BASE Management Company is an independent fiduciary investment management firm
specializing in actively managed equity portfolios. BASE attempts to create real long run
investment returns for clients by incurring risk economically in pursuit of that return. BASE was
organized and has operated continuously since 1986.
BASE provides discretionary investment supervisory services for US entities including individuals
as well as trusts, charitable organizations and corporations. Investment supervisory service means
that investment advice and investment management is provided on a continuous basis and is
provided taking into account a client’s individual circumstances and needs, among other things.
BASE provides these services in exchange for fees based on the asset values involved.
Mr. Francis M. Hogle, III is President, CEO and majority owner of BASE. BASE has two other
shareholders: Carolyn Frenkil and Patricia Hoffman. Mr. Hogle, born in 1944, graduated with a
BS in Physics from Carnegie Institute of Technology in 1967. He has been a licensed professional
in the securities business since 1973. There are no other licensed personnel. BASE requires of its
personnel securities knowledge, securities experience as well as a compatible investment
philosophy. BASE does not accept non-discretionary accounts for an asset based fee, but it may
charge an appropriate hourly fee. BASE does not have a minimum account size, per se. Client
restrictions are an item for negotiation. When agreed to, such restrictions are applied on a best
efforts basis. BASE will deal with a client only if, in the sole opinion of Mr. Hogle, it can
reasonably provide the services that the account requires, and if, in the sole opinion of Mr. Hogle,
that BASE and the prospective client can conduct a mutually beneficial relationship. BASE does
not participate in wrap fee programs, in other words, BASE has no arrangements with brokerage
firms or other advisors to manage client assets.
BASE by its nature is a generalist. BASE selects and follows securities on its own and does not
rely on others for those functions. Research of value to BASE lies in suggesting structures of
analysis and relationships so that BASE can accomplish its own functions. BASE presently
manages approximately $49.4 million on a discretionary basis and approximately $45.6 million on
a non-discretionary basis. BASE claims compliance with the Global Investment Performance
Standards (GIPS). The firm consists of all client assets of BASE that are both discretionary and fee
paying, plus assets under BASE’s purview that are proprietary, related and (or) non-discretionary.
BASE Management Company, ADV Brochure, 03/31/23, Page 4 of 9
4a. CONFLICTS OF INTEREST
Because BASE’s investment philosophy is and has been supplied by Mr. Hogle, he and (or) related
entities may own securities or may trade in securities that BASE clients own.
BASE is a fiduciary adviser. While BASE attempts to eliminate conflicts of interest with clients by
design in BASE’s business methods, a class of conflicts exists that cannot be eliminated. Questions
of the size or of the existence of an account are clear examples of this. Because BASE charges an
asset based fee, it has an interest in the answer. BASE is unaware of any conflicting business
interests that might make its proxy voting interests different than those of its clients. (Please see
item 17)
BASE has no arrangements with third parties (unrelated entities) to receive or pay compensation
on, by, or as a result of BASE accounts (including soft dollar arrangements, execution rebates, and
sub advisor arrangements) except as contained in an agreement between BASE and Fidelity
Clearing and Custody Solutions. That agreement makes custody and execution services available
to BASE’s clients. That agreement was made based on Mr. Hogle’s experience with and contacts
within the Fidelity organization, and was based on the inability of many clients to negotiate
custody and
execution arrangements for themselves that are both favorable to themselves and
compatible with BASE’s need for electronic access to those accounts. While neither BASE nor
Fidelity receives any direct compensation from each other as a result of that arrangement, certain
aspects of Fidelity’s Wealth Central platform might be viewed as indirect compensation in one
direction or the other if BASE relied upon them. BASE does not view these aspects to be
significant, either to itself or to its clients. Clients are not required to use Fidelity and may direct
custody and (or) execution in any manner they choose that is compatible with BASE’s access and
(or) execution requirements respectively. (See, item 12)
The following are common conflicts of interest that are not present in BASE’s business:
1.BASE does not participate in wrap fee programs.
2.BASE does not receive compensation beyond the agreed upon fees related to BASE clients. All of
BASE’s revenue is from either client fees or investment returns on assets owned by BASE itself.
3.BASE does not charge performance based fees. (See, item 6)
4.BASE is not a broker-dealer and has no agreements with broker-dealers beyond the Fidelity
agreement described above. (See also, items 12 and 15)
5.BASE has no business relationship with mutual funds, unit trusts, private investment companies,
hedge funds, offshore funds, other financial advisors, financial planners, futures commission
merchants, commodity pool operators, commodity trading advisors, insurance agencies, pension
consultants, realtors, or sponsors of limited partnerships.
6.BASE does not engage in purchasing benefits for itself using client commissions (soft dollars).
7.BASE does not compensate for referrals. (See, item 14)
8.No partnership exists wherein related persons of BASE are general partners and BASE clients are
investors.
BASE Management Company, ADV Brochure, 03/31/23, Page 5 of 9
4b. PRIVACY
BASE collects nonpublic personal information about clients from a number of sources. It collects
information from clients and their designated agents, from consumer and business reporting
agencies, from brokers, dealers, custodians and from public sources. BASE uses this information
to form an opinion about suitability, to clear trades and generally to operate client accounts as
investment adviser.
BASE does not disclose nonpublic personal information about clients to anyone except as
permitted by law or as specifically directed by those clients. If a client decides to close an account,
or become an inactive customer, BASE will continue to adhere to the same privacy policy relative
to that account as described herein. Internally, BASE restricts access to client personal and account
information to those employees who need to know that information so that BASE can accomplish
its fiduciary responsibilities on its clients’ behalf. If Mr. Hogle should end his association with
BASE, both Mr. Hogle and BASE would be in possession of client nonpublic personal information,
subject in both cases to the privacy policy described herein. BASE maintains reasonable physical,
electronic and procedural safeguards to guard client nonpublic personal information.
As a matter of law, BASE may receive and share such personal information from and with brokers,
dealers, custodians, regulators, court systems in any relevant jurisdiction, and specified interested
parties on a need to know basis without specific authority from clients. BASE and its employees
will need written authorization in order to communicate nonpublic personal or financial
information to other client agents such as a CPA, a lawyer or other business or personal contacts
with whom clients would like BASE to share. BASE is not adverse to using electronic means of
communication; however, electronic communication is not private. BASE will need specific
written authority from clients in order to send sensitive information to them or to their designated
agents via electronic means.