Disclosure
Item 1.CoverPag
ENTRUST PARABLE CAPITAL, LLC
aRegistered Investment Adviser
CRD No. 172248
4705 NW 153rd Terrace
Edmond, Oklahoma 73013
Tel:(405) 412-8022
This brochure provides information about the qualifications and business practices of Entrust Parable Capital, LLC CRD No. 172248 (hereinafter “Entrust Parable” or the “Firm”). If you have any questions about the contents of this brochure, please contact Corey M. Kenedy, CCO, at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.
Item 2. Material Changes
The material changes in this brochure from the last annual updating amendment of Entrust Parable Capital, LLC on 03/19/2023 are described below. Material changes relate to Entrust Parable Capital, LLC’s policies, practices or conflicts of interests.
- Entrust Parable Capital, LLC has removed TD Ameritrade as a custodian and added Charles Schwab & Co., Inc. as a custodian due to Charles Schwab’s acquisition of TD Ameritrade. (Item 12)
Item 3. Table of Contents
Item 1. Cover Page........................................................................................................................................................1
Item 4. Advisory Business
Entrust Parable was formed as a limited liability company in June 2014. The principal owner is Corey M. Kenedy
While this brochure describes the business of Entrust Parable, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Entrust Parable’s behalf and is subject to the Firm’s supervision or control.
Entrust Parable offers a variety of advisory services, which include investment consulting, and investment management services. Prior to Entrust Parable rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with Entrust Parable setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”).
Investment Consulting Services
Entrust Parable offers clients a broad range of consulting services, which can include any or all of the following functions:
- Business Planning
- Cash Flow Forecasting
- Trust and Estate Planning
- Financial Reporting
- Investment Consulting
- Retirement Planning
- Risk Management
- Charitable Giving
- Tax Planning
While each of these services are typically rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below), certain of them will also be available on a stand-alone basis.
In performing these services, Entrust Parable is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Entrust Parable under an investment consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Entrust Parable’s recommendations and/or services.
Investment and Wealth Management Services
Entrust Parable manages client investment portfolios on a discretionary or non-discretionary basis. In addition, Entrust Parable can provide clients with wealth management services which include a broad range of comprehensive financial planning and consulting services as well as discretionary and/or nondiscretionary management of investment portfolios.
Entrust Parable primarily allocates client assets among various mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, and options in accordance with their stated investment objectives. In addition, Entrust Parable can also recommend that certain eligible clients invest in privately placed securities, which include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds).
Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage Entrust Parable to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Entrust Parable directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider
Entrust Parable tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. Entrust Parable consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify Entrust Parable if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if Entrust Parable determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
Client Assets Managed by Entrust Parable Capital
The amount of client assets managed by Entrust Parable Capital totaled $ 34,083,619.00 as of December 31, 2023. It is all managed on a discretionary basis.
Item 5. Fees and Compensation
Entrust Parable offers services on a fee basis, which include hourly fees, as well as fees calculated as a percentage of the balance of a client’s account.
Investment Consulting Fees
Entrust Parable charges an hourly fee for providing financial planning and consulting services under a stand-alone engagement. The hourly fee ranges from $120 - $200, depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. If the client engages the Firm for additional investment advisory services, Entrust Parable can offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. These fees are negotiable.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement and Entrust Parable requires one-half of the fee (estimated hourly) payable upon execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. The Firm does not, however, take receipt of $500 or more in prepaid fees in excess of six months in advance of services rendered.
Investment Management Fees
Entrust Parable offers investment management services for an annual fee calculated as a percentage of the balance of a client’s account. This management fee varies between 100 and 275 basis points (1.00% – 2.75%), depending upon the size and composition of a client’s portfolio and the type of services rendered. Please note a fee in excess of 2% is in excess of that normally charged in the industry and that asset allocation services can be obtained for less.
The annual fee is divided and charged monthly, in advance, calculated by the market value of a client’s account being managed by Entrust Parable on the last day of the previous month.
