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Item 1: Cover Page
One8zero8, LLC
d/b/a
1808 Capital Partners
Form ADV Part 2A
Investment Adviser Brochure
5 Corporate Center Ct., Suite 100
Greensboro, NC 27408
(336) 814-9800
March 25,2026
https://www.1808capital.com
This brochure (the “Brochure”) provides information about the qualifications and business
practices of 1808 Capital Partners (“1808,” “Adviser,” or “Firm”). If you have any questions
about the contents of this Brochure, please contact George Hall II, Chief Compliance Officer,
at (336) 814-9800 and/or
george.hall@1808capital.com. 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. Registration as an investment adviser does not imply a
certain level of skill or training.
Additional information about the Adviser