Governance
Investment Policy Committee
LotusGroup Advisors’ Investment Policy Committee’s (IPC) role is to develop Client specific strategies by marrying the unique circumstances of the Client with the firm’s portfolio strategies. Each Client has a dedicated IPC working together as a team, each of whom has a distinct day-to-day role, thus leveraging individual expertise. Raphael Martorello (Chief Investment Strategist) is responsible for the broad macroeconomic analysis as well as the tactical asset allocation changes in response to market conditions.
Andy Seth (Chief Operations Officer) is responsible for portfolio engineering and implementation, keeping the portfolio in compliance with the Investment Policy Statement (IPS), and the efficient and timely execution of tactical changes. The Private Client Advisor is the liaison who seeks to understand the Client’s situation and changes and brings those to the IPC who in turn, adjusts its strategies and tactics as appropriate.
As part of the process, the IPC meets immediately upon the conclusion of the Client’s Intro Interview to develop an IPS which becomes the governing document by which the Client’s portfolio is managed. The IPS is delivered to the Client to establish a mutual understanding prior to portfolio implementation and is updated by the IPC as changes to the Client’s situation arise that would affect the strategic and tactical execution.
POLICIES AND PROCEDURES
Material, Non-public Information and Insider Trading
LotusGroup Advisors, LLC. (LGA) will comply with all laws and regulations regarding the use of material, non-public information. The purpose of this material, non-public information and insider trading policy is to prevent the trading of securities, even for the benefit of the client, based on the use of material, non-public information in violation of the Securities Act of 1934, as amended, or rules and regulations promulgated there under.
Disaster Recovery, Contingency Planning and Internal Controls
LotusGroup Advisors, LLC. (LGA) will maintain a plan to recover all the company’s records in the event of a disaster and will plan for contingencies that may impact its operation. The purpose of this disaster recovery and contingency planning is to fulfill our fiduciary responsibilities and obligations to our clients even during a disaster or other event disrupting the normal operation of our business.
Privacy Policy
LotusGroup Advisors, LLC. (LGA) will ensure the privacy of clients. The purpose of this privacy policy is to ensure the safeguarding of our customers non-public personal information.
Valuation of Securities in Clients’ Accounts
All securities held in clients’ accounts will be valued by outside reputable pricing services at all times. Never will LotusGroup Advisors, LLC. (LGA) arbitrarily pricesecurities in accounts. The purpose of this securities valuation policy is to ensure fair, accurate, and equitable valuation of securities for all clients at all times.
Personal Securities Trading
LotusGroup Advisors, LLC. (LGA) prohibits all Investment Advisor Representatives (IARs) and /or its employees from executing any transaction in securities in which one would acquire a direct or indirect beneficial ownership with the exception of personal trades which, where possible, are aggregated with the clients’ orders and are allocated on the same basis as that of the clients.
Access persons, officers and directors must periodically report personal securities transactions and holdings to the Chief Compliance Officer (CCO), who will review those reports to identify possible improper trading.
The purpose of this personal trading policy is to prevent any potential or appearance of conflicts of interest with any LGA clients and to ensure personal trading does not compromise or interfere with LGA’s fiduciary duty to its clients as also explained in our Code of Ethics (Exhibit A) and Part II of our ADV.
Trading – Best Execution
Unless otherwise specified in writing or specifically directed by a client, LotusGroup Advisors, LLC. (LGA) is authorized to use its best judgment to buy or sell securities and managed transaction for its clients and their accounts. LGA has no financial relationships with any Broker / Dealer and received no client referrals from these firms.
The purpose of this best execution trading policy is to seek the best terms reasonably available for clients’ transactions in order to fulfill our fiduciary obligation to act in our clients’ best interest.
Trading – Best Execution (Allocation Policy)
LotusGroup Advisors, LLC. (LGA) will utilize an allocation approach to block trading that maintains consistency and fairness across clients. The purpose of this best execution trading (allocation policy) policy is to ensure client interests are always placed first in order to fulfill our fiduciary obligation to act in our clients’ best interest.
ADV Part II – This is considered the ‘fine print’ although we’re proud of the fact that we have no conflicts of interest to disclose. To be compliant with the Financial Regulatory Authority (FINRA), we also keep an updated copy of the ADV filed and will let you know of any changes we make.