Minneapolis Portfolio Management Group, LLC

Minneapolis Portfolio Management Group, LLC (MPMG) is a value-based investment management firm founded in 2004 by Harrison T. Grodnick and Phillip W. Grodnick, specializing in designing investment portfolios consisting of equity securities. MPMG's investment strategy, the "All-Cap Value" strategy, focuses on small-, mid-, and large-cap companies domestically and abroad. The firm may also include fixed income instruments in portfolios and manages accounts on a discretionary basis, with limited non-discretionary management. Clients have the right to place limitations on their portfolios. MPMG acts as a fiduciary for retirement plan and individual retirement accounts, ensuring client interests are prioritized. The firm charges investment advisory fees based on a percentage of assets under management, with fees payable quarterly. MPMG generally recommends Charles Schwab & Co. as a custodial broker-dealer for client accounts. The firm does not charge performance-based fees, and employees may receive compensation for new business referrals. MPMG has a Proxy Voting Policy for voting client securities and does not engage in cross trades or principal transactions. Clients receive regular account reports and have the option to direct proxy votes. MPMG has no material changes to its brochure since March 2024 and has not been subject to disciplinary events. The firm's financial information indicates no impairments in meeting client commitments.