ADVI Advisors, LLC 1050 K Street, NW Suite 340 Washington, DC Tel This brochure was last updated on March 18, 2014

Transcription

1 ADVI Advisors, LLC 1050 K Street, NW Suite 340 Washington, DC Tel This brochure was last updated on March 18, 2014 This brochure provides information about the investment advisory qualifications and business practices of ADVI Advisors, LLC ("ADVI Advisors"). If you have any questions about the contents of this brochure, please contact us at the number listed above or at andy.statler@adviadvisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. ADVI Advisors is registered with the District of Columbia as an investment adviser; however, such registration does not imply a certain level of skill or training. Additional information about ADVI Advisors is available on the SEC's website at

2 MATERIAL CHANGES There are no material changes since the brochure dated August 29, 2013.

3 TABLE OF CONTENTS A. ADVISORY BUSINESS Background Services Provided... 1 B. FEES AND COMPENSATION... 1 C. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT... 2 D. TYPES OF CLIENTS... 2 E. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS... 2 F. DISCIPLINARY INFORMATION... 2 G. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS... 3 H. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING... 3 I. BROKERAGE PRACTICES... 4 J. REVIEW OF ACCOUNTS... 4 K. CLIENT REFERRALS AND OTHER COMPENSATION... 4 L. CUSTODY... 4 M. INVESTMENT DISCRETION... 4 N. VOTING CLIENT SECURITIES... 4 O. FINANCIAL INFORMATION... 4 P. REQUIREMENTS OF STATE-REGISTERED ADVISER... 5

4 A. ADVISORY BUSINESS 1. Background ADVI Advisors, LLC ( ADVI Advisors or the Company ), previously a part of HillCo HEALTH, LLC, and since August 2013, a wholly owned subsidiary of HillCo HEALTH, LLC, (n/k/a ADVI, LLC) is a boutique investment adviser firm whose primary business activity is to provide investment advisory services to clients concerning the health care industry and issuers. The sole owner of ADVI Advisors is ADVI, LLC whose primary owners are Marc Samuels and Lawrence Leisure. 2. Services Provided ADVI Advisors provides due diligence research and comprehensive analyses on health care and health care related issuers with respect to existing coverage, coding, and reimbursement frameworks for products as well as evaluations of potential regulatory and legislative risks of such health care and health care related issuers. ADVI Advisors will also provide research on health care related topics and industries at the request of the client. ADVI Advisors, at its discretion, will make its supervised persons available to clients to discuss its reports and analyses. Such reports and analyses will not be personalized by reference to the investment objectives or needs of the client. ADVI Advisors investment advisory services are non-discretionary; ADVI Advisors does not manage portfolios, vote proxies or exercise any form of investment discretion over clients accounts. B. FEES AND COMPENSATION ADVI Advisors annual fees range from approximately $50,000 to $180,000 per year per client. The exact fee charged is negotiated with the client on a case-by-case basis and depends on the level of services provided (i.e., frequency, type of due diligence performed, depth of research, availability to client, etc.). ADVI Advisors generally enters into written agreements for the services provided to clients. Fees are generally billed quarterly. Clients may pre-pay fees (but not six months or more in advance). Clients may terminate their relationship with ADVI Advisors at any time without penalty. Any pre-paid fees are refunded on a pro-rata basis. Clients may pay for services by submitting payment directly to ADVI Advisors. Clients may also pay for services pursuant to commission sharing arrangements with their respective brokerdealers. Fees are paid in this manner by the client directing its broker-dealer to make payment on its behalf. See also Section K. ADVI Advisors provides non-discretionary investment advice and research services. In order to trade the securities of issuers directly or indirectly referenced in ADVI Advisors analyses and reports, clients must open an account with a broker-dealer and will incur brokerage, custody and 1

