Other business activities
Outside business activity is any business or activity undertaken by an advisor that is outside the scope of their relationship with their firm (e.g., consulting services, real estate, freelance work, teaching, etc.). Investors should stay informed about these activities to ensure no conflicts of interest.
1) Kevin Edward Sullivan is a licensed insurance agent. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client's needs. Additionally, the offer and sale of insurance products by supervised persons of Naples Asset Management Co., LLC are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. Naples Asset Management Co., LLC (NAMCOA) addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. Periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client's risk profile and investment objectives rather than on the receipt of any commissions or other benefits. Naples Asset Management Co., LLC will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by NAMCOA's supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. 2. Chaotic Holdings, Real Estate, Adviser owns commercial property, and receives rental income, less than 1 hour a month spent outside of trading hours. 3. RIA Sources, adviser's wholesale organization which also acts as a management company for tax purposed and personal investments in a SEP, less than 1 hour a month spent outside of trading hours. 4. Marion West Stables, landowner and ownership of horses, no income at this time. Less than 1 hour a month spent outside of trading hours. 5.Wicked Holdings, LLC, adviser, and family holds property at 107 Kilson Drive, Mooresville, NC 28117. within this LLC. Rental income from this entity, less than 1 hour spent per month outside of trading hours. Located at 107 Kilson Drive, Mooresville, NC 28117. 5. Hair Trigger Arms, LLC, adviser, and family hold personal property under this entity, less than 1 hour spent per month outside of trading hours. Peritus, LLC , currently inactive entity, may be used for real estate property ownership. No hours spent per month. 6. Member: Naples Private Capital LLC: �Investment Related. �Location 107 Kilson Drive, Ste 206; Mooresville, NC, 28117. �Description of the business: This LLC was set up to own 50% of NAMCOA. This entity to owned 51% by Robin Whitlock and 49% by Kevin Sullivan. 1 hour per month.