Introduction
Hollister Associates, LLC (“Hollister”, “our firm”, “we”, or “us”) is registered with the Securities and Exchange Commission (“SEC”) and the Financial Industry Regulatory Authority (“FINRA”) as a broker-dealer. Brokerage and investment advisory services and fees differ and that it is important for the retail investor (‘investor” or “you”) to understand the differences. Free and simple tools are available to research firms and financial professionals at http://www.investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing.
Q. What investment services and advice can you provide me?
Our firm offers brokerage services to retail and institutional investors. Retail investors may invest in private placements of issuers, such as companies, private equity funds, and/or other funds, when we act as a placement agent and/or finder/referral agent. We may refer investors to other investors to facilitate the purchase or sale of securities or refer investors to investment advisers of separately managed accounts. We may offer recommendations to retail investors.
We generally require you to meet the SEC’s definition of an accredited investor, which establishes thresholds for net worth and annual income and status, but we do not have minimum investment amounts. Issuers of a security or sponsors of a product may have minimum investment amounts or require investors meeting higher qualifications requirements than that of an accredited investor. Our firm does not accept limited discretionary authority. We do not monitor your investments as a standard service nor establish brokerage accounts on behalf of you. We only offer a limited number of product or security types available in the financial industry. We cannot meet all your asset class diversification needs, address all of your financial needs and objectives, or make available to you all securities product types. In limited circumstances, our firm may serve as a placement agent for securities issued of entities controlled by or managed directly or indirectly by our firm’s financial professionals.
Conversation Starters – Ask us the following questions:
• Given my financial situation, should I choose a brokerage service? Why or why not?
• How will you choose investments to recommend to me?
• What is your relevant experience, including your licenses, education, and other qualifications? What do these qualifications mean?
Q. What fees will I pay?
You may pay commissions for investing in a private placement; commissions and/or fees for referrals to other investors; or an asset management fee to the investment adviser for allocating capital to a separately managed account. Commissions for private placements are received by us from the issuer, manager, investment adviser, or escrow agent for the issuer or other financial institutions. Commission/fees for referrals of investors to other investors may be paid directly to us, by you, the counterparty investor, escrow agent/attorney, and/or other financial institution. A percentage of asset management fees collected by an investment adviser for management of separately managed accounts may be paid by the investment adviser to us provided you continue to maintain assets with the investment adviser . Commissions are typically charged at the time of the transaction for private placements and referral of investors to other investors. Fees for separately managed accounts are assessed by the investment adviser at regular intervals. You may also be subject to a carried interest fee imposed by the issuer for the benefit of the manager or investment adviser, which may be owned and/or controlled by one of our firm’s financial professionals. We may be entitled to such fees. Retail investors will nominally pay more commissions when investing higher amounts and/or more frequently investing in
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private placements. We inherently have a conflict to recommend a retail investor invest more capital and/or invest in private placements with greater frequency.
You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.
Conversation Starters – Ask us the following questions:
• Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?
Q. What are your legal obligations to me when providing recommendations? How else does your firm make money and what conflicts of interest do you have?
When we provide you with a recommendation, we have to act in your best interest and not put our interest ahead of yours. The way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the recommendations we provide you. Here are some examples to help you understand what this means. The receipt of compensation gives us an incentive to recommend larger investments in and more frequent investments in private placements. Differences in commissions paid to us by issuers gives us an incentive for us to market products offering higher commissions.
At other times, we do not provide recommendations. The way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the services we provide you. Here are some examples to help you understand what this means. When acting as a finder/referral agent, we:
1) have an incentive to provide your name to as more advisers, managers, or issuers as we will receive compensation if you make an investment;
2) do not have the same level of due diligence obligations to you as we otherwise have when making a recommendation.
Conversation Starters - Ask us the following questions:
How might your conflicts of interest affect me, and how will you address them?
Q. How do your financial professionals make money?
Financial professionals receive commissions and/or fees earned by our firm consistent with agreements entered into by Hollister Associates, LLC. Financial professionals have an incentive to recommend investments and/or refer more investors to receive increased potential compensation.
Q. Do you or your financial professionals have legal or disciplinary history?
Yes. Some of our financial professionals have legal and/or disciplinary history. Hollister Associates, LLC does not have a legal or disciplinary history. Visit http://www.investor.gov/CRS for a free and simple search tool to research Hollister Associates, LLC and financial professionals.
Conversation Starters - Ask us the following questions:
• As a financial professional, do you have any disciplinary history? For what type of conduct?
Additional Information
For additional information about Hollister Associates, LLC and our services, please visit http://www.investor.gov/CRS and FINRA’s BrokerCheck (https://brokercheck.finra.org/).
You may also contact us for information, including a copy of the relationship summary, by calling 404 317-4781.
Conversation Starters - Ask us the following questions:
• Who is my primary contact person?
• Is he or she a representative of an investment adviser or a broker-dealer?
• Who can I talk to if I have concerns about how this person is treating me?”