Conflict-of-Interest Statement

I, Stephen (Steve) Deutsch of Institutional Investing Enhancement LLC (IIE), am an investment consultant and I am committed to providing my institutional clients with the best possible advice and service as a fiduciary which means to always act in the best interests of its institutional clients.
I understand that there are potential conflicts of interest that could arise in my role as an investment consultant and I am committed to disclosing and managing these conflicts in a transparent and ethical manner.

Unlike other investment consultants with direct or indirect affiliations, Stephen Deutsch/IIE:

    • does not earn commissions or any compensation from investment companies for recommending their products, I am fee-only;
    • does not provide research and educational services to investment managers nor receive compensation from them for those services;
    • is not affiliated with a broker-dealer or have a relationship with an unaffiliated broker-dealer or any financial institution;
    • does not manage or custody assets under management;
    • does not trade or sell securities or products or provide trade instructions to any broker or financial institution;
    • does not engage in principal transactions;
    • does not buy or sell a security that is being purchased, sold, or considered for client accounts;
    • does not vote shares on institutional clients’ behalf;
    • does not accept gifts, gratuities, entertainment, etc. other than covering expenses for speaking at a conference or meeting following the invitation of a professional association of which he is a member;
    • does not recommend to clients or buy or sell for clients’ accounts investments in which the owner/Founder/Consultant or related persons has a material financial interest, as the firm does not conduct these activities;
    • is not an investor and/or partner/member in private investment partnerships, limited liability
      companies or corporations that invest in securities or private equity opportunities;
    • does not engage in the business of or receive compensation for finding potential investors or limited partners, raising capital for private funds, or receiving “finders fees.”
    • does not act as an advisor, sponsor or placement agent for these private investment partnerships, limited liability companies or corporations;
    • does not serve on third-party advisory boards;
    • does not provide private wealth management services to anyone, including Board and Investment Committee members of prospects and clients;
    • does not receive a fee from an investment adviser for client referrals and does not compensate solicitors or pay for client referrals;
    • does not make contributions to
          • (i) to candidates running for U.S. state or local political office,
          • (ii) to candidates running for U.S. federal office who currently hold a U.S. state or local political office, or
                (iii) to political parties or PACs that may contribute to such campaigns (collectively, a “Political Contribution”);
    • does not make Political Contributions or otherwise endorse or support political parties or candidates (including through intermediary organizations such as PACs or campaign funds) with the intent of directly or indirectly influencing any investment management relationship;
    • does not engage in any of the foregoing activities indirectly, such as by funneling payments through third parties including, for example, attorneys, family members, friends/companies affiliated with IIE. 

Steve Deutsch of Institutional Investing Enhancement LLC will disclose in writing to the institutional client:

  • Any interest the firm or Steve Deutsch may have in the consideration of selecting, monitoring, and replacing investment options/investment managers/service providers to the institutional plan(s).
  • Personal securities transactions for Steve Deutsch and whether the transactions are similar or inconsistent with investment consultation advice given to clients.
  • Any financial and disciplinary events.
  • Any financial/investment-related business affiliations that IIE has entered.

I am committed to providing my institutional clients with the best possible advice and service, and I believe that disclosing and managing conflicts of interest is an important part of that commitment. 

Since it may materially affect an institutional client’s decision to conduct business with IIE, I will disclose all known potential conflicts of interest to my institutional clients in writing before I provide any advice or service. I will also take steps to manage these conflicts in a way that protects my clients’ interests. For example, I may recuse myself from providing advice or service if I have a conflict of interest.

If you have any questions about this conflict-of-interest statement or other conflict-of-interest concerns, please do not hesitate to contact me.

My policy for conflicts is a dynamic document that can be updated as I learn about the conflicts that I face and how they can best be managed. 

June 2023