in the investment management
agreement, organizational documents, or other governing documents relating to each Client
and are tailored to the specific goals, objectives and operating guidelines of each Client.
In most cases, we provide Clients with portfolio management services focusing on two distinct
strategies: first, we offer a “Global Tactical Asset Allocation” strategy (“GTAA Strategy”) that
leverages our global macro views to position the portfolios in appropriate asset classes and
sub-asset classes; second, we provide Clients with exposure to emerging market equities
through a strategy that employs US listed liquid ETFs and ADRs on a managed account basis
(“Emerging Markets Strategy”).
Our GTAA Strategy is designed to provide Clients with tactical exposure to the “correct”
asset class. Within such asset class, we provide appropriate sub-asset class exposures. We
provide access to multiple asset classes via tactical allocations to global equities (US, EAFE and
Emerging markets), Global Fixed Income (Sovereign, Investment Grade and High Yield),
Commodities and Currencies. We use liquid listed ETFs and Dollar denominated securities.
Our Emerging Markets Strategy is designed to exploit inefficiencies in the pricing of global and
regional macro variables and in the valuation of out-of-favor sector and country indices. We
seek to identify value plays (from a macro perspective) within emerging markets, taking into
consideration the primary role exerted by currency valuation and economic growth. We
utilize bottom-up quantitative value-driven models to cross-verify our top-down macro view.
Our Emerging Markets portfolio has a bias towards large liquid countries and large cap stocks
within emerging market equities. The portfolio is typically comprised of 8-12 country ETFs
representing more than 300 underlying stocks and a few large cap liquid ADRs. Our strategy
is an actively managed strategy with a high turnover ratio.
Generally, the investment advice offered by Glovista is limited to the investment strategies
described above and as further detailed in Section 8 below. Glovista manages its Client
Accounts based on these strategies, subject to the restrictions and guidelines set forth in each
Client agreement and does not tailor its advisory services to any Fund investor or SMA Client
except that Glovista will manage other strategies related to its core GTAA or EM strategies
at the specific request of a Client subject to review and agreement on the type of strategy,
applicable investment restrictions, minimum account size and agreement on fees.
If you participate in our discretionary portfolio 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.
You will be charged a fee for portfolio management services which is generally billed monthly
or quarterly in arrears based on the asset value of your Account during the relevant billing
period. In most cases, we will compute fees based on “average capital base” under
management. Average capital base is determined by calculating the market value of the
Account at the beginning of the period and adjusting for any additional paid-in capital during
the period. In our sole discretion, we may negotiate other fee payment arrangements with
you. Fees will be assessed pro rata in the event the portfolio management agreement is
executed at any time other than the first day of the month.
In addition to an asset-based fee, “qualified clients” (who have a net worth of more than
$2,200,000 or at least $1,100,000 under management with our Firm) and Private Funds Clients
may be charged a negotiable performance-based fee. The performance-based fees are based
on profits generated for investors subject to certain conditions described below. In each case,
the performance fees are specifically authorized by you in the relevant investment management
agreement or disclosed in any Private Fund disclosure documents.
We may charge performance-based fees of up to 20% on an annual basis of the profits
generated in the account, billed quarterly in arrears based upon the asset value of the account
on the last day of the month. This performance
fee will comply in full with Rule 205-3 under
the Investment Advisers Act of 1940.
The performance fee allocation with respect to any Account may be subject to a "high water
mark" provision such that no performance fee will be paid to us, except when the account
surpasses the highest value for the investments in your Account, subject to adjustment for
withdrawals or contributions.
The performance fee calculation may create an incentive for our Firm to make investments
that are riskier or more speculative than would be the case in the absence of a performance
fee formula.
With respect to Accounts, we will either invoice you directly for management fees or
management fees will be paid to us by the qualified custodian holding your funds and securities,
provided that you supply written authorization permitting the fees to be paid directly from
your Account. We will not have access to your funds for payment of fees without your written
consent. Further, the qualified custodian agrees to deliver an account statement, at least
quarterly, directly to you, showing all disbursements from your Account. We encourage you
to review all account statements for accuracy. Our Firm will receive a duplicate copy of the
statement that was delivered to you.
