Vineyard Capital Management LLC

The firm provides ongoing portfolio management and investment advice to individual and high-net-worth clients, preparing a tailored Investment Policy Statement for each client that addresses goals, tax considerations, time horizon, and risk tolerance. It generally concentrates on equity investments and charges asset-based advisory fees, with no stated account minimum.

The firm operates primarily on a non‑discretionary basis — it does not place trades or exercise investment discretion for client accounts, and essentially all reported assets are managed under non‑discretionary arrangements, a model that is uncommon among independent advisers. Investment recommendations are grounded in a mix of charting, fundamental and technical analysis with a long‑term trading orientation, and accounts are reviewed at least monthly.

Distinctive operational features include a firm requirement that clients custody assets at Morgan Stanley, a policy of not participating in wrap fee programs, and an approach that declines proxy‑voting authority so clients receive and vote proxies directly. The brochure also discloses that representatives may receive outside sales compensation (which the firm documents when it occurs) and that fees are collected in advance, reflecting a recommendation‑focused, non‑executory advisory model rather than discretionary trade execution.