Stellar Assets L.L.C.

Stellar Assets is a small independent advisory firm that provides ongoing discretionary portfolio management primarily to individual clients, including accredited and qualified investors. The firm focuses on managing a portion of a client’s investible assets and does not ordinarily provide comprehensive financial planning or a holistic asset-allocation plan for assets outside its managed accounts.

The firm’s investment process combines charting, fundamental, quantitative and technical analysis and employs both long- and short-term trading strategies. Stellar Assets specializes in publicly traded equities and exchange-traded equity options, may use options for exposure, hedging or income generation, and generally documents client objectives through advisory agreements and questionnaires rather than individualized investment policy statements.

Distinctive features disclosed in the brochure include the firm’s documented use of derivatives in separately managed accounts and the availability of performance-based fee arrangements for qualified clients, with the brochure describing the related performance calculation practices and conflicts of interest. The firm notes that performance arrangements are typically associated with option-intensive strategies and cautions clients about the higher volatility of such accounts; it also describes an alternative management-fee approach for clients who want option strategies but do not qualify for performance-based arrangements.