Investment Policy Statement

SAMPLE

Tarpon Capital Management, Inc.
Investment Policy Statement

INTRODUCTION

The purpose of this Investment Policy Statement (IPS) is to establish a clear understanding between _________________________________ (“Client”) and Tarpon Capital Management, Inc (“Advisor”) as to the objectives of the Client’s investment portfolio. This IPS will:

• Establish reasonable expectations and guidelines for the investments
• Set forth an investment structure detailing permitted asset classes
• Encourage effective communication between the Advisor and the Client
• Serve as a reference over time to provide a long-term investment plan

This IPS is not a contract but will provide the framework within which the Advisor will help manage the assets of the Client. This IPS is intended to be a summary of an investment philosophy that provides guidance for the Client and the Advisor.

INVESTMENT OBJECTIVE

The Client’s objective for the investment assets of the account is:

___________________________________________

LIQUIDITY AND INCOME NEEDS

The Client has an immediate need for income from the account of:

$_____________________

TIME HORIZON

For the purpose of planning, the Client’s time horizon for these investments is:______________________

RISK TOLERANCE AND ASSET ALLOCATION

Deciding on the appropriate asset allocation is based on answers to the Client’s Risk Tolerance Questionnaire, and a discussion of current savings, income, employment status, personal investments and business holdings.

After review, an asset allocation of:  _____% Equity _____% Fixed Income is selected to achieve the Client’s objectives.

DIVERSIFICATION

Investment of the assets can include securities in the following categories:

I. Cash Equivalent

A. CD

B. Checking/Saving

C. Money market

D. Foreign Currency

II. Fixed Income

A. Short ? Long Term Bond

1. Government

2. Corporate

a. Investment grade

b. Below investment grade

3. Municipal

a. Investment grade

b. Below investment grade

4. Foreign

a. Developed market

b. Emerging market

III. Equity

A. Stock

1. Domestic large company

a. Growth

b. Value

2. Domestic mid company

a. Growth

b. Value

3. Domestic small company

a. Growth

b. Value

4. Foreign company

a. Developed market

b. Emerging market

B. Real Estate

1. Domestic REIT

2. Foreign REIT

C. Commodity

1. Energy

2. Precious Metal

3. Industrial Metal

4. Agricultural

*Investment constraints and/or preferences:  _______________________________________________

PORTFOLIO REVIEW

Advisor is personally available to the Client during normal business hours, and weekends.  Quarterly review of accounts is recommended. Cash flows will be deployed in a manner consistent with this Investment Policy Statement and the Client’s wishes.

REBALANCING PROCEDURES

Advisor will continually monitor the asset allocation. Any asset class deviating from the written strategy by more than 10% will be evaluated for reallocation.  Reallocations are normally required due to some asset class either greatly outperforming or underperforming. Asset-weight deviations of more than 10% will be reallocated as necessary to maintain target allocation.

RESPONSIBILITIES

The Client should always know that they have the ultimate responsibility for the investment of their assets. The Advisor will assist the Client to discharge this responsibility with the care, skill, and diligence that a prudent person, acting in a like capacity and familiar with such matters, would use under such circumstances.  The Client should provide the Advisor with all relevant information on financial condition, net worth, and risk tolerance and will notify the Advisor promptly of any changes to this information. Failure to disclose all such relevant information will limit the Advisor’s ability to provide prudent investment advice.

ADOPTION

Adopted by the Clients this ________ day of  ______________________, ___________.

Client   _________________________

Client   _________________________