Changing Parameters, LLC

Changing Parameters, LLC is a registered investment adviser based in Los Altos, California, established in July 2004 by Howard P. Smith. The firm offers investment management services to registered investment companies and provides investment advisory tactical allocation services to separate account clients on a discretionary basis. Clients typically include individuals, investment companies, pensions, trusts, estates, charitable organizations, and corporations, with a minimum asset requirement of $500,000 for separate accounts. Changing Parameters, LLC charges advisory fees based on a percentage of assets under management, with a cap of 2.50% per annum. The firm does not participate in wrap fee programs and does not provide performance-based fees. Investment strategies involve price trend analysis methods for securities investments, with a focus on bond, equity, and money market mutual funds. The firm exercises investment discretion for clients, making decisions on securities, amounts, brokers, and commission rates. Changing Parameters, LLC does not vote proxies for separate account clients but does so for the Fund it manages. The firm maintains custody of client funds and securities with a qualified custodian and does not have any disciplinary information or bankruptcy history.