Intelligent Portfolio Design 

Advisor Registration

Item 1 – Cover Page
Fleet Capital Management, LLC
26 Sunflower Cir
Bellingham, WA 98229 360.389.6407

Last update March 16, 2019

This Brochure provides information about the qualifications and business practices of Fleet Capital Management, LLC. If you have any questions about the contents of this Brochure, please contact us at 360-389-6407. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.

Fleet Capital Management, LLC (FCM) is a Registered Investment Advisor (crd#138836). Bruce Fleet (crd # 01529233) is an investment adviser representative of FCM. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser.

Additional information about Bruce Fleet also is available on the SEC’s website at

Item 2 – Material Changes

On July 28, 2010, the United State Securities and Exchange Commission published “Amendments to Form ADV” which amends the disclosure document that we provide to clients as required by SEC Rules. This Brochure dated Mar. 16, 2019 is a new document prepared according to the SEC’s new requirements and rules. As such, this Document is materially

different in structure and requires certain new information that our previous brochure did not require.

The material change for this annual ADV 2 is that Bruce Fleet has opened a second investment management firm called Fleet Futures Trading Advisory, LLC. This new firm will concentrate on trading futures on the S&P 500 as well as the Nasdaq. Bruce does not anticipate any conflict between his two firms or any diminishment of his available time commitment to either firm. The vast majority of research done on behalf of FCM is completed after market hours and futures is completed during market hours.

In the past, we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC Rules, we will ensure that you receive a summary of any materials changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. We may further provide other ongoing disclosure information about material changes as necessary.

We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge.

Currently, our Brochure may be requested by contacting Bruce Fleet, President at 360-389- 6407 or Our Brochure is also available on our web site also free of charge.

Additional information about Bruce Fleet is also available via the SEC’s web site The SEC’s web site also provides information about any persons affiliated with Fleet Capital Management who are registered, or are required to be registered, as investment adviser representatives of Fleet Capital Management.

Item 3 -Table of Contents

Item 1 – Cover Page
Item 2 - Material Changes
Item 3 - Table of Contents
Item 4 – Advisory Business
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics
Item 12 – Brokerage Practices Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Item 19 – Requirements for State-Registered Advisers
Brochure Supplement(s)

Item 4 – Advisory Business

Fleet Capital Management, LLC (FCM) is a fee-only investment advisory firm. FCM is owned in its entirety by Bruce Fleet, who opened the firm in December 2005. Bruce Fleet has been a professional in the investment management industry since May 1986. FCM was first registered with Colorado in July 2008 and Washington State in September 2010. FCM was also registered with the Securities and Exchange Commission in January 2006.

FCM provides investment advisory services with an emphasis on the risk management, thus our primary concern is with downside protection rather than the maximization of returns. This risk management practice is implemented utilizing technical analysis. The firm also uses multiple technology platforms to assist with this work, including but not limited to, Investor’s Business Daily, TD Ameritrade Institutional and Zacks Investment Research.

As of Mar. 16th, 2019 FCM manages sisteen million, six hundred twenty-eight thousand dollars ($16,228,259) of discretionary client assets. Clients may choose to have their portfolios held at the custodian of their choice, yet the preferred and default custodian for FCM is TD Ameritrade Institutional.

Item 5 – Fees and Compensation

Fleet Capital Management, LLC provides Investment Policy Statement creation or review, risk assessment, cash flow analysis, and expected rate or return needs analysis prior to the creation of the investment portfolio. Fees are charged only for portfolio management.

Fleet Capital Management is compensated using a percentage fee based on the amount of total assets to be managed for a family. Fees are based on an annual basis yet charged monthly, in advance, based on the close of business value on the last business day for the prior calendar month.

The Fee is based on a percentage of the assets under management, is charged on all assets under management in a particular investment platform (i.e. LTH or RTA), and is not a graduated scale. Fleet Capital Management maintains a five hundred-thousand-dollar minimum account size. Accounts for immediate family members can be aggregated to meet this minimum

Client's Annual Management Fee for the LTH portfolio and/or the mutual fund portfolio:

$500,000 up to $1,500,000           0.75%

$1,500,001 up to $2,000,000        0.65%

$2,000,000 up to $2,500,000       0.55%

Above $2,500,000                       0.50%

Client's Annual Management Fee for the RTA account: Up to 5,000,000 1.00%

Fees are negotiable for accounts over $5,000,000. Investment management fees are charged in advance and pro-rated to the number of days remaining in the month. Should an account be terminated prior to the end of a calendar month, unearned fees will be refunded to the client. Clients can cancel the advisory agreement within five business days without penalty if the client was not furnished with Form ADV Part 2 at least 48 hours prior to signing the agreement. Clients will be responsible for the payment of all fees charged by the custodian. The adviser’s fee will be billed directly to the client’s account, and the custodian will show the paid management fee on the corresponding client statement provided by the custodian.

