Neumeier Poma Investment Counsel LLC ("Neumeier") is an investment adviser registered with the United States Securities and Exchange Commission (the "SEC"), under the Investment Advisers Act of 1940 (the "Advisers Act").
Clients invest with us knowing we invest exclusively in small-cap value stocks (portfolio 30-40 holdings).
Neumeier's Compliance Manual sets forth policies and procedures that are reasonably designed to prevent violations of the Advisers Act and SEC rules by Neumeier and its employees as envisioned by SEC rule 206(4)-7(a).
Neumeier enforces a written Code of Ethics to comply with SEC Rule 204A-1. Employees are to comply with applicable federal and state securities laws and regulations.
As a fiduciary to each client, Neumeier owes each client the same duty of loyalty. As a consequence, Neumeier cannot give one client or group of clients' preference over other clients. Yet it is not always possible to execute all client transactions in the same security or other investments for all clients simultaneously. Therefore, Neumeier has adopted Transaction Allocation Policies as part of its Client Transaction Policies and Procedures for allocating, in an equitable manner, transactions among its clients participating in a given transaction. Conflicts are generally dealt w/ on a case by case basis.