Comus Investment, LLC

Comus Investment provides discretionary equity portfolio management to individual and institutional clients, and also acts as a sub-advisor to other investment firms under separate arrangements. The firm focuses solely on direct stock investing and does not offer general financial or retirement planning, options, shorting, margin, or wrap-fee programs.

The firm follows an international, deep-value investment approach that concentrates in small-cap and microcap companies in developed foreign markets; portfolios are typically concentrated, fully invested, and managed without leverage. Investment decisions emphasize the relation between price and prospective cash flows with an explicit expectation of mean-reversion in out-of-favor companies, and the portfolio manager generally holds much of his personal capital in the same holdings as clients.

Noteworthy differences from many peers include the availability of performance-based fee arrangements for qualified or institutional clients and a substantial sub-advisory relationship in which approximately $4.5 million is managed under a performance-fee agreement and not listed on the firm’s ADV. The firm also explicitly directs clients seeking low-cost index funds or fixed income investments to other providers and expects clients to maintain diversification outside the accounts it manages.