Stringer Asset Management is a registered investment adviser that provides services through (i) model portfolios on a sub-advisory basis
(through the direct delivery of said models and through separately managed accounts), and through (ii) a registered investment company,
the Stringer Growth Fund (the “Fund”). When acting as a sub-adviser or an adviser, the Firm’s relationship is generally with the institution
that designates Stringer Asset Management to manage such assets. Throughout this Disclosure Brochure, any reference to the institution
that designates Stringer Asset Management to manage assets is referred to as the “institutional client” as distinguished from the benefi-
cial owner of the assets being managed.
Prior to engaging Stringer Asset Management to provide any of the foregoing investment advisory services, all clients are required to enter
into one or more written agreements with Stringer Asset Management setting forth the terms and conditions under which Stringer Asset
Management renders its services (collectively the “Agreement”).
Stringer Asset Management was formed in October 2012 and is wholly owned by Laurus Principal Group, LLC.
This Disclosure Brochure describes the business of Stringer Asset Management. Certain sections may also describe the activities of Su-
pervised Persons. Supervised Persons are any of Stringer Asset Management’s officers, partners, directors (or other persons occupying a
similar status or performing similar functions), or employees, or any other person who provides investment advice on the Firm’s behalf and
is subject to Stringer Asset Management’s supervision or control.
INVESTMENT MANAGEMENT SERVICES
Institutional clients can engage Stringer Asset Management (“Firm”) to manage all or a portion of their assets on a discretionary basis. The
Firm offers model portfolios to institutional clients through a sub-advisory relationship. Pursuant to that relationship, the institutional client
is generally responsible for conducting an initial assessment and reviewing the investment needs, goals, objectives and risk tolerance of
the beneficial owner of the assets (or end-client). Thereafter, funds are allocated to Stringer Asset Management for discretionary manage-
ment services.
Stringer Asset Management primarily allocates clients’ investment management assets among exchange-traded funds (“ETFs”). In addi-
tion, when we feel it is appropriate or in the client’s best interests, Stringer Asset Management will allocate assets among individual debt
and equity securities, corporate debt securities, municipal securities, U.S. government securities and investment company securities.
When appropriate and desirable, the Firm will also research and offer advice pertaining to other types of investments as needed to meet a
client’s needs.
All clients are advised to promptly notify Stringer Asset Management if there are changes in their clients’ or their own financial situation or
investment objectives, respectively, or if they wish to impose any reasonable restrictions upon Stringer Asset Management’s management
services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their
assets be invested in socially responsible funds) if, in the Firm’s sole discretion, the conditions will not materially impact the performance
of a portfolio strategy or prove overly burdensome to its management efforts.
WRAP FEE PROGRAMS
Stringer Asset Management offers investment advice to clients through our participation in “wrap fee” programs. These programs are
offered by brokerage firms to provide their clients with access to non-affiliated investment advisers. Wrap fee accounts are managed in
the same manner as other accounts that we manage. If a sponsor’s client selects the Firm to manage funds, we receive a portion of the
fee charged by the sponsor.
DIFFERENT TYPES OF WRAP FEE PROGRAMS
Clients can access our strategies and the Stringer Growth Fund through wrap fee program SMA, UMA, or MDP accounts at Sponsor
Firms.
The following is a brief description of each type of account and discussion of how they differ from each other with respect to our offerings.
SMAs
A separately managed account (“SMA”) is an individually managed account offered by Sponsor Firms through one of their Financial Advi-
sors and managed by an independent investment management firm (the “investment manager” or “manager”). These programs typically
offer a wide array of investment managers from which the client can choose.
When a client (or a client’s Sponsor Firm with discretion) selects an investment manager for an SMA, the client will usually grant the in-
vestment manager full discretion (including trading discretion) over the account. With this authority, the manager directs trading activity in
the account according to its investment process and securities selection discipline. Trading discretion requires the investment manager to
seek best execution for trades executed in the SMA. Each SMA requires its own custodial account. As a result, a client who chooses to
invest with multiple managers maintains multiple custodial accounts at the Sponsor Firm – one for each investment manager selected.
If selected to manage the assets in a client’s SMA maintained by a Sponsor Firm, Stringer Asset Management will provide investment
management services on a discretionary basis to that client in accordance with one or more model portfolios selected by the client. For
more information about Stringer Asset Management's trading policies, please see Item 12 of this Brochure.
MDPs and UMAs
Model delivery platforms (“MDPs”) are wrap program accounts for which Stringer Asset Management only provides a model to the Spon-
sor Firm. Under these arrangements, Stringer Asset Management generally provides non-discretionary investment advice in the form of
the relevant investment models. Stringer Asset Management generally does not have discretion, trading or otherwise, over these ac-
counts. These programs are often referred to as Model Delivery Arrangements, Model Manager Sub-Advisory Arrangements, or Model
Delivery Platforms. Stringer Asset Management does not operationally distinguish between MDP accounts and UMA (as defined below).
Unified managed accounts (“UMAs”) are similar to MDPs, but there are important differences that investors should take the time to under-
stand. A UMA combines all of a client’s assets into a single account. While an MDP account holds the securities associated with a single
investment manager in a unique custodial account at the Sponsor Firm, a UMA typically holds multiple investment strategies in the same
custodial account, as well as other investment products, such as mutual funds, individual stocks, or bonds.
In a MDP or UMA account, the investment manager delivers an investment model to the Sponsor Firm and often does not have trading
discretion over the account. Clients should speak to their Financial Advisor about the similarities and differences associated with SMAs,
UMAs, and MDP accounts so they fully understand their specific account structure.
Performance Differences Between Stringer Asset Management SMA, UMA, and MDP Accounts
While Stringer Asset Management SMA, UMA, and MDP accounts utilizing the same investment solutions may perform similarly, there
are expected to be performance differences between them. There will be performance dispersion between UMAs and MDP accounts as
compared to SMAs because Stringer Asset Management does not have trading discretion over the UMAs and MDP accounts. For more
information on Stringer Asset Management’s trading policies and procedures, please see Item 12 of this Disclosure Brochure.
Assets Under Management (“AUM”)
On December 31, 2023, Stringer Asset Management had $47,866,340 in discretionary assets under management. Discretionary assets
are those over which the Firm has full authority to make investment decisions.
Assets Under Advisement (“AUA”)
As of December 31, 2023, Stringer Asset Management had $600,267,648 in assets under advisement. Assets under advisement repre-
sent those assets for which we provide investment decisions as to which securities to buy and/or sell, as well as the target weight of the
security involved in the trade, but for which we do not effect the trade. As a result, these assets are not included as assets under manage-
ment.