A. If we or any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, we must disclose this fact.
Certain of our firm’s advisory affiliates, in their individual capacities, are registered representative with Purshe Kaplan Sterling Investments, Inc. (“PKS”), a registered broker-dealer and member FINRA/SIPC. Our firm is not affiliated with PKS. In order to comply with FINRA Conduct Rule 3040, PKS as an unaffiliated broker-dealer may periodically review the investment advisory transactions of our firm. This information will be viewed by PKS’ compliance department personnel for supervisory purposes only. No information viewed will be utilized for purposes of solicitation or shared with any affiliation outside the scope of regulatory compliance. Clients are under no obligation to act upon any recommendations or execute any transactions through our advisory affiliates if they decide to follow the recommendations.
B. If we or any of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities, we must disclose this fact.
Neither the Adviser nor any of its management persons is a commodity broker/futures commission merchant, a commodity pool operator, commodity trading advisor or an associated person for the foregoing entities or has an application for registration pending.
C. We must describe any relationship or arrangement that is material to our advisory business or to our clients that we or any of our management persons have with any related person. We must identify the related person and if the relationship or arrangement creates a material conflict of interest with clients. We must describe the nature of the conflict and how we address it.
1. Insurance company of agency:
Certain of our firm’s advisory affiliates, in their individual capacities, are licensed insurance agents with various insurance companies in the state of California. In their individual capacity, they may recommend, on a fully disclosed commission basis, the purchase of certain insurance products. A conflict of interest exists to the extent that our firm’s advisory affiliates may recommend the purchase of insurance products where our firm’s advisory affiliates receive insurance commissions or other additional compensation. Clients are under no obligation to act upon any recommendations or execute any transactions through our advisory affiliates if they decide to follow the recommendations.
2. Banking or thrift institution:
In addition, advisory affiliate(s) may refer clients to banks where clients would set up a margin account for which advisory affiliate(s) will be compensated by these financial institutions.
3. Real Estate Company:
Management person, Amit Stavinsky, is a general partner for Gapa, LLC, a limited liability company formed in California for real estate investments and development. Mr. Stavinsky spends 12-14 hours per month on this activity. Tamar Securities’ clients are not solicited to invest in this outside business therefore no conflicts of interest exist.
D. If we recommend or select other investment advisers for clients and we receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if we have other business relationships with those advisers that create a material conflict of interest, we must describe these practices and discuss the material conflicts of interest these practices create and how we address them.
Please see Item 4B of this Brochure. Prior to referring clients to third party advisors, we will ensure that third party advisors are licensed or notice filed with the respective authorities.