Eric Kuby’s Stock Picks: JOUT, BBW

TDAmeritrade Network  Market On Close 

April 13, 2021

TDAmeritrade Network Link

As of 4.13.2021 Johnson Outdoors (JOUT) is a 5.16% holding in the North Star Micro Cap Fund and Build-A-Bear (BBW) is a 1.30% holding in the North Star Micro Cap Fund.

North Star Micro Cap Fund Investment Objective: The primary investment objective of the North Star Micro Cap Fund is capital appreciation and, secondarily, to derive income from short term liquid securities.

Important Risk Information:

Mutual funds have investment risks including loss of principal. There is no guarantee either fund will meet its objective. In general, the price of a fixed income security falls when interest rates rise. There is a risk that issuers and counterparties will not make payments on securities and other investments held by the Fund, resulting in losses to the Fund. The Fund may invest in high yield securities, also known as “junk bonds”. High yield securities provide greater income and opportunity for gain but entail greater risk of loss of principal. Foreign common stocks and currency strategies will subject the Fund to currency trading risks that include market risk, credit risk and country risk. Municipal securities are subject to credit risk where a municipal security might not make interest and principal payments as they come due. The Advisor follows an investing style that favors value investments. At times when the value investing style is out of favor, the Fund may underperform other funds that use different investing styles. Investments in lesser known, small and medium capitalization companies may be more vulnerable than larger, more established organizations. As with any investment, there are risks associated with REITs. Investments in lesser-known, small and medium capitalization companies may be more vulnerable than larger, more established organizations. The Advisor does not attempt to keep the portfolio structure or fund performance consistent with any market index. Increased portfolio turnover may result in higher brokerage commissions, and other transaction costs may result in taxable capital gains.

Investors should carefully consider the investment objectives, risks, charges and expenses of the North Star Funds. No-load mutual funds are sold without sales charge; however, they have ongoing expenses, such as management fees. This and other important information about each of the Funds are contained in the prospectus, which can be obtained at www.nsinvestfunds.com or by calling (855) 580-0900. The prospectus should be read carefully before investing. The North Star Funds are distributed by Northern Lights Distributors, LLC member FINRA/SIPC.

2020 IRA Contributions and Tax Filing Deadlines

April 12, 2021

IRA Contributions

This is a reminder that you still have time to make contributions to your IRA accounts for the Tax Year 2020. The deadline for contributions has recently been extended to May 17th, 2021.

If you are mailing a check for your contribution, the envelope needs to be postmarked by the May 17th for a valid 2020 contribution. Remember to mail early if you are sending a check.

For your reference the Contribution Limits are listed below.

Catch-Up Contributions

Beginning in 2020, you are allowed to make catch-up contributions for both Traditional and Roth IRAs, once you reach age 50. Typically, the catch-up amount is $1,000 above the normal contribution amount.
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Tax Filing Deadlines*

• Federal Tax filing extended until May 17, 2021.
• State tax filing: IL, MI, & WI have all extended their state deadlines for filing. 2020 taxes to May 17, 2021. Check your local state for extensions.

*Both Federal and State Tax installments are still due on 4/15/2021

North Star Update – Presidents’ Day and Tax Season

February 12, 2021

In observance of Presidents’ Day, North Star offices and all domestic stock and bond markets will be closed on Monday, February 15, 2021.

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1099 Season is officially upon us.
We expect custodians to issue all 1099 forms by the end of February.
Please let us know if you would like us to email forms to you or your tax professional when they become available.

Medicare Options 2021

November 5, 2020

Now is the time to review and consider your Medicare choices for 2021. Seniors currently enrolled in Medicare can reconsider their choices from October 15 through December 7, 2020.  This is called the Open Enrollment Period and coverage can start on January 1, 2021.

The below link directs you to an article by Sharon Egan, North Star’s Director of Financial Planning, which outlines a number of the issues surrounding these decisions.  If you or anyone you know is currently enrolled in Medicare, please take the time to read this article.

If there is anything we can do to help you with this, please let us know.

Medicare 2021

North Star is Proud to Announce the Sponsorship of the Chicago North Stars

October 26, 2020

Chicago Sun Times

North Star is proud to announce the sponsorship of the Chicago North Stars.  They are the first all women’s team to play in an adult men’s league.  Please view the article in the Chicago Sun-Times featuring one of our own — Anna Lurie.  We wish the team success in their debut season!