For new clients, the initial fee is charged at the beginning of the second month of service. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), Entrust Parable can negotiate a fee rate that differs from the range set forth above.
Performance-Based Fees
Entrust Parable can also offer investment management services to certain qualified clients for a performance-based fee in accordance with applicable laws, rules and regulations. Under this arrangement, the Firm charges a fee based upon the performance of a client account in addition to an annual fee based upon assets under management.
The performance fee is equal to 15% of the annual net gains achieved in a client’s account, subject to a high-water mark. The performance fee is charged annually in arrears, based upon the net portfolio gains achieved on the anniversary of the date on which the client initially engaged Entrust Parable.
The annual asset-based fee of 150 basis points (1.50%) is divided and charged monthly, in advance, based upon the market value of the assets being managed by Entrust Parable on the last day of the previous month. For new clients, the initial fee is charged at the beginning of the second month of service. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate
Fee Discretion
Please note Entrust Parable does not implement an assets under management tier fee schedule. Rather, Entrust Parable will, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, and account retention. Please note this discretionary method can cause accounts with relatively similar assets under management to be charged different fees.
Additional Fees and Expenses
In addition to the advisory fees paid to Entrust Parable, clients will also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, reporting charges, margin costs, charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses), deferred sales charges, oddlot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are described at length on page 13, Item 12, below.
Direct Fee Debit
Clients provide Entrust Parable with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Entrust Parable. Where required, Entrust Parable also sends to clients a written invoice itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based.
Account Additions and Withdrawals
Clients can make additions to and withdrawals from their account at any time, subject to Entrust Parable’s right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to Entrust Parable, subject to the usual and customary securities settlement procedures. However, the Firm generally designs its portfolios as longterm investments and the withdrawal of assets can impair the achievement of a client’s investment objectives. Entrust Parable can consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they will be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
Item 6. Performance-Based Fees and Side-by-Side Management
As stated on page 7, Item 5, Entrust Parable can provide advisory services to qualified clients for a performance- based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Although Entrust Parable believes that this fee arrangement best aligns the interests of the Firm and its clients, it will raise conflicts of interest. A performance fee creates the incentive for the Firm to make or recommend investments that are riskier or more speculative than would be the case absent a performance fee arrangement. In addition, where Entrust Parable charges performance-based fees and also provides similar services to accounts not being charged performance-based fees, there is an incentive to favor accounts paying a performance-based fee. Entrust Parable has procedures in place to ensure that any decisions are made are in the best interest of clients regardless of the applicable fee structure.
Item 7. Types of Clients
Entrust Parable offers services to individuals, trusts, estates, charitable organizations, corporations and business entities
Minimum Account Requirements
Entrust Parable does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Entrust Parable utilizes a combination of fundamental, technical and cyclical methods of analysis.
Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a particular fund or issuer. For Entrust Parable, this process typically involves an analysis of an issuer’s management team, investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental analysis is that while the overall health and position of a company may be good, evolving market conditions may negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information in determining the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on investor sentiment rather than the fundamentals of the company. A substantial risk in relying upon technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Entrust Parable will be able to accurately predict such a reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a macro (entire market or economy) or micro (company specific) level, rather than focusing on the overall fundamental analysis of the health of the particular company that Entrust Parable is recommending. The risks with cyclical analysis are similar to those of technical analysis.
Risk of Loss
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of Entrust Parable’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that Entrust Parable will be able to predict those price movements accurately or capitalize on any such assumptions.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares.
Options
Options allow investors to buy or sell a security at a contracted “strike” price at or within a specific period of time. Clients may pay or collect a premium for buying or selling an option. Investors transact in options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate on the performance of the underlying securities. Options transactions contain a number of inherent risks, including the partial or total loss of principal in the event that the value of the underlying security or index does not increase/decrease to the level of the respective strike price. Holders of options contracts are also subject to default by the option writer which may be unwilling or unable to perform its contractual obligations.