The specific manner in which fees are charged by FCM is established in a client’s written agreement with FCM. FCM will generally bill its fees on a monthly basis. Clients may also elect to be billed directly for fees or to authorize FCM to directly debit fees from client accounts. Management fees shall be prorated for each capital contribution and withdrawal made during the applicable calendar quarter (with the exception of de minims contributions and withdrawals). Accounts initiated or terminated during a calendar month will be charged a

prorated fee. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable.

Fleet Capital Management fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses, which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd- lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to FCM’s fee, and FCM shall not receive any portion of these commissions, fees, and costs.

Item 12 further describes the factors that FCM considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

Item 6 – Performance-Based Fees and Side-By-Side Management

Fleet Capital Management does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client).

Item 7 – Types of Clients

Fleet Capital Management provides portfolio management services to individuals, high net worth individuals, charitable institutions, foundations, and trust accounts. As of March 16, 2019, one hundred percent of FCM managed accounts are of High Net Worth families, including their personal trust accounts. FCM maintains a minimum $500,000 account or family aggregate.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

“Investing in securities involves risk of loss that clients should be prepared to bear.” Due to liquidity, transparency and diversification, Fleet Capital Management uses mutual funds, ETF’s and stocks as primary investment vehicles. FCM uses technology to screen thousands of

investment choices.

One of the technology components used by FCM is Investor’s Business Daily; a subscription program designed for investment professionals. FCM uses proprietary technical analysis to filter all stock and ETF fund offerings available to investors in the United States, ranked by numerous technical and fundamental indicators”.

We then narrow the field utilizing addition technical analysis including but not limited to convergence/divergence indicators, on balance volume, RSI and Japanese candle technology.

Once the firm's current investment selection is made and based on market trend analysis, the actual investments chosen for a particular portfolio are based on the portfolio stated risk tolerance, investment time horizon as well as appropriate allocation to taxable vs. tax-deferred accounts.

FCM offers three primary account management styles. The first is called LTH or Long Term Holdings. This account will primarily utilize mutual funds and ETF’s as their investment vehicles. Sector rotations along with market trend analysis are the principal decisions made which may cause changes to the investment selections. Assets for this strategy may be segregated to a separate account for billing and performance measurement. All trading will be completed on a discretionary basis.

The second option is our Long Term High-Quality Mutual Fund Portfolio.

The third option, called RTA or Risk-managed Trading Account, is a Highly Sophisticated Technical Analysis Platform Combined With Multi-Level Risk Management and Fundamental Analysis.

After extensive research, FCM has designed a multi-platform trading system, which will include multiple separate trading platforms, each utilizing its own particular technical trading techniques, as well as multiple sources of investment lists.

This multi-platform system allows for a portion of the investors trading portfolio to be managed in each of the systems contained within this program, thus reducing strategy risk. Each trading platform may be changed for another system based on trading efficiency at the discretion of FCM.

Each trading strategy will employ multiple risk management techniques with the intent of reducing the risks associated with stock trading to a highly rules-based structure. Trading stocks and other securities is inherently risky. FCM will use numerous resources and techniques in order to help minimize these associated risks.

This program may trade stocks, ETF’s, and options, as well as other financial instruments, both in long and short positions based on FCM’s sole discretion. All trading will be completed on a discretionary basis as timing is of the essence in this type of rules-based trading program. FCM will offer quarterly account reviews to discuss all aspects of the program specific to each client, including performance reporting, risk analysis, and strategy efficiency.

The minimum account size for RTA is currently $250,000, as long as the five hundred thousand dollar minimum family account aggregate has been met, for this trading platform (subject to change to new clients with written notice). The management fee for this program will be a flat one percent of assets charged to the account on a monthly basis in advance. (.02/12=.00167 monthly) This management fee will be separate from, and not in addition to, the management fee charged to FCM assets held outside of this platform. Assets for this strategy may be segregated to a separate account for billing and performance measurement.

I/We may authorize FCM to allocate a portion of our investable assets to either or both of these trading strategies, as well as discontinue their use in writing via e-mail. There is no fixed contractual time period in which a client must remain within these two strategies. I/We understand that every effort will be made by FCM to provide added value within these two advisory services yet no guarantee has been expressed or implied.

Item 9 – Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Fleet Capital Management or the integrity of Bruce Fleet’s management.

While employed at UBS Financial Services, both Bruce Fleet and UBS were named in a client-initiated arbitration which resulted shortly after the major market decline and bear market of 2000. In the arbitration, the client asked for three million dollars in damages, yet the arbitration panel awarded the client, one-tenth of the amount requested. Bruce Fleet was not asked by UBS to participate in the award to the client.

The NASD (now known as FINRA) did impose a suspension of fifteen business days and a five thousand fine.

Due to extenuating circumstances, the legal counsel recommended that Mr Fleet counter sue the client for defamation of character. While the settlement to this is confidential, Mr Fleet was pleased with the outcome.

Item 10 – Other Financial Industry Activities and Affiliations

Bruce Fleet is an internationally published author. Published Books include Demystifying Wall Street and The Solomon Secret. Bruce Fleet spends no time marketing and promoting the books, as the publisher generally does this. It is not expected that this business will negatively impact the investment management business, which will always take the priority position of Bruce’s time.

