Martino Capital manages client portfolios directly in-house. We do not outsource day-to-day investing to a TAMP (turnkey asset management platform) or a third-party model shelf you never interviewed. That is an ADV-aligned firm rule, not a slogan: selection, sizing, rebalancing, and explaining the book stay with the people you can actually reach.
In plain English: “In-house portfolio management” here means Martino Capital builds and oversees client portfolios directly. We do not outsource that day-to-day portfolio management role to a TAMP.
We are a Colorado RIA focused on high-net-worth clients. Compensation is a single transparent AUM fee, with insurance/annuity commissions only when that structure benefits the client, is clearer or cheaper than wrapping the same fit under multi-year AUM, and is disclosed — no double-dip, no hidden kickbacks. Co-founders Tom Martino (CEO / consumer advocate) and Pat Jolliffe (COO / Compliance) treat “who runs the book” as a fiduciary question. Pair this guide with What is a TAMP? and managed portfolios.
What does “in-house portfolio management” mean here?
In plain English, in-house means:
- We design and maintain the investment approach for client accounts under our discretion.
- We are accountable for what sits in the book, when it changes, and why.
- We can answer operational questions without routing you to a platform help desk that runs someone else’s models.
- A third-party TAMP is not the investment engine between our name and your trades.
In-house does not mean we invent every security from scratch or never use ETFs, mutual funds, or other vehicles. It means accountability for the portfolio process stays with Martino Capital — not a turnkey sleeve sold as “our” management. For the outsourced side of that contrast, see what is a TAMP. For how we describe the offering on the site, see how we’re different.
Why don’t we use a TAMP?
Common industry reasons to outsource are real: scale without a full investment team, uniform models across many advisors, faster onboarding, and borrowing a platform’s “institutional” brand. None of those automatically fails a fiduciary test when roles and total cost are plain.
We still decline TAMPs for Martino Capital because our positioning is the opposite of that stack:
- Direct accountability. HNW households asking “who places trades in my accounts?” should get a firm answer, not a relationship manager reading a platform dashboard.
- Fee clarity. A single AUM line is easier to map in dollars than advisory + platform + sleeve + fund layers that only appear after onboarding. Vocabulary that often blurs this: fee-only vs fee-based vs AUM and how to spot hidden commissions and conflicts.
- ADV alignment. Our Form ADV Part 2A posture is direct management — not “we advise while a turnkey platform runs the book.” Brochure and CRD: Part 2A and IAPD / CRD 329648.
- Consumer-advocate standard. Marketing that sounds like personal portfolio management while the engine is outsourced is exactly the blur Tom’s background exists to challenge. Process beats adjectives: fiduciary duty in practice.
How does a single transparent AUM fee fit in-house management?
Martino Capital charges a single, transparent fee based on assets under management. No product kickbacks. No layered third-party manager fees on top of ours.
That fee language is deliberate. In-house management without a TAMP removes one common stack of platform and model-manager charges. Fund expense ratios and custodian costs can still exist — those are not the same as an advisory firm adding a turnkey platform fee while still collecting a full AUM wrap.
For soft dollars, 12b-1 fees, revenue sharing, and other costs that sit outside the AUM line, see soft dollars, revenue sharing, and invisible costs.
Commissions (including insurance/annuity products) are allowed only under a Client-benefit rule: when that structure is clearer or cheaper for the client than wrapping the same fit under multi-year AUM, with plain disclosure, no double-dip, and no hidden kickbacks. Commission is not automatically predatory. Hidden commission and undisclosed incentives are the problem. See also fee-only vs fee-based vs AUM.
Illustration only — not a quote for your household, not advice. Ask any firm for a fee-layer map in dollars at your asset level: advisory, platform (if any), underlying managers, fund expenses, and how commissions would appear if products enter the plan.
Who actually runs the book — Tom, Pat, and the team?
Leadership and compliance ownership sit with Tom Martino (CEO / consumer advocate) and Pat Jolliffe (COO / Compliance). Day-to-day portfolio work is a human-led process inside the firm — meetings, documentation, and investment decisions that can be explained without pointing at a black-box model provider.
That does not mean every trade is a celebrity signature. It means the firm you hired is the firm accountable for the book. Contrast that with a split where the relationship advisor is local and the investment engine is a national TAMP menu. Questions that surface the split are in questions to ask any advisor and the TAMP companion piece what is a TAMP.
