1. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 1: Cover Page
Pawol Capital LLC
Home Office Address: 420 Wayne Ave., Ellwood City, PA 16117
Main Phone Number: (724) 674-8385
Web Site Address: http://pawolcapital.com
E-mail Address: info@pawolcapital.com
Organization CRD #: 165379
This brochure was last updated on September 11th 2012.
The brochure provides information about the qualifications and business practices of Pawol Capital
LLC. If you have any further questions about the contents of this brochure, please contact us at
info@pawolcapital.com or through our website address at http://pawolcapital.com. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission or any other federal or state authorities.
If you have any questions about this brochure, please contact Joshua Ryan Powell, manager, who is
responsible for regulatory requirements at (724) 674-8385 or jpowell@pawolcapital.com.
Registration of an IA to the SEC or any state authorities does not imply a certain level of skill or
training.
Pawol Capital LLC
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2. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 2: Summary of Material Changes
The United State Securities and Exchange Commission requires that we provide to all clients an annual
summary of material changes in ADV Part 2A. This summary discusses only 'specific' material changes
that are made to the Brochure since the last revision. We may further provide other ongoing
disclosure information about material changes as necessary, at any time, without charge.
Since this will be the initial Brochure there are no material changes.
Pawol Capital LLC
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3. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 3: Table of Contents
Item 1: Cover Page Page 1
Item 3: Summary of Material Changes Page 2
Item 3: Table of Contents Page 3
Item 4: Advisory Business Page 3
Item 5: Fees and Compensation Page 5
Item 6: Performance Fees and Side-by-Side Management Page 7
Item 7: Types of Clients Page 7
Item 8: Methods of Analysis, Strategies, and Risk of Loss Page 10
Item 9: Disciplinary Information Page 12
Item 10: Other Financial Industry Activities and Affiliations Page 12
Item 11: Code of Ethics, Personal Trading, Client Accounts Page 13
Item 12: Brokerage Practices Page 14
Item 13: Review of Accounts Page 15
Item 14: Client Referrals and Other Compensation Page 16
Item 15: Custody Page 16
Item 16: Investment Discretion Page 16
Item 17: Voting Client Securities Page 16
Item 18: Financial Information Page 17
4: Advisory Business
The Advisory Business
Pawol Capital LLC primarily manages hedge funds for clients. Hedge funds are pooled investments
where clients give us discretion to make investment choices for them based on various strategies and
objectives that we, the firm, and the individual client agrees upon.
Our services are generally built for high wealth clients, businesses, or clients with at least $750,000
assets under our management. Clients who do not fit into those categories may be turned away
because of securities laws requirements for accredited investors.
The firm also offers wealth management services where we manage an individual client's accounts
with an objective specified by the client. Client's of our wealth management services may discuss their
accounts with us as often as necessary to ensure their assets are being managed as needed.
The Firm's History
Pawol Capital LLC
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4. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Pawol Capital LLC was formed in July, 2012 by Joshua Ryan Powell. Mr. Powell's objective for the firm is
to provide clients effective investment products and personal financial advice. Acting as a fiduciary,
the firm operates in the best interest of every single client so to meet their personal goals an
objectives.
The Principal Owner
With 100% ownership interest in the firm, Joshua Ryan Powell makes all administrative and
investment decisions.
Amount of Assets Under Advisement
As this is the first Brochure toward registration, there are currently $0 under advisement.
Non-Participation in Wrap Fee Programs
Wrap fees and wrap fee programs are created to make a fee that is not directly based on the
investment advisory services rendered. By policy, Pawol Capital LLC does NOT charge wrap fees.
Available Advisory Programs (Services) Offered
1. Pawol Capital 'Select Funds' Hedge Funds
◦ Hedge funds with specific strategies
2. Pawol Capital 'Premium Funds' Hedge Funds
◦ Small hedge funds with specific objectives
3. Pawol Capital Portfolio Management
Each of these programs are described in further detail in Item 5 (“fees and Compensations”) of this
Brochure.
Available Services Objectives
Our services are all designed to meet the objectives of certain individual clients. We take careful
consideration when moving any of our client's assets into any specific objective by assessing the
client's needs, risk tolerance, and financial situation. Investments or inclusion into our hedge fund
products for our clients are always mutually agreed upon before executing any transactions.
Pawol Capital LLC
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5. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Pawol Capital 'Select Funds'
The objectives of our Select Funds are set by the fund's managers and advisers. The managers and
advisers of the fund will maintain a specific strategy. Changing client objectives do not change or
effect the fund. In the event that a client's objectives may change, we will advise the client to another
more suitable product or service.
Pawol Capital 'Premium Funds'
The objectives of our Premium Funds are set out by the fund's clients (partners). Changing client
objectives will directly effect the fund. If a client's stray too far from our other clients in the fund then
we will advise the client into a new more fitting product or service.
