De Luchi Investment Management

The firm provides discretionary portfolio management to individuals and high‑net‑worth individuals, preparing an Investment Policy Statement for each client and focusing on mutual funds, fixed income, equities, REITs, ETFs (including precious‑metals ETFs), treasury inflation‑protected securities and selected non‑U.S. securities. It does not participate in wrap fee programs or delegate management to third‑party advisers, and clients are responsible for custodial and transaction costs charged by their broker‑dealer.

The investment approach centers on fundamental analysis and a long‑term trading horizon, with the adviser documenting risk tolerance and objectives in each client’s Investment Policy Statement and conducting at least quarterly account reviews and custodial reporting. The adviser generally operates with discretionary trading authority to implement the strategy without pre‑trade client approval.

Compared with many peers, the firm manages a relatively large amount of assets for a small number of clients, reflecting concentrated, high‑balance relationships and a standardized service offering that does not accommodate client‑imposed investment restrictions based on values or beliefs. The firm requires clients to use a specific institutional custodian (Schwab Institutional), may receive custodial research and other soft‑dollar benefits, does not aggregate trades for multiple client accounts, and discloses that supervised persons may accept outside compensation for sales of certain investment products — all items that can affect trade execution and present potential conflicts of interest.