LEGAL DISCLOSURES

Lyons Investment Management, Inc. is registered as an investment adviser with the SEC and only transacts business in states where it is properly registered, or is excluded or exempted from registration requirements. SEC registration does not constitute an endorsement of the firm by the Commission nor does it indicate that the adviser has attained a particular level of skill or ability.

This website is a publication of Lyons Investment Management, Inc. Information presented is believed to be factual and up-to-date, but we do not guarantee its accuracy and it should not be regarded as a complete analysis of the subjects discussed. All expressions of opinion reflect the judgment of the authors as of the date of publication and are subject to change.

Information on this website does not involve the rendering of personalized investment advice. Always consult an attorney or tax professional regarding your specific legal or tax situation. None of the content should be construed as being an offer to buy or sell, or a solicitation of any offer to buy or sell the securities mentioned herein.

Past performance may not be indicative of future results. Therefore, no current or prospective client should assume that the future performance of any specific investment or investment strategy will be profitable or equal to past performance levels.

All investment strategies have the potential for profit or loss. Changes in investment strategies, contributions or withdrawals, and economic conditions may materially alter the results of your portfolio.

Different types of investments involve varying degrees of risk, and there can be no assurance that any specific investment will either be suitable or profitable for a client’s investment portfolio. There are no assurances that a portfolio will match or outperform any particular benchmark. The indices shown are not the only indices that can be used as a benchmark for measuring the performance of a portfolio. Depending upon the holdings in your portfolio, your investment objectives, and your risk temperament, it may be more appropriate to measure performance against a different benchmark.

Lyons Investment Management, Inc. uses certain proprietary databases and formulas, “devices,” in its investment decision process. Such “devices” have limitations and difficulties with respect to their use. The use of these devices does not change the possibility of loss inherent in all investment decisions.

Performance returns are presented gross-of-fees and net-of-fees and reflect the reinvestment of dividends and capital gains. Historical performance results for investment indexes and/or categories, generally do not reflect the deduction of transaction and/or custodial charges or the deduction of an investment-management fee, the incurrence of which would have the effect of decreasing historical performance results.

Third-party rankings and recognition from rating services or publications are no guarantee of future investment success. Working with a highly-rated adviser does not ensure that a client or prospective client will experience a higher level of performance or results. Generally, ratings, rankings and recognition are based on information prepared and submitted by the adviser. A more thorough disclosure of the criteria used in making these rankings is available upon written request.

Hyperlinks on this website are provided as a convenience. We disclaim any responsibility for information, services or products found on websites linked hereto.

PRIVACY POLICY NOTICE

Revised: April 6, 2020

Lyons Investment Management has adopted this privacy policy with recognition that protecting the
privacy and security of the personal information we obtain about our customers is an important
responsibility. We also know that you expect us to service you in an accurate and efficient manner. To
do so, we must collect and maintain certain personal information about you. We want you to know
what information we collect and how we use and safeguard that information.

INFORMATION WE COLLECT
We collect certain nonpublic information about you (“Customer Information”). The essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer Information we collect may include:

Information that you provide on applications or other forms. This Customer Information may include personal and household information such as income, spending habits, investment objectives, financial goals, statements of account, and other records concerning your financial condition and assets, together with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
Identifying information such as your name, age, address, social security number, etc.
Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other chosen investment sponsors).
Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various materials we may use to provide an appropriate recommendation or to fill a service request.


SECURITY OF YOUR INFORMATION

We restrict access to your nonpublic personal information to those employees who need to know that information to service your account. We maintain physical, electronic and procedural safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.

INFORMATION WE DISCLOSE
As required or permitted by law, we disclose the nonpublic personal information we collect about our customers: (i) to persons necessary to effect the transactions and provide the services that our customers authorize, such as broker-dealers, custodians, independent managers etc.; (ii) to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided by law. We are permitted by law to disclose the nonpublic personal information about you to governmental agencies and other third parties in certain circumstances (such as third parties that perform administrative or marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or share the information for any other purpose.

INFORMATION WE DISCLOSE TO AFFILIATED THIRD PARTIES
We are affiliated with Lyons Wealth Management, LLC, a registered investment adviser. We will share information related to your personal information, account holdings, and any additional information needed to assist with the management of your portfolio(s).

FORMER CLIENTS
If you decide to close your account(s) or become an inactive customer, we will adhere to our privacy policies, which may be amended from time to time.

CHANGES TO OUR PRIVACY POLICY
In the event there were to be a material change to our privacy policy regarding how we use your confidential information, we will provide written notice to you. Where applicable, you would be given an opportunity to limit or opt-out of such disclosure arrangements.

QUESTIONS
If you have questions about this privacy notice or about the privacy of your customer information call our main number 386-775-1177 and ask to speak to the Chief Compliance Officer. Alternatively, you can send us an email at info@lyonsinvest.com or fill out the form on our contact page.