For Denver metro and Colorado HNW readers comparing what “local fiduciary” should mean in practice — registration, access, in-house management, and fee clarity — see what “local fiduciary” means for Denver and Colorado high-net-worth investors.
Where does S.W.E.L.L. fit — research tool, not judgment substitute?
S.W.E.L.L. is our proprietary AI research tool. It sits inside a human fiduciary process. It does not replace advisory judgment, discretion, or the duty to put the client’s interest first.
Practical framing:
- Research aid for screening, organizing, and stress-testing ideas
- Human review before recommendations and portfolio actions
- No marketing claim that “the AI manages your money”
If a firm markets AI as the portfolio manager while fees and discretion stay murky, treat that as a clarity problem — same family of issues as outsourcing to a TAMP without saying so. More on our research posture: SWELL AI, how S.W.E.L.L. AI fits a fiduciary research process, and how we’re different.
What should you ask any firm that says “we manage your portfolio”?
Use these as a filter (expand in questions to ask any advisor):
- Who places trades and rebalances in my accounts — name the firm or team?
- Do you use a TAMP, model marketplace, or other advisers for the investment engine?
- Show advisory + platform + underlying costs in dollars at my asset level.
- Can I speak with someone who actually runs the book — or is that outsourced?
- Where is that answer written in Form ADV Part 2A?
If hallway language and ADV language diverge, believe the paperwork — then ask why the pitch differed. Reading help: how to read Form ADV Part 2A. Conflict patterns: how to spot hidden commissions and conflicts.
When is outsourcing still a legitimate design — and when is it a red flag?
Education only — not a recommendation for your situation.
Outsourcing can be a reasonable firm design when roles are disclosed, total cost is mapped in dollars, models fit the client, and the client prefers a standardized sleeve over a custom book. Some households care more about planning and relationship than about who clicks rebalance — as long as fees are plain and the ADV matches the hallway story.
Red flags look different: opaque stacks, “we manage your money” when a TAMP runs the book, inability to name the trading party, resistance to a written fee-layer map, or incentives to keep you in a preferred platform sleeve. Fiduciary duty in practice is what happens when incentives and clarity collide — not the adjective on the homepage.
Martino Capital’s choice is explicit: direct in-house management, no TAMPs, single transparent AUM fee, commissions only under the Client-benefit / disclose / no double-dip rule. That is the comparison point we offer against outsourced stacks.
FAQ
Does in-house mean you never use ETFs or outside funds?
No. In-house means we are accountable for selection, sizing, rebalancing, and explaining the portfolio. Using funds or ETFs as building blocks is normal. Handing the whole investment engine to a TAMP is what we do not do.
Is “no TAMPs” just marketing?
No. It is aligned with how we describe our advisory business in Form ADV Part 2A. Verify on Part 2A and IAPD / CRD 329648. For how outsourcing shows up at other firms, read what is a TAMP.
Do you charge platform or third-party manager fees on top of AUM?
No layered third-party manager fees on top of ours. The public fee posture is a single transparent AUM fee, with no product kickbacks. Underlying fund expense ratios and custodian costs are separate line items that can exist in any portfolio — ask for the dollar map either way. Related reading: invisible costs (soft dollars, revenue sharing, 12b-1).
How do commissions fit if you are AUM-based?
Only when a transparent commission structure benefits the client (clearer or cheaper than multi-year AUM for the same fit), with disclosure, no double-dip, and no hidden kickbacks — including insurance/annuity products when that comparison favors commission. See fee-only vs fee-based vs AUM.
Does S.W.E.L.L. manage my portfolio?
No. S.W.E.L.L. is a research tool inside a human process, not a substitute for fiduciary judgment or discretionary management.
How do I talk to someone about whether this model fits?
Phone-first: call 303.771.4357 or use the contact page. Email: tom@martinocapital.com. No online schedulers. Bring the questions above and your current ADV/fee stack if you are comparing firms.
Disclaimer: This article is general education, not personalized investment, tax, or legal advice, and not a substitute for reading a firm’s current Form ADV or consulting your own counsel. It does not create an attorney-client or adviser-client relationship. Advisory services are offered only where Martino Capital is appropriately registered or exempt. Past performance does not guarantee future results. For current disclosures, see our Form ADV on IAPD.
Page reviewed September 2026 for clarity. This is educational information, not personalized investment advice.