Bruce is also the president of Fleet Futures Trading Advisory, LLC. Given that the two firms trade completely diffident types of securities, and the fact that much of the futures trading is automated, while much of the FCM investment research is done after market hours, Bruce does not anticipate any extra demands on his time.

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Fleet Capital Management has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of

Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumormongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at FCM must acknowledge the terms of the Code of Ethics annually, or as amended.

Fleet Capital Management anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which FCM has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which FCM, its affiliates and/or clients, directly or indirectly, have a position of interest. FCM’s employees and persons associated with FCM are required to follow FCM’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of FCM and its affiliates may trade for their own accounts in securities, which are recommended to and/or purchased for FCM’s clients. The Code of Ethics is designed to assure that the personal securities transactions; activities and interests of the employees of FCM will not interfere with (i) making decisions

in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of FCM’s clients. In addition, the Code requires pre-clearance of many transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between FCM and its clients.

Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with FCM's obligation of best execution. In such circumstances, the affiliated and client accounts will share commission costs equally and receive securities at a total average price. FCM will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.

Fleet Capital Management’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Bruce Fleet.

It is FCM’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. FCM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer.

Item 12 – Brokerage Practices

Fleet Capital Management does not participate in any account or programs that provide soft dollar benefits to our firm. All of the research and technology used by FCM is paid for on a subscription basis. In addition, FCM receives absolutely no benefit from any investment product or manager, thus we feel certain we have eliminated any conflict of interest this may otherwise cause.

Most of FCM’s client assets are held custody at TD Ameritrade Institutional. Clients may choose to have their investment assets held at the custodian of their choosing. FCM utilizes TD Ameritrade Institutional to execute investment trades on behalf of our clients who choose to have TD Ameritrade Institutional custody their investment assets. FCM is not bound to TD Ameritrade Institutional and thus feels there is no conflict of interest.

On occasion, due to FCM’s use of the most cost-effective ways for our clients to invest in certain investment products, a minimal transaction fee may be associated with an investment transaction. This fee is charged by the custodian and in no way benefits FCM.

Item 13 – Review of Accounts

Fleet Capital Management, LLC performs a daily review and data update of all investments held in client accounts. Clients of FCM have daily access to online information concerning their accounts through TD Ameritrade technology.

Clients receive monthly account statements from the custodian.

FCM provides each client with a detailed review of all investments in their accounts, as well as market conditions and economic outlooks. These regular reviews may be completed in person but mostly utilize video conferencing technologies.

Clients also have daily access to Blueleaf technology which is a Web Portal. FCM places research into the client password protected web portal on a regular basis. All documents are then filed into an electronic filing system, which allows clients to access these reports at any time. Filed reports are never deleted. Client review reports and monthly fee invoices are also filed in this system.

Item 14 – Client Referrals and Other Compensation

Fleet Capital Management, LLC does not provide economic benefit to any non-client who may provide a referral to our firm. Likewise, FCM receives no economic benefit from any professional to whom we may refer a client.

Item 15 – Custody

Clients should receive at least quarterly statements from the broker-dealer, bank or another qualified custodian that holds and maintains client’s investment assets. FCM urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities.

In no circumstance is FCM authorized to transfer funds or securities out of the Client's Account(s) except if the Client gives Investment Advisor specific authorization to debit Investment Advisor's fees from Client's Account. Investment Advisor sends a copy of the Client's invoice to

the Custodian of the Client's Account. Clients receive an electronic permanent copy of the quarterly fee calculation and accounting. At least quarterly, the Client will receive statements from the Custodian of the Client's Account and such statement will reflect the amount of the advisory fees if the Client authorizes the Custodian to debit the advisory fees from the Client's Account.

Item 16 – Investment Discretion

Fleet Capital Management, LLC usually receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. Clients must first agree to and sign for this authority as part of the new account opening process. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account.

When selecting securities and determining amounts, FCM observes the investment policies, limitations and restrictions of the clients for which it advises. For registered investment companies, FCM’s authority to trade securities may also be limited by certain federal securities and tax laws that require diversification of investments and favour the holding of investments once made.

Investment guidelines and restrictions must be provided to FCM in writing.

Item 17 – Voting Client Securities

As a matter of firm policy and practice, FCM does not have any authority to and does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. FCM may provide advice to clients regarding the clients’ voting of proxies.

Item 18 – Financial Information

Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about FCM’s financial condition. FCM has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.

Item 19 – Requirements for State-Registered Advisers

Bruce Fleet received his CFP Certified Financial Planner designation from the College for Financial Planning in 1989. He received the Certified Investment Management Analyst designation in 2003 and the Investment Strategist Certificate in 2004, both from The Wharton School at the University of Pennsylvania via the Investment Management Consultants Association. Mr. Fleet no longer participates in the continuing education programs of these certifying organizations, thus does not present these as current affiliations.

Bruce Fleet, born June 20, 1960, has been in the investment advisory business since May of 1986. Included in his Wall Street career, Bruce was a national trainer for Merrill Lynch for five years from 1990-1995 and was a Senior Vice President of Investments and Chairmen’s Club member at UBS Financial Services.