North Star Announces New Additions to Team

May 7, 2020

Eric Papenhagen
Harry Petruleas

We are excited to announce two new members to North Star. Eric Papenhagen and Harry Petruleas each have over 20 years of serving the financial needs of families. They will be joining the North Star Family Office, which provides a wide range of services, including:

  • Asset Allocation & Investment Oversight
  • Retirement, Tax and Insurance Planning
  • Cash Flow Analysis, Budgeting and Bill Pay
  • Estate Planning and Administration
  • Trust Administration
  • Philanthropy

The links above provide more detail about Eric and Harry.

We welcome Eric and Harry to the North Star family!

Eric Papenhagen

Eric Papenhagen

Harry Petruleas

Harry Petruleas

North Star Weekly Update 4.30.2020

NORTH STAR OFFERS FREE FINANCIAL COUNSELING TO THOSE IN NEED

We appreciate the people who support our lives right now – first responders and hospital workers, food preparers and deliverers, city workers who keep our city going, teachers conducting classes online, and the myriad of others who are on the front lines in the battle with COVID-19.

At North Star, we would like to do our part too by offering free financial counseling to those in need with one of our Certified Financial Planners.

If there is someone you know – a family member, friend, co-worker – who would like to talk to a financial professional regarding their finances, we are here to help. We can assist with changing a budget, understanding details about college loan repayment changes for 2020, creating projections, understanding the CARES Act and a wide range of additional topics.

We are offering this free counseling with the intention of finding those people who may not be typical North Star clients but have no one else to turn to. Please let us know and we will provide the contact information for one of our planners.

North Star Weekly Update 4.23.2020

While many are using this unique time to reflect and evaluate, this may be an appropriate time to review existing life insurance policies.

Whether life insurance is for personal reasons, such as:
Family or income protection
Estate planning
Wealth accumulation
…or business purposes, funding:
Buy sell agreements
Key person protection
Succession planning
Deferred compensation programs
…policies should be regularly reviewed.

As life changes, coverage should be evaluated. Depending on when a policy was issued, needs may have changed. Here are some considerations:

How long? The need for coverage may be for a longer or shorter period than expected. A policy’s premium and benefit provisions should match the need. Changes can often be made.

How much? The amount of coverage needed may also be different than current values. There are ways to increase or decrease policy benefits. There are also formulas to assist in determining the appropriate amount of protection.

Analyzing policies for cost effectiveness could yield savings

Alternate ideas. Some policies have cash values. These policies tend to have higher premiums. Some clients have successfully used existing cash values to fund a new policy that may better suit current needs, while eliminating future premiums.

No longer needed. Maybe coverage is no longer needed. There are multiple options to consider. Cash values could be used to fund other sorts of insurance, like Long Term Care or annuities, while maintaining tax benefits. There also exists the opportunity to sell an existing insurance policy. Even term policies without cash may be valuable.

What else? Some policies, based on interest rate calculations, have under-performed and will not fulfill their promises. New policies with guarantees are available, and in many cases are less costly than older plans.

New coverage. Should new coverage be needed, many carriers are underwriting without the need for an in-person exam. This is especially relevant in these times.

Changes. Finally, you may want to review policy beneficiary and ownership designations.

Please contact us if you are interested in a review of your policies or have concerns related to you, your family or your business’ need for life insurance.

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Watch out for COVID-19 scams

Scammers are trying to get your private information while Americans are most vulnerable during the coronavirus pandemic. Protect yourself and your finances by learning how to spot these scams and report the fraudsters.

We’re seeing the following scams unfolding:

• Phishing emails claiming to be sent from national or global health authorities trying to trick victims into providing personal or payment information, often including an attachment containing malware.

• Criminals posing as government workers asking for Social Security, bank account or credit card numbers to “start the process for receiving the federal stimulus check.” We are also seeing a rise in fraudsters calling to ask for a personal address to send the stimulus check.

• People imitating healthcare workers or healthcare billing departments trying to collect money for “a loved one who has fallen ill with coronavirus, who doesn’t have funds for treatment.”

Scammers claiming to be from Falcon or other fraud monitoring tools inquiring about debit card transactions and then asking for personal information like Social Security number, date of birth or debit card PIN numbers.

