Integrity

Lloyd Tevis Investments, LLC consistently adheres to the knowledge, skills and values of strong business practices designed to safeguard the advisory relationship in a professional and ethical manner.

Legal Standards

Lloyd Tevis operates on a fiduciary basis with regard to its clientele; this is a specific legal requirement on the company's part to give its clients its full faith & loyalty. The advice given is based on what is beneficial to our clients, not what is advantageous to the company or its employees.

Lloyd Tevis is a registered investment adviser, as such the firm is subject to the requirements of the Investment Company Act of 1940. This law spells out in detail the duties a fiduciary owes to his clientele and establishes specific business practices which are imposed on the company to ensure the fiduciary obligations are fulfilled. Government inspectors, to ensure compliance with the act, also periodically audit Registered Investment Companies.

While the 1940 Act defines the basic standards for fiduciaries, it also allows a diverse collection of business arrangements. For instance, a bank may own a registered investment company, but the bank is not subject to the 1940 Act. This creates a complex situation for the client, where the client speaks to multiple employees not realizing that the bank employees are not bound by fiduciary obligations; only the direct employees of the Registered Investment Company are.

At Lloyd Tevis, we go beyond the requirements of the 1940 Act. Lloyd Tevis is a stand-alone entity not associated with any financial provider. As such our business model is free of the conflicts of interest that plague firms combining advisory services with other financial services. In addition, clients can deal with our advisers secure in the knowledge that all staff are bound by common standards of fiduciary conduct.

Professional Standards

The law and standards above address the business relationship between the client and the company. Of equal importance is the professionalism with which the company serves the client. At Lloyd Tevis, we follow the well-established professional standards of the CFA (Chartered Financial Analyst) Institute. These include specific standards for:

• Ethical treatment of our clientele.
• Investment judgments which should be based upon a disciplined investment process.
• Fair amd standardized presentation of results to our clients.
• Maintenance of books and records to document compliance with the standard.

Company Policy

Beyond these practices, Lloyd Tevis has adopted two additional practices to safeguard its clients.

• Legal Powers – In general Lloyd Tevis does business with their clients without requiring any power of attorney delegation from their client.
• Privacy – It is Lloyd Tevis policy to hold client information in strictest confidence. Our privacy policy disclosure describes our practices in full detail. In broad summary, we adhere to high standards of client privacy protection. Except by operation of law or under written instructions from the client, Lloyd Tevis will not disclose client information to third parties. In particular, we will not sell the client's contact information or provide a client description to marketing organizations. Lloyd Tevis employs computer security techniques such as encryption and sequestration of personally identifying information in an effort to guard against data breaches and other cybercrimes.

Common Industry Abuses

While these measures may seem routine, they are rarely universally adopted. The majority of banks and brokerage houses operate on a nonfiduciary basis. While they may call their employees financial advisers, they are in fact commissioned salespeople. These employees are often compensated on their ability to generate revenue for their employer through sale of specific and/or proprietary products. Standard business practices, which violate no laws but which are not in the client's best interest are:

• Recommending investments created by the firm even though cheaper and more suitable investments of a similar nature are readily available from other providers.
• Accepting payments from investment providers in return for recommending their products.
• Entering into lucrative side businesses with firms whose securities are recommended for purchase.
• Obtaining instructions from individual investors to sell or buy and transacting those instructions with sophisticated trading firms which pay the broker for the opportunity to trade against his customer's orders.
• Ignoring key investment considerations, such as income taxes, with the result that clients are encouraged to trade more frequently.
• Preparing investment analyses which fall short of the standard of being fair, accurate and complete. As a consequence, such analyses may fail to reveal short comings and limitations in the advisor's recommendations.

We at Lloyd Tevis urge all investors to observe extreme caution when dealing with non-fiduciary companies. Expensive branding and self-promotion are no substitutes for legal protections.

Bad Advice

Finally, not all advice, even when given on a fiduciary basis, is good advice. For instance, an adviser may determine that a client is living beyond their means. In these circumstances, some advisers will recommend potentially high-risk investments in an effort to bridge the gap. While this gamble may work out, it definitely risks much worsening the client's financial position. Sadly, this practice is common and it is found even at well reputed firms.

Our policy at Lloyd Tevis is to always be honest about unrealistic client aspirations and instead guide our clients to personalized programs for their needs in good times and bad.

Precision investing^TM means advice in your interest only.