FORM CRS

Great Northern Asset Management, Inc.
d/b/a: Lyons Investment Management
June 19, 2020

Lyons Investment Management is registered with the Securities and Exchange Commission as an investment adviser and, as such, we provide advisory services rather than brokerage services. Brokerage and investment advisory services and fees differ and it is important for you, our client, to understand the differences. Additionally, free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which also provides educational materials about broker-dealers, investment advisers, and investing. This document is a summary of the services and fees we offer to “retail” investors, which are natural persons who seek or receive services primarily for personal, family, or household purposes.

What investment services and advice can you provide me?
We offer the following investment advisory services to retail investors: Portfolio Management Services and Portfolio Manager to a Wrap Fee Programs. Detailed information regarding our services, fees and other disclosures can be found in our Form ADV Part 2A Brochure clicking this link https://adviserinfo.sec.gov/firm/brochure/166788. Refer to Items 4, 7, 8, 13 and 16.

Account Monitoring: If you open an investment account with our firm, as part of our standard service we will monitor your investments on an ongoing basis.

Investment Authority: We manage investment accounts on a discretionary basis whereby we will decide which investments to buy or sell for your account. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.

Investment Offerings: We offer advice on the following types of investments or products: domestic and foreign, equity securities, warrants, money market funds, exchange traded funds and foreign currencies.

Account Minimums and Requirements: In general, we require a minimum account size based on the investment strategy selected, to open and maintain an advisory account, which may be waived at our discretion.

Key Questions to Ask Your Financial Professional

How will you choose investments to recommend to me?
What is your relevant experience, including your licenses, education and other qualifications?
What do these qualifications mean?
Given my financial situation, should I choose an investment advisory service? Why or Why Not?

What fees will I pay?
The following summarizes the principal fees and costs associated with engaging our firm for investment advisory services. For detailed information, refer to our Form ADV Part 2A, Items 5 and 6, by clicking this link https://adviserinfo.sec.gov/firm/brochure/166788.

Asset Based Fees – Payable quarterly in advance based the total account asset value on the last trading day of each calendar quarter. Since the fees we receive are asset-based (i.e. based on the value of your account), we have an incentive to increase your account value which creates a conflict especially for those accounts holding illiquid or hard-to-value assets;
Performance-based Fees – Payable annually in arrears, if applicable. Performance-based fees create an incentive for our firm to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. Since we manage both accounts that charge a performance-based fee and accounts that are charged another type of fee, we have an incentive to favor accounts for which we receive a performance-based fee;

Clients may also pay additional fees and/or expenses. Examples of the most common fees and costs applicable to our clients are:

Custodian fees;
Account maintenance fees;
Fees related to mutual funds and exchange-traded funds;
Transaction charges when purchasing or selling securities; and
Other product-level fees associated with your investments.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Key Questions to Ask Your Financial Professional

Help me understand how these fees and costs might affect my investments. If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me?

What are your legal obligations to me when acting as my investment adviser? How else does your firm make money and what conflicts of interest do you have?
When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means.

Revenue Sharing: We have a revenue sharing arrangement with Morgan Stanley Wealth Management (“Morgan Stanley”), as we are a portfolio manager to a wrap fee program sponsored and administered by Morgan Stanley. We receive a portion of the advisory fees for accounts we manage through Morgan Stanley’s Wrap Fee Program. Revenue sharing arrangements present certain conflicts of interest due to the fact that we may be incentivized to recommend Morgan Stanley’s Wrap Fee Program.

Refer to our Form ADV Part 2A, Item 5, 10, 12 and 14, by clicking this link https://adviserinfo.sec.gov/firm/brochure/166788 to help you understand what conflicts exist.

Key Questions to Ask Your Financial Professional

How might your conflicts of interest affect me, and how will you address them?

How do your financial professionals make money?
The financial professionals servicing your account(s) are compensated through the following ways: salary, bonus or via a percentage of the revenue the firm earns from the financial professional’s advisory services or recommendations. Financial professionals’ compensation is based on the overall revenue of the firm and the individual’s contribution to the firm’s success. The bonus compensation paid to our financial professionals involves a conflict of interest because they have a financial incentive to refer clients to our firm.

Do you or your financial professionals have legal or disciplinary history?
No, our firm and our financial professionals currently do not have any legal or disciplinary history to disclose. Visit Investor.gov/CRS for a free and simple research tool.

Key Questions to Ask Your Financial Professional

As a financial professional, do you have any disciplinary history? For what type of conduct?

You can find additional information about your investment advisory services and request a copy of the relationship summary at 386-775-1177 or click the link provided https://adviserinfo.sec.gov/firm/brochure/166788.

Key Questions to Ask Your Financial Professional

Who is my primary contact person?
Is he or she a representative of an investment adviser or a broker-dealer?
Who can I talk to if I have concerns about how this person is treating me?

~Click HERE to download a pdf of this CRS Form.~