• Government or healthcare workers will never reach out to you and ask for your Social Security number, bank account, credit card information, or personal address. The government will never ask you to pay anything up front to get a federal check or direct deposit, and hospitals would never call a relative to demand up-front money to treat their loved one.

Never hesitate to reach out to North Star if something seems fishy regarding any calls, letters or emails you receive about your North Star accounts.

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Reminder Regarding Financial Planning

North Star has Certified Financial Planners and Insurance Professionals on staff that can help guide you through financial issues and evaluate current and future goals appropriate to your situation or for a family member or friend.

Read more regarding financial planning in last weeks update: https://nsinvest.com/weekly-update-4-16-2020/

North Star Weekly Update 4.16.2020

Reminder regarding 1st Quarter Performance Reports:

We are suspending mail copies of this Quarter’s Performance Reports. If you would like to receive an electronic version of your report, please let us know. For those who receive these reports electronically, you will be receiving notification next week when they are posted to your portal. Monthly statements from your custodian will continue to be issued.

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It has been said that people spend more time planning their vacation than planning their retirement. Since vacation planning might not be your main focus right now, perhaps this is a good time to think about financial issues and evaluate current and future goals appropriate to your situation. North Star has Certified Financial Planners and Insurance Professionals on staff that can help guide you through a wide range of topics, including:

General Financial Planning

1. Retirement Projections – these will show you, based on various assumptions, how well you are positioned to retire, and what you can do to strengthen your position.

2. Investment Analysis – see how your assets are allocated and understand how changes in markets might affect you.

3. Risk Assessment – understand what your “risk number” is – how to invest so you are comfortable with the securities you choose.

4. Socially Responsible Investing – learn how your portfolio scores against ESG investing (Environmental., Social, and Governance) guidelines, to assess the sustainability and societal impact of your investments.

5. Estate Planning – IRAs cannot be “stretched” by beneficiaries anymore – all money must come out in 10 years. This might make you decide to change your strategy in leaving your wealth. Make sure your Will reflects your wishes. Check beneficiaries on retirement accounts. Be sure you have Powers of Attorney for Health Care and Assets. Remember digital assets – keep records so your executor knows where things are and can get to them.

6. Insurance Review – assess the risks you take and decide how to mitigate those risks. Disability, Long Term Care, Homeowners and Auto, Term or Whole Life, Annuities, and Directors Insurance can be valuable safeguards. As your life changes, your risks change, and you should review your insurance annually to be sure you are covered for the risks with most potential cost. You also may no longer need some insurance you are holding.

7. Budgeting – learn how to build a spending plan to ensure you spend less than you make.

8. Debt Repayment – various resources can help you identify your debt, consolidate it, and help you create a plan to exit debt as soon as you can.

9. Goal Setting – if you have a life-long goal, we can put this in your projections, and using “what if” scenarios, show you how you can achieve the goal – and if other changes need to be made or not.

10. Social Security Claiming Strategies – be sure you understand your benefits and those of your spouse, and plan your claiming strategy to maximize your benefit.

11. Medicare – once you are eligible, let us help you navigate the process.

12. Avoid scammers – we’ve assisted clients in identifying scams and hackers, and shown them how to sidestep any involvement.

If you are interested in discussing any of the above, please contact us.

North Star Weekly Update 4.9.2020

North Star will be closed on Friday, April 10, 2020

In recognition of Good Friday, April 10, 2020, all domestic equity and bond markets, as well as North Star, will be closed. The bond market will also close at 2:00 PM ET on Thursday, April 9. Please note that the banking system is open on Good Friday.

Money Movement:

– No outbound cashiering items (checks, wires, EFTs) will be processed on
Friday, April 10th.

– Incoming wires and direct deposits received on Good Friday will receive
Friday’s value date.

– Check deposits, using Remote Check Deposit or Mobile Check Deposit, submitted after cutoff Thursday, April 9 will post Monday, April 13.

– Debit Cards: On-line debits and authorizations will shadow post on Good Friday. Clearing times may vary and could be after Monday, April 13.

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1st Quarter Performance Reports:

We are suspending mail copies of this Quarter’s Performance Reports. If you would like to receive an electronic version of your report, please let us know. For those who receive these reports electronically, you will be receiving notification next week when they are posted to your portal. Monthly statements from your custodian will continue to be issued.