Pawol Capital Portfolio Management
Our portfolio management services are tailored to meet the needs of individual clients, based on a
mutually agreed upon strategy. Clients may meet with us at any time to re-evaluate their portfolio and
discuss their current needs and objectives – we will change their portfolio objectives as needed.
Item 5: Fees and Compensation (and service details)
How Fees are Paid For
On our fees may be paid by check or wire transfer. For our hedge funds products, fees are taken
directly out of the client's account.
Our Fees
Generally, our fees are set forth based on the following:
• Assets under management (AUM)
• Performance
What is not charged a fee:
• There is no fee for meetings or advisement
• There is no hourly fee
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6. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
• There is no minimum fee
• There is, generally, no sales charge or buy-in fee
All fees are negotiable. Negotiating fees depends on various factors such as relation to the client,
amount of initial investment, ease of strategy, amount of leverage needed, and additional transaction
fees or expenses associated with the account.
Higher initial investments receive price breaks. Price breaks depend on the product type – for
instance, Select Funds have more price breaks since average investment is smaller whereas Premium
Funds have few price breaks since required investment is much higher.
AUM Fees
These fees are generally paid annually and are recalculated annually. AUM fees are usually between
1.0 and 2.0%.
Performance Fees
These fees are mostly attached to hedge fund products and are higher in funds that are more actively
managed or produce higher than usual total returns. A normal actively managed hedge fund has a
performance fee of about 10% of the total returns created by our firm for the client. Performance fees
are generally paid out of client's account monthly. Client's may request to pay performance fees
quarterly for a slightly higher fee.
Other Fees Paid in Connection To Advisory Services
Fees paid to closed-end funds, ETFs, and various other securities are different than the fees which are
paid the firm. These fees are generally very small (less than 1% of the total amount invested in the
security) and vary in occurrence. These type of fees are paid by the clients directly out of their
investment.
For our wealth management services, Brokerage fees, transaction fees, and subscription fees are
charged to the clients account.
Performance-Based Fee Conflicts of Interest
Since we charge a performance fee to some hedge fund products, there is a conflict of interest. In
that, we mean that our management may be tempted to take on riskier investments so to induce
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7. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
higher performance. Each product we manage sets forth the risk tolerance level and clients should
only invest in a fund that meets their specific risk tolerance and objectives.
Item 6: Performance-Based Fees and Side-by-Side Management
Pawol Capital LLC charges a performance-based fee on some the firm's hedge fund products.
Performance-based fees are charged as a percentage of total return created by the firm for it's clients.
For example: In a year where there is a 10% performance fee, a total gain of $100 would create a
performance-based fee of $10.
Item 7: Types of Clients
The firm mainly provides investment advice to accredited investors. This includes wealthy individuals,
businesses, and clients who invest at least $750,000 into one of our funds.
As of 9/10/2012, the definition of an accredited investor is as follows (excludes financial institutions):
• Corporations or partnerships with assets exceeding $5 million
• A director, officer, general partner of a company selling securities
• Business in which all the equity owners are accredited investors
• Person who has an individual net worth (or joint net worth with spouse) that exceeds $1
million. This does NOT include the value of the primary residence, but DOES include real
estate.
• Person who made $200,000 each of the last two years or joint income with a spouse exceeding
$300,000 in those two years with a reasonable expectation of the same income level in the
current year
• A trust with assets in excess of $5 million, not formed to acquire the securities offered, whose
purchases a sophisticated person makes.
There is no expectation for this rule changing, but the current rule including the ruling in regards to
financial companies can be found at the following web address:
http://www.sec.gov/answers/accred.htm
Pawol Capital LLC
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8. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 8: Methods of Analysis, Investment Strategies and Risk of
Loss
Pawol Capital LLC provides clients with analysis, research, due diligence, account monitoring, and
recommendations to our clients. Clients of the firm receive the benefit of Pawol Capital LLC quant and
formulaic strategies, expansive research and proprietary analysis. Each clients with be evaluated to
assess the what the correct objective and risk level he or she should enter. Clients who wish to take on
more risk than recommended must sign an investment risk disclosure explaining that they understand
the risks that they are taking.
Methods of Analysis
In designing investments for client's portfolios, Pawol Capital LLC relies solely on the information
supplied by the clients and occasionally the clients' other professional advisors. This information
include detailed financial condition, current investments, emergency funds, employment history,
financial goals, age, lifetime plans, investment time horizon and perceived risk tolerance. We believe
with this information we can place the client in investments which match their goals and objectives.
Investment Strategies
Our hedge funds use strategies that involve formulaic and algorithmic models. We use these
sophisticated computer calculations to evaluate the market and individual securities. Upon evaluation,
we can deduce what securities will fit which our client's objectives.