Item 9. Disciplinary Information
Entrust Parable has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
Entrust Parable is an independent investment advisor firm and only provides investment advisory services. The firm is not engaged in any other business activities and offers no services other than those described in this Disclosure Brochure. We do not have any arrangements whereby we recommend (or refer) clients to a third-party investment advisor.
Entrust Parable is not and does not have a related company that is a (1) broker/dealer, municipal securities dealer, government securities dealer or broker, (2) investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, and offshore fund), (3) other investment adviser firm (4) futures commission merchant, commodity pool operator, or commodity trading advisor, (5) banking or thrift institution, (6) accountant or accounting firm, (7) lawyer or law firm, (8) insurance company or agency, (9) pension consultant, (10) real estate broker or dealer, or (11) sponsor or syndicator of limited partnerships.
Item 11. Code of Ethics
Entrust Parable has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. Entrust Parable’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of Entrust Parable’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions will be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly affect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless:
- the transaction has been completed;
- the transaction for the Supervised Person is completed as part of a batch trade with clients; or
- a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact Entrust Parable to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Recommendation of Broker/Dealers for Client Transactions
Entrust Parable recommends that clients utilize the custody, brokerage and clearing services of Interactive Brokers and Charles Schwab & Co., Inc. (“Schwab”) for investment management accounts. Schwab offers independent investment advisers services which include custody of securities, trade execution, clearance and settlement of transactions. Entrust Parable receives some benefits from Schwab through its participation in the program.
Factors which Entrust Parable considers in recommending Interactive Brokers and Schwab or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Interactive Brokers and Schwab enable the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Interactive Brokers and Schwab can be higher or lower than those charged by other Financial Institutions.
The commissions paid by Entrust Parable’s clients to Interactive Brokers and Schwab comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to affect the same transaction where Entrust Parable determines that the commissions are reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a Financial Institution’s services, including among others, the value of research provided, execution capability, commission rates and responsiveness. Entrust Parable seeks competitive rates but will not necessarily obtain the lowest possible commission rates for client transactions.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers in return for investment research products and/or services which assist Entrust Parable in its investment decision-making process. Such research generally will be used to service all of the Firm’s clients, but brokerage commissions paid by one client may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest because Entrust Parable does not have to produce or pay for the products or services.
Entrust Parable periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Entrust Parable will receive without cost from Interactive Brokers and Schwab computer software and related systems support, which allow Entrust Parable to better monitor client accounts maintained at Interactive Brokers and Schwab. Entrust Parable will receive the software and related support without cost because the Firm renders investment management services to clients that maintain assets at Interactive Brokers and Schwab. The software and support is not provided in connection with securities transactions of clients (i.e., not “soft dollars”). The software and related systems support will benefit Entrust Parable, but not its clients directly. In fulfilling its duties to its clients, Entrust Parable endeavors at all times to put the interests of its clients first. Clients should be aware; however, that Entrust Parable’s receipt of economic benefits from a broker/dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker/dealer over another that does not furnish similar software, systems support or services.
Specifically, Entrust Parable will receive the following benefits from Interactive Brokers and Schwab:
- Receipt of duplicate client confirmations and bundled duplicate statements;
- Access to a trading desk that exclusively services its institutional traders;
- Access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and
- Access to an electronic communication network for client order entry and account information.
There is no direct link between Entrust Parable’s participation in Schwab’s customer program and the investment advice it gives to its clients, although Entrust Parable receives economic benefits through its participation in the program that are typically not available to Schwab retail investors. Additionally, Entrust Parable will receive the following benefits from Schwab through its registered investment adviser division: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its Registered Investment Adviser participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. The Firm also has the ability deduct advisory fees directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to the Firm by third party vendors. Schwab will fund business consulting and professional services received by Entrust Parable’s related persons.
Some of the products and services made available by Schwab through the program will benefit Entrust Parable but not its client. These products or services will assist Entrust Parable in managing and administering client accounts, including accounts not maintained at Schwab. Other services made available by Schwab are intended to help Entrust Parable manage and further develop its business enterprise. The benefits received by Entrust Parable’s participation in the program do not depend on the amount of brokerage transactions directed to Schwab.