North Star Weekly Update 4.2.2020

April 2, 2020

As you know, our offices are closed and all North Star employees are working remotely. We have not encountered any interruption of services and we can still be reached at our normal phone numbers and email addresses. As a reminder, PLEASE DO NOT PLACE TRADE INSTRUCTIONS IN VOICEMAIL AS THEY WILL NOT BE EXECUTED.

Please keep us updated and informed about any changes regarding your personal situation. We are here to help.

These are difficult times for all of us and our thoughts are with those directly impacted by this pandemic.

Below is some new information about the CARES Act as well as updated instructions about depositing checks.

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CARES Act

The CARES (Coronavirus Aid, Relief and Economic Security) Act was signed into law late last week. This is a $2 trillion stimulus bill that is broad based: it covers various areas, industries, businesses, and individuals. The aim is to offer relief to those affected by the restrictions placed on all of us as we fight the spread of viral contagion. Very few areas of our society are unaffected.

Understanding all details of this total bill will take some time to analyze. However, we thought you would like to see the areas we think are important for individuals and families.

1. Stimulus Checks – also called recovery payments. All US residents with adjusted gross income of up to $75,000 ($150,000 for joint filers) are eligible for a payment of $1,200 per person, plus an additional $500 per child (under age 17).
– No minimum income requirements
– Based on either your 2018 or 2019 tax filings, payment not dependent on whether you have filed taxes for 2019
– As your adjusted gross income increases, your stimulus amount will go down and is phased out at $99,000 for single filers and $198,000 for joint filers with no children

2. Tax Filing Delayed – deadline is moved from April 15th, 2020 to July 15th, 2020
– Check your state’s tax filing date to ensure that it also has been moved to July 15th, 2020
– Includes tax payment due – moved to July 15th

3. Unemployment – increases benefits and broadens who is eligible
– Adds $600 per week on top of what is being paid by the state, for four months
– Adds 13 weeks of unemployment insurance
– Gig workers – normally cannot apply for unemployment insurance, but now are able if work is lost as result of public health emergency

4. Student Loans
– Employers can contribute up to $5,250 to a student loan, and the employee does not have to report this as income
– Suspends payments due until Sept. 30, 2020 with no penalties or accrued interest
-Contains provisions for students sent home mid-semester like universities can pay students who were unable to complete work-study programs

5. Required Minimum Distributions
– Waived for 2020, (not delayed)
-Can stop taking distributions at any time
-Includes inherited Traditional IRAs and inherited Roth IRAs

6. Elimination of Early Withdrawal Penalty
– Waives the 10% penalty for those under the age of 59 ½ who take a withdrawal up 100,000 from their IRA and who qualify for COVID-19 relief
– Can reconstitute over 3 years without affecting their contribution limits

7. Increase in Retirement Plan Loan Amount
– Loans can be taken from qualified accounts up to $100,000 in 2020
– Amount increased to 100% of the account balance

8. Mortgages
– Requires servicers of federally-backed mortgages to postpone mortgage payments if the borrowed attests to financial hardship due to COVID-19. Postponement must be for 180 days, and then an additional 180 days at request of borrower.
– Foreclosure Moratorium – Prevents federally-backed mortgage loan servicers from foreclosing for at least 60 days starting on March 18
– Eviction Relief for Renters – For 120 days after CARES Act is made law, mortgages backed by Federal Agencies cannot pursue eviction, or charge fees or penalties

9. Charitable Gifts
– $300 deduction for a charitable contribution regardless of whether you itemize deduction
– For corporations, the 10% limit on charitable contribution is raised to 25% of taxable income

There are many additional details to these provisions, and we encourage you to work with your tax professional before making any decisions. If you have any questions or would like to discuss anything, please let us know, we are here to help.

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Important Information:

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IRA Contribution Information:

According to the IRS Code, contributions are considered to be made in a taxable year as long as they are made by the filing deadline. This would imply that contributions are OK until July 15th.

COVID-19 Information page:

We will continue to provide you updates such as these via email as warranted. Additionally, we have established a special page on our website with all notices posted, which can be viewed by clicking here.