With respect to Clients for whom we manage an SMA, either party, upon 30 days written
notice to the other, may terminate the management agreement. The management fee will be
pro-rated for the month in which the cancellation notice was given.
Please see Section 5: Fees and Compensation below for a complete description of our fees.
Wrap Fee Programs
“Wrap arrangements,” “wrap fee programs,” and/or “wrap fee accounts” involve individually
managed accounts for individual or institutional Clients. The wrap fee accounts are offered as
part of a larger program by a “sponsor,” usually a brokerage, banking or investment advisory
Firm, and managed by one or more investment advisers. Glovista has agreements with several
brokerage, bank or investment advisory firms (sponsors) who sponsor “wrap fee” programs
where Glovista acts as adviser or sub-adviser to the wrap fee program and provides
investment management services to those Clients who select Glovista as part of the program.
The sponsor typically pays a portion of its program fee to Glovista for its services.
Generally, Glovista’s management of wrap fee accounts and other accounts under the same
investment strategy is consistent. Subject to our best execution policy, when selecting brokers
for trading for our wrap fee program accounts, Glovista at its discretion may trade with
different broker/dealers than for our other (non-Wrap) accounts or trade away with a single
broker/dealer on a combined basis. Trades for wrap fee program accounts are typically
directed to the wrap fee program sponsor (or its designated broker/dealer), since brokerage
commissions are included in the wrap fee. In such situations, Glovista may be required to trade
a wrap fee program’s accounts separately from other accounts being managed within the same
strategy. As described in “Item 12- Brokerage Practices,” while directed brokerage is designed
to benefit the wrap fee program account through lower trading costs, there may be
circumstances where directed trades do not receive the best price, or where dividing the
trade into separate components may inhibit Glovista’s ability to obtain the same level of or as
timely an execution as it may otherwise have been able to obtain if it had been able to execute
the entire trade with one broker/dealer. Operational limitations with these types of accounts
make trading away from the sponsor difficult. To the extent that Glovista trades away from
the sponsor by placing trades with a different brokerage firm, the Client will typically incur the
costs associated with this trading in addition to the wrap fees normally payable. Subject to
these limitations, Glovista continues to employ methods, such as trade rotation and periodic
brokerage review, in an effort to reduce the impact of these issues. Clients who enroll in these
programs should satisfy themselves that the sponsor is able to provide best price and
execution of transactions.
Glovista may engage in wrap programs involving both single-contract and dual-contract
accounts. In a single contract, the sponsor typically provides a level of research and due
diligence on Glovista and often stands as a co-fiduciary with Glovista. Customers execute one
contract with the sponsor. Dual contract programs require a customer to execute two
separate contracts: one covering services provided by the sponsor; and the other covering
separate investment management services provided by Glovista.
With respect to single contract wrap fee program accounts, Glovista may not be provided
sufficient information by the wrap fee program sponsor to perform an assessment as to the
suitability of Glovista’s services and investment strategy for the Client. In such cases, Glovista
will rely upon the wrap fee program sponsor who, as part of its fiduciary duty to the Client,
must determine not only the suitability of Glovista’s services and investment strategies for the
Client, but also the suitability of the wrap fee program in general. In addition, Glovista relies
upon the wrap fee program sponsor to provide required disclosures to such Clients, including
delivery of this Form ADV Part 2A (Brochure) to Clients as required.
Please see additional information regarding wrap fee programs in “Item 5 – Fees and
Compensation.”
Types of Investments
As stated earlier, we primarily offer advice related to our GTAA Strategy and Emerging
Markets Strategy, but may also offer general advice on equity securities, corporate debt
securities, investment company securities, US Government securities, Foreign Exchange
forwards, and options contracts on securities.
Additionally, we may advise you on any type of investment that we deem appropriate based
on your stated goals and objectives. We may also provide advice on any type of investments
held in your portfolio at the inception of our advisory relationship. 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 December 31, 2022, our Regulatory Assets Under Management was approximately
$321.2 million. Of this amount, approximately $34.5 million was on a non-discretionary basis
and approximately $286.7 million was on a discretionary basis.