Brokerage for Client Referrals
Entrust Parable does not consider, in selecting or recommending broker/dealers, whether the Firm receives client referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct Entrust Parable in writing to use a particular Financial Institution to execute some or all transactions for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to “batch” client transactions for execution through other Financial Institutions with orders for other accounts managed by Entrust Parable (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, Entrust Parable may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties.
Trade Aggregation
Transactions for each client generally will be affected independently, unless Entrust Parable decides to purchase or sell the same securities for several clients at approximately the same time. Entrust Parable can (but is not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among Entrust Parable’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which Entrust Parable’s Supervised Persons invest, the Firm generally does so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities and Exchange Commission. Entrust Parable does not receive any additional compensation or remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines which prohibit it from purchasing other securities which are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
Entrust Parable monitors client portfolios on a continuous and ongoing basis while regular account reviews are conducted on at least a quarterly basis. Such reviews are conducted by one of the Firm’s Principals. All investment advisory clients are encouraged to discuss their needs, goals and objectives with Entrust Parable and to keep the Firm informed of any changes thereto. The Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or recommendations and quarterly to discuss the impact resulting from any changes in the client’s financial situation and/or investment objectives.
Account Statements and Reports
From time-to-time or as otherwise requested, clients also receive written or electronic reports from Entrust Parable and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. In accordance with several states’ securities laws, the Firm also sends certain clients duplicate fee statements, as discussed on page 8, Item 5. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from Entrust Parable or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm provides compensation to McLoud Advisory Services, LLC and Tip-Top Capital LLC as a third-party solicitor for client referrals. In the event a client is introduced to Entrust Parable by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such referral fee is paid solely from Entrust Parable’s investment management fee and does not result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the solicitor is required to provide the client with Entrust Parable’s written brochure(s) and a copy of a solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement. Any affiliated solicitor of Entrust Parable is required to disclose the nature of his or her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a copy of the Firm’s written brochure(s) at the time of the solicitation in addition to a Solicitor Disclosure Statement to Client.
Other Economic Benefits
In addition, Entrust Parable is required to disclose any relationship or arrangement where it receives an economic benefit from a third party (non-client) for providing advisory services. This type of relationship poses a conflict of interest and any such relationship is disclosed in response to Item 12, page 13, above.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution authorizes Entrust Parable to debit client accounts for payment of the Firm’s fees and to directly remit those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to Entrust Parable. Where required, Entrust Parable also sends to clients a written invoice itemizing the fee, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based.
In addition, as discussed on page 16, Item 13, Entrust Parable will also send periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from Entrust Parable.
Item 16. Investment Discretion
Entrust Parable may be given the authority to exercise discretion on behalf of clients. Entrust Parable is considered to exercise investment discretion over a client’s account if it can affect and/or direct transactions in client accounts without first seeking their consent. Entrust Parable is given this authority through a limited power-of-attorney included in the agreement between Entrust Parable and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). Entrust Parable takes discretion over the following activities:
- The securities to be purchased or sold;
- The amount of securities to be purchased or sold; and
- When transactions are made.
Item 17. Voting Client Securities
Declination of Proxy Voting Authority
Entrust Parable does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations.
Item 18. Financial Information
Entrust Parable is not required to disclose any financial information due to the following:
- The Firm does not require or solicit the prepayment of more than $500 in fees six months or more in advance of services rendered;
- The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and
- The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
Item 19. Requirement for State Registered Advisers
Principal Executive Officers and Management Persons
COREYM.KENEDY(CRDNo.5470975)
Born 1980
Post-Secondary Education
- University of Central Oklahoma| B.A., Philosophy | 2002
Recent Business Background
- Entrust Parable Capital, LLC | Managing Member, CCO, CFO, Investment Advisor Representative | July 2014 – Present
- The Farmers Bank | Director | February 2017 – June 2020
- Merrill Lynch | Financial Advisor | January 2012 – June 2014
- Edward Jones Investments | Financial Advisor | January 2008 – January 2012