5 related costs. See also Section I. ADVI Advisors is not registered as a broker-dealer and does not receive commissions for executing trades for its clients. C. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ADVI Advisors does not receive fees based on a share of capital gains on or appreciation of the assets of a client. D. TYPES OF CLIENTS ADVI Advisors client base for its services described above is primarily institutional asset managers, including asset managers to pooled investment vehicles. ADVI Advisors clients may also include banks, hedge funds, private equity funds, venture capital funds, and registered investment companies. ADVI Advisors does not have any minimum account size requirements. E. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ADVI Advisors conducts due diligence research and comprehensive analysis of health care related issuers with respect to existing coverage, coding, and reimbursement frameworks for products as well as evaluations of potential regulatory and legislative risks of such health care issuers. ADVI Advisors sources of information include newspapers and magazines, industry publications, government hearings, testimony, and meetings, government reports, inspections of corporate activities, corporate annual reports, prospectuses, filings with the SEC, and company press releases. Sources of information may also include policymakers and industry or trade group representatives. ADVI Advisors does not manage accounts or select the investment strategies to be used by the client. ADVI Advisors products and services are designed to be a factor to consider in conjunction with traditional investment analysis and may not account for certain material factors which may have affected, or may in the future affect, the securities, industries or markets involved. Clients should use ADVI Advisors products and services as one of several resources in implementing an investment strategy. Material Risks Involved: Investing in securities, including those of health care and health care related issuers, involves risk of loss that clients should be prepared to bear. There can be no assurance that the future performance of any issuer of securities made reference to directly or indirectly in reports and analyses provided by ADVI Advisors will be profitable or will be suitable for every investor. Securities of issuers in the health care and health care related industries may be subject to volatility based on changes in the regulatory environment. F. DISCIPLINARY INFORMATION There are no legal or disciplinary events involving ADVI Advisors that are material to a client s or a prospective client s evaluation of ADVI Advisors advisory business or the integrity of its management. 2

6 G. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Neither ADVI Advisors nor its supervised persons are registered as a broker-dealer, commodity trading advisor, commodity pool operator, or futures commission merchant. ADVI Advisors does not have any related person in the financial industry and does not recommend or select other investment advisers on behalf of clients. H. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ADVI Advisors has adopted a Code of Ethics which describes certain standards of conduct for its employees and supervised persons. ADVI Advisors does not buy or sell securities for its own account. ADVI Advisors supervised persons, employees, officers and directors may own, buy or sell securities of issuers which are discussed directly or indirectly in ADVI Advisors reports and analyses provided to clients. ADVI Advisors Code of Ethics is designed to protect clients interests and prohibits ADVI Advisors employees and supervised persons from engaging in securities transactions and activities for their own accounts that might conflict with or be detrimental to clients interests. Accordingly, supervised persons must obtain the approval of the Chief Compliance Officer before buying or selling any security. If approved, such permission will be good only for the period of time specified therein. If the approved trade is not executed within the time specified, a new clearance must be obtained. ADVI Advisors Code of Ethics also sets forth, among other things, general standards of conduct and reporting requirements imposed on ADVI Advisors supervised persons, including employees, officers and directors. ADVI Advisors monitors compliance with its Code of Ethics through a review of employee s securities/brokerage statements on a quarterly and annual basis. ADVI Advisors personnel may come into possession of material non-public information from its clients as well as through ADVI Advisors parent company, ADVI, LLC, which provides consulting services to health care industry participants. ADVI Advisors Insider Trading Policy and Procedures set forth, among other things, ADVI Advisors procedures to identify possible material, non-public information and prohibit ADVI Advisors employees and supervised persons use or distribution of such information. ADVI Advisors monitors compliance with its Insider Trading Policy and Procedures. ADVI Advisors will provide a complete copy of its Code of Ethics and Insider Trading Policy and Procedures to any client or prospective client upon request. ADVI Advisors may have an incentive to provide investment advice to clients concerning issuers which may be clients of ADVI, LLC, ADVI Advisors parent company. To mitigate this conflict of interest, ADVI Advisors personnel will not participate in any ADVI, LLC consulting activities and, where applicable, will disclose to clients that its parent company provides consulting services to such issuer. 3

