Ponder Investment Co

Ponder Investment Co. is a registered investment adviser under the U.S. Investment Advisers Act of 1940, providing investment supervisory services since 1986. The firm offers discretionary and non-discretionary investment advisory services, specializing in short and long-term debt instruments. Clients' assets under management total $1,270,570,413 as of December 31, 2022. Fees are generally charged based on a percentage of assets under management and are negotiable. Clients may incur custodian fees, brokerage charges, and other transaction expenses. Ponder Investment Co. does not charge performance-based fees and manages accounts in the best interest of each client. The firm serves institutional clients such as state and local entities, hospitals, and educational institutions. Investment strategies include fundamental, technical, and cyclical analysis, with a focus on long-term and short-term securities trading. Clients should be prepared for risks such as interest rate, spread, prepayment, credit, and liquidity risks. The firm does not receive compensation for selling securities and allows clients to purchase through unaffiliated broker-dealers. Ponder Investment Co. exercises investment discretion, reviews accounts regularly, and votes on behalf of clients in corporate governance matters. The firm's personnel adhere to a strict Code of Ethics and do not engage in investment-related businesses that may create conflicts of interest. No disciplinary events have occurred in the last 10 years, and supervised persons are compensated based on the firm's performance, without receiving commissions or bonuses for selling securities.