Every security also goes through advanced technical analysis and fundamental analysis. Technical
analysis is a way of comparing a securities current chart pattern to historical chart movements.
Fundamental analysis is done by analyzing a company's financial condition and situation through their
financial statements, industry information, and research reports.
Types of Investments
Each hedge fund or client portfolio will consist of a variety or securities based on their risk tolerance
and investment goals. Any client portfolio may consist of securities on the follow page any any time.
Depending on the current market we may shift from one type of security to another.
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9. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Growth Stocks
Stock of a company that has had faster than average gains in earnings and is expected to continue to.
Growth stocks usually don't provide dividends. They carry the higher risk, but also may provide a
higher return.
Value Stocks
Stock of a companies which is perceived to be undervalued. Generally, value stocks are of companies
which are financially sound.
Strategy-specific ETFs
ETFs or exchanged traded funds are investment funds traded on public stock exchanges. They are
invested in a number of stocks or other securities that fit into the fund's strategy.
To fit certain strategies we may invest in ETFs which have a strategy that fits our fund's current
objective. For example, we may invest in Low Volatility ETFs during a time when we are trying to
remain invested in only conservative securities.
Sector ETFs
These are ETFs that invest in the stock of companies which are all from the same sector. For example
one ETF might invest in only bank stocks while another would invest in only oil and gas companies.
Leveraged ETFs
These ETFs use leverage to give much higher return than regular ETFs. This type of ETF also comes
with high risk. They are usually built as sector ETFs or cap specific ETFs where they only invest in
stocks of the same market cap (ie small cap, mid cap, large cap).
Publicly Traded Real Estate Investment Trusts (REITs)
REITs are the stock of companies which invest in real estate, either through properties or mortgages.
REITs receive special tax considerations by paying out 90% or more of their net income to
shareholders and typically offer investors high yields, as well as a highly liquid method of investing in
real estate.
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10. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Risk of Loss
Investing in securities involves a risk of loss that clients should bear in mind. Our investment
recommendations attempt to limit risk exposure by using sophisticated valuation and technical
models, but all investments carry risk of total loss no matter their 'implied' amount of risk.
Pawol Capital LLC seeks to achieve a positive return for investors, but this can not be guaranteed, and
investment objectives cannot be guaranteed to be met.
Risk of Loss, Certain Higher-Risk Securities
In the US marketplace, there are certain securities which possess a higher than average risk to
investors. This includes, but is not limited to, small cap stocks, leveraged ETFs, small cap funds and
developmental company stocks.
Pawol Capital LLC may employ these type of securities in a clients portfolio to reach their investment
goals and objectives.
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11. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Types of Risk
To educate clients, the following are risks that must considered.
• Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing their
market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and
intangible events and conditions. This type of risk is caused by external factors independent of
a security's particular underlying circumstances. For example, political, economic, and social
conditions may trigger market events.
• Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next
year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment's originating country. This is also referred to as
exchange rate risk. Note to currency risk: Pawol Capital LLC attempts to limit investment in
most US-listed foreign stock (ADRs) and foreign bonds in order to decrease currency risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested a potentially lower rate of return (ie interest rate). This primarily relates to bonds
and other fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then refining
it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability
than an electric company, which generates its income from a steady stream of customers who
buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business' operations increases the risk of
probability of bankruptcy because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations may
result in bankruptcy and/or a declining market value.
• Small Capital Stock Risk: Small companies often have narrower markets and limited financial
resources, so investments in these stocks present more risk than investments in those of larger,
more established Co’s.
Pawol Capital LLC
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12. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 9: Disciplinary Information
Registered Investment Advisers are required to disclose all material facts regarding any legal or
disciplinary events of their firm or certain management personnel which would be material to clients'
evaluation of Pawol Capital LLC management of clients' investment portfolio.
There is no legal or disciplinary events.
Item 10: Other Financial Industry Activities and Affiliations
No Pawol Capital LLC employees have any other affiliations or industry activities by policy. This
reduces conflicts of interest.
Pawol Capital LLC is NOT registered (and does NOT have an application pending) as a broker-dealer,
municipal securities dealer, or government securities dealer or broker. Pawol Capital LLC does NOT
have any relationship or financial arrangement that involves any of the following:
• Any mutual fund
• Other investment advisers or financial planner
• Futures commission merchant, commodity pool operator, or commodity trading advisor
• Banking or thrift institution
• Lawyer or law firm
• Insurance company or agency
• Pension consultant
• Real estate broker or dealer
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13. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Person Trading
Code of Ethics
• Treat every client with dignity regardless of their financial situation
• Maintain a professional attitude toward the business of investment advisory
• Act fully responsible with every client account and financial product
• Never take unnecessary risk in regards to clients funds or business risk
• Act in the best interest of every client
Pawol Capital LLC has adopted these Code the Ethics to express the firm's commitment to ethical
conduct and satisfaction for our clients.
Participation or Interest in Client Transaction and Personal Trading
Pawol Capital LLC does not participate in securities in which it has a material financial interest. Pawol
Capital LLC and its related persons, as a matter of policy, do not recommend to clients, or buy or sell
for client accounts, securities in which the firm or its related persons has a material financial interest.
Pawol Capital LLC, related persons and associated individuals may buy or sell securities for their
personal accounts identical or different than those recommended to clients. However, it is policy that
no person employed with Pawol Capital LLC may buy or sell securities solely in anticipation of
transactions for clients.
Pawol Capital LLC
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14. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 12: Brokerage Practices
Selected Brokerage Firms (Custodians)
With the anticipated increase in assets under management, Pawol Capital LLC will select Bank of
America Merrill Lynch to act as our hedge fund's prime brokerage and securities clearing company.
Bank of America Merrill Lynch delivers global coverage and access to 70 exchanges around the world
as well as timely market transactions. They provide all types of securities including equities (stocks),
fixed income (bonds) and derivatives (options).
Our Recommendations of Brokerage Firms
We generally advise clients to use a reputable online brokerage, although we do not recommend any
specific brokerage firms. Less reputable firm may allow us less access to securities than others.
Soft Dollar Arrangements
Pawol Capital LLC, by policy, does NOT accept any soft dollar arrangements.
Aggregation of Client Trades
We combine the trades of its clients only for clients of our hedge funds. All other clients do not have
combined trades.
Relationships with Investment Product Providers
Since we create our own investment products rather than purchase products from investment
companies, we do not have any relations with any other investment product providers.
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15. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 13: Review of Accounts
Periodic Portfolio Reviews
Pawol Capital LLC makes periodic reviews of all client accounts. This is to ensure that all client
accounts are on track toward their objectives. After review, the reviewer may or may not take
corrective measures to put the client's account back on track toward their objective.
Additional Portfolio Reviews are undertaken upon request by the client if a special need or change of
objective occurs.
Account Reviewer
Joshua Ryan Powell is the account reviewer.
Portfolio Reports Provided to Clients
Quarterly reports are provided to all clients of our hedge funds. The reports detail transactions within
the last quarter, fund performance and economic outlook. Such reports may also include additional
information such as the client's account balance, goals and objectives status, gains and loss report and
current portfolio.
Clients are strongly encouraged to read the report that they receive from us and contact us if there is
any conflicts with their investment needs.
Pawol Capital LLC
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16. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 14: Client Referrals and Other Compensation
• We do NOT accept any type of compensation from any person for a client referral.
• We do NOT refer any of our clients to any other service provider for a fee.
Item 15: Custody
Pawol Capital LLC, generally, has custody of client's funds or accounts for all hedge fund products. In
other words, the firm may put a client's funds in their own account and transact, withdraw and have
general control of the funds as long as it is within the best interests of the client.
Custody is evidenced by a limited power of attorney and subscription agreement which are signed by
the client seeking to allow custody of their funds.
Item 16: Investment Discretion
Pawol Capital LLC may have discretion over client's accounts. Discretion is only taken after consent is
received from the client. Discretion is evidenced by a subscription agreement and a limited power of
attorney agreement signed by the client seeking to allow discretion. In other words, the client is giving
the firm authorization to make transactions in their account at the discretion of the firm. Generally,
this authorization of discretion over a client's funds allows the firm to make transaction without prior
notice to the client.
Item 17: Voting Client Securities
By matter of firm policy and practice, when securities are under firm discretion, does not accept
authority to vote proxies on behalf of clients. Clients retain the responsibility for receiving and voting
proxies for any and all securities in the client portfolios. Generally, clients may call or e-mail their
adviser with questions regarding a particular proxy and solicitation, and Pawol Capital LLC may provide
advice to the clients regarding the voting of proxies or such solicitations.
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17. Form ADV Part 2A (“Firm Brochure”)
for Pawol Capital LLC
Item 18: Financial Information
Under no circumstances do we require a pre-payment of any amount per client more than 6 months
in advance of services rendered.
As explained in Item 15 and 16, Pawol Capital LLC accepts custody and discretion of a client's funds.
Due to this acceptance, the firm is required to disclose any financial condition that is reasonably likely
to impair it's ability to meet contractual commitments to clients.
Current financial conditions that may impair the firm's ability to meet contractual commitments
There are no conditions that may impair it's ability to meet contractual commitments.
Pawol Capital LLC has never been the subject of a bankruptcy proceeding.
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