7 I. BROKERAGE PRACTICES ADVI Advisors does not manage client assets, does not execute transactions for clients and does not direct brokerage. ADVI Advisors does not select broker-dealers for clients, does not negotiate brokerage services or commission rates for clients and does not require clients to execute trades through a particular broker-dealer. All brokerage selection decisions remain the sole responsibility of the client. J. REVIEW OF ACCOUNTS ADVI Advisors does not review client accounts and does not provide reports to clients regarding their accounts. K. CLIENT REFERRALS AND OTHER COMPENSATION ADVI Advisors may receive cash payments from broker-dealers in consideration of providing its research services to its clients. In such situations, ADVI Advisors acts as a third-party research provider in the client s commission sharing arrangements with its broker-dealer. ADVI Advisors does not compensate any third parties for client referrals, and does not have solicitor arrangements with any third party. ADVI Advisors does not select broker-dealers for clients, does not negotiate brokerage services or commission rates for clients and does not require clients to execute trades through a particular broker-dealer. All brokerage selection decisions remain the sole responsibility of the client. L. CUSTODY ADVI Advisors does not have custody over clients funds or securities. M. INVESTMENT DISCRETION ADVI Advisors does not have investment discretion over any client accounts. N. VOTING CLIENT SECURITIES ADVI Advisors does not manage client accounts and does not vote client proxies. Clients are responsible for making their own arrangements with an investment manager or custodian with respect to the voting of proxies. O. FINANCIAL INFORMATION ADVI Advisors does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. ADVI Advisors does not have discretionary authority over, or custody of, client funds. ADVI Advisors has never been the subject of a bankruptcy petition. 4

8 P. REQUIREMENTS OF STATE-REGISTERED ADVISER ADVI Advisors principal executive officer and management personnel are as follows: Mr. Andrew Statler, Chief Compliance Officer Born: February 12, 1988 Formal Education: Bachelor of Arts, Kenyon College, Recent Business Experience: Manager, CCO, Senior Analyst, ADVI Advisors, LLC, 08/2013 to present. Analyst and Director, Business Development, HillCo HEALTH, LLC, 01/2013 to 08/2013. Account Executive, Potomac Research Group, 02/2011 to 01/2013. Investment Performance Associate, Cambridge Associates, 09/2010 to 02/2011. Neither ADVI Advisors nor any supervised person is compensated for advisory services through performance-based fees. Neither ADVI Advisors nor any supervised person has been found liable in a proceeding described in Item 19 D of Part 2A of Form ADV. Neither ADVI Advisors nor any management person has any relationship or arrangement with any issuer of securities that is not listed herein. 5

9 Brochure Supplement for Andrew Statler ADVI Advisors, LLC 1050 K Street, NW Suite 340 Washington, DC Tel This brochure supplement was last updated on March 18, 2014 This brochure supplement provides information about the above listed individuals that supplements ADVI Advisors, LLC s ( ADVI Advisors ) brochure. You should have received a copy of that brochure. Please contact the Chief Compliance Officer, Mr. Andrew Statler, at the phone number above, if you did not receive ADVI Advisors brochure or if you have any questions about the contents of this supplement. Additional information about Andrew Statler is available on the SEC's website at

10 Andrew Statler, Chief Compliance Officer, Senior Analyst Educational Background and Business Experience. Born: February 12, 1988 Formal Education: Bachelor of Arts, Kenyon College, Recent Business Experience: Manager, CCO, Senior Analyst, ADVI Advisors, LLC, 08/2013 to present. Analyst and Director, Business Development, HillCo HEALTH, LLC, 01/2013 to 08/2013. Account Executive, Potomac Research Group, 02/2011 to 01/2013. Investment Performance Associate, Cambridge Associates, 09/2010 to 02/2011. Disciplinary Information None. Other Business Activities None. Additional Compensation None. Supervision ADVI Advisors monitors the advice provided to clients and other activities of Mr. Statler through its compliance procedures and periodic meetings with the management personnel of ADVI Advisors owner, ADVI, LLC. ADVI, LLC may be reached at (202)