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OUR INVESTMENT MANAGEMENT APPROACH

Nicholson Capital Management customizes each client's portfolio depending on their risk tolerance, time horizon and income needs. Individual stocks may be appropriate for some accounts, but not for others. No-load stock mutual funds may be a better choice for those accounts. The Firm uses a Target Strategy Statement for each client, which tracks asset class targets and current allocation. This Statement is used to allocate and monitor the portfolio.

For those accounts using individual stocks, the Firm's individual stock strategy uses a "blend" style of value and growth stocks with a multi-cap focus. There will be an emphasis on certain cap sizes as the market dictates. The allocation between value and growth during any given year may change depending on the manager's outlook for the market. Individual stocks may be used in conjunction with a diversified list of mutual funds where warranted. These funds will be used in areas, such as international investments, where individual stocks would not normally be purchased. For those accounts using only equity mutual funds for the equity allocation, funds will be chosen which will mirror, as closely as possible, the Firm's individual stock strategy. The Firm has also developed a proprietary stock selection system, the Central Stock Selection System, which uses a database of 1700 stocks to scan for undervalued individual stocks. This system combines technical and fundamental analysis. The Firm also uses two sophisticated scanning database software packages to analyze and choose mutual funds.

The Firm's fixed income/bond style is "intermediate blend," and uses governments, municipals, corporates, and short-term bond funds to balance the bond portfolio. The Firm may also buy a diversified basket of high-yield bond funds where warranted. The emphasis among various fixed income sectors will be adjusted according to the Firm's outlook for movements within the bond market. The Firm may lower or raise bond maturity levels depending on the outlook for interest rate movements.

NCM uses a proactive management approach and will make shifts of asset allocation between stocks and bonds in response to the current market environment, as asset classes become over or undervalued.

NICHOLSON CAPITAL MANAGEMENT, INC - FEE SCHEDULE

Investment Management Accounts
Annual Fee, Deducted ¼ Quarterly

1% (.01)
7/10% (.007)
4/10% (.004)
¼% (.0025)
    times market value on first $1,000,000,
times market value on next $4,000,000,
times market value on next $5,000,000,
times market value on balance


Negotiated fees will be considered at certain asset levels.

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