Reminder of our safe practices for preventing Fraud:

– Be aware of suspicious phone calls, emails, and texts from persons you do not know asking you to send money or disclose personal information.
– Keep us informed regarding changes to your personal information.
– Expect us to call you to confirm email requests to move money, trade, or change account information.

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Check Deposits:

Please send your check deposits directly to the custodian of your brokerage account:

For Deposit to NFS Brokerage Account:

National Financial Services
Attention: Check Processing
Mail Code: KY10
100 Crosby Parkway
COVINGTON KY 41015-4325

You must indicate the NFS account number on the front of the check. (this is your NTR#)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.

If your check is not payable to NFS but made payable to you, you must write the account number on the front of the check. And on the back of the check it must be endorsed by you and you must write on the back “payable to NFS”.

If you have a Wealthscape Investor Mobile App on your phone you can deposit checks easily thru the App.

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For Deposit to Fidelity Brokerage Account:

Overnight delivery:
Fidelity Investments
100 Crosby Parkway, Mailzone KC1H
Covington, KY 41015

US Mail:
Fidelity Investments
P.O. Box 770002
Cincinnati, OH 45277-0074

You must indicate the Fidelity account number on the front of the check. (This is a 9 digit account number)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.

If you have a Wealthscape Investor Mobile App on your phone you can deposit checks easily thru the App.

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For Deposit to Charles Schwab Brokerage Account:

Charles Schwab & Co.,
Chicago Metro Team
1958 Summit Park Drive, Suite 500
ORLANDO, FL 32810-5936

You must indicate the Charles Schwab account number on the front of the check. (This is an 8 digit account number)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.

If you have a Schwab Mobile App on your phone you can deposit checks easily thru the App.

North Star Weekly Update 3.25.2020

To our Valuable Clients and Friends, as you most likely know on Friday, March 20th, Illinois Governor Pritzker issued a “stay at home” order for the entire state. Complying with this order, North Star employed our Business Continuity Plan and instructed all employees to work in a remote capacity for their safety. During this time we are continuing to focus on providing the superior client service you have come to expect from us. With our employees working remotely we have not encountered any interruption to service and you can still contact us at our normal email addresses and phone numbers.

Since we are operating under a remote status, we have had to enable our phone system’s automated attendant at all times rather than have a receptionist answer your calls at the Chicago office. You will need to dial an employee’s direct extension or utilize our employee directory function. All employee extensions are being forwarded to alternate phones of those team members.

PLEASE DO NOT PLACE TRADE INSTRUCTIONS IN VOICEMAIL AS THEY WILL NOT BE EXECUTED.

We realize these are difficult times for all of us. Please keep us updated and informed about any changes regarding your personal situation. We are here to help.

Important Information:

U.S. extends tax filing deadline to July 15:
The U.S. government will give individuals and companies an extra three months to file their 2019 tax returns, extending the deadline to July 15, 2020 amid the coronavirus outbreak.

Check with your State as most are also extending state filings.

IRA Contribution Information:

According to the IRS Code, contributions are considered to be made in a taxable year as long as they are made by the filing deadline. This would imply that contributions are OK until July 15th.

COVID-19 Information page:

We will continue to provide you updates such as these via email as warranted. Additionally, we have established a special page on our website with all notices posted, which can be viewed by clicking here.

Reminder of our safe practices for preventing Fraud:

• Be aware of suspicious phone calls, emails, and texts from persons you do not know asking you to send money or disclose personal information.
• Keep us informed regarding changes to your personal information.
• Expect us to call you to confirm email requests to move money, trade, or change account information.

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Please send your check deposits directly to the custodian of your brokerage account:

For deposit to NFS account:

National Financial Services
Attention: Check Processing
Mail Code: KY10
100 Crosby Parkway
COVINGTON KY 41015-4325

You must indicate the NFS account number on the front of the check. (this is your NTR#)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.

If your check is not payable to NFS but made payable to you, you must write the account number on the front of the check. And on the back of the check it must be endorsed by you and you must write on the back “payable to NFS”.
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For Deposit to Fidelity Brokerage Account:

Overnight delivery:
Fidelity Investments
100 Crosby Parkway, Mailzone KC1H
Covington, KY 41015

US Mail:
Fidelity Investments
P.O. Box 770002
Cincinnati, OH 45277-0074

You must indicate the Fidelity account number on the front of the check. (This is a 9 digit account number)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.
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For Deposits to Charles Schwab Brokerage Account:

Charles Schwab & Co.,
Chicago Metro Team
1958 Summit Park Drive, Suite 500
ORLANDO, FL 32810-5936

You must indicate the Charles Schwab account number on the front of the check. (This is an 8 digit account number)
For IRA, SEP contributions you must indicate the year on the front of the check by the acct number.

All inquires should be directed to your North Star Advisor.

From our family to yours, please be safe and know that we are here to help in any way we can.

North Star Weekly Update 3.13.2020

To safeguard our employees from the coronavirus outbreak, we have asked our employees to work from home as a precautionary measure.  Effective today, Friday March 13, we will not be working in the office. We will still have uninterrupted access to email, and we can still be reached by calling us at our office numbers. Callers who call the main line will be asked to press 1 for the directory and then the first 3 letters of the first or last name of the person you are trying to reach.

Please let us know if you have any questions or concerns.

North Star Coronavirus Preparation

Due to the recent and growing concerns regarding the spread of COVID-19 (Coronavirus) we wanted to assure you that we are taking extra steps to keep our staff and visitors to our office safe and healthy. Currently, the risk to residents in Chicago still remains low even though the governor has declared a state of emergency in the State of Illinois.

Since the precautionary COVID-19 measures are beginning to impact daily life across the U.S., including workplace closures, we are keeping a close eye on the changing environment. We do not expect any interruptions to our continuity of service. Our Business Continuity Plan includes a Pandemic Preparedness Plan which has been thoroughly tested. We have extensive remote access technologies that will allow each employee, advisor, and portfolio manager to work outside of the office in a secure environment.

In the event we are forced to close our offices and work remotely, we will still have uninterrupted access to email and we can still be reached by calling our main numbers. For the Chicago office, 312-580-0900, or 847-831-8831 for our Highland Park office. You will be prompted to our directory where you can enter the extension of the person you would like to speak with.

Please let us know if you have any questions or concerns.

Special Market Commentary 2.28.2020

Concerns over the coronavirus have led to the fastest correction in stock market history. As of the opening of trading Friday morning the S&P 500 has declined from 3393 to 2880, or over 15%, from the all-time record high set last Wednesday. Meanwhile the yield on the Ten-Year Treasury has set record lows at 1.17%. This decline is painful and this outbreak unnerving, however it remains important to keep things in perspective. Let’s look at the growth in the S&P 500 over the last five years:

The market has given back the gains made in the 4th quarter of 2019. The future is uncertain, but today’s prices reflect an efficient pricing of all the information available. In the short-term the odds are even between a continued decline or bounce back rally. The swift decline reflects that the optimism of a resumption of growth in corporate earnings in 2020 has evaporated, although some forecasts have simply pushed out that growth to the back half of 2020. At this point everyone is just guessing because we are confronted with a global outbreak of a disease that is not well understood. The data so far suggests it is very contagious, but not particularly lethal except for people in more challenging health conditions. Be prepared for the headlines on the spread of the virus to get worse before it gets better.

Stocks were trading at historically high P/Es prior to this decline, supported by extraordinarily low interest rates that made the earnings yield attractive versus the risk-free rate. We take some comfort in that the recent decline in both equity prices and interest rates have widened that spread to historically high levels.

This episode serves to remind one to keep their allocation to equities consistent with one’s risk tolerance. Regardless of the absolute level of the market, it would make sense to target your equity allocation consistent with your risk tolerance. That might imply either buying or selling equities at these current levels. Please let us know if you would like to discuss whether the current amount of risk in your portfolio is appropriate.

Fear and greed are always the enemies of rational investing. Don’t panic. If history is a guide, this crisis will pass. Over the last 100 years we have had world wars, terrorist attacks, a global financial crisis, and numerous global epidemics of infectious diseases.

If you would like to discuss anything in greater detail, please do not hesitate to contact us.

North Star may only transact business in a jurisdiction if first registered, excluded, or exempted from state investment adviser registration requirements and follow-up, individualized responses to persons in a specific jurisdiction by the Firm will not be made absent compliance with state investment adviser registration requirements, or an applicable exemption or exclusion therefrom.

The information provided in this commentary is not an offer to sell or the solicitation of an offer to purchase any security, product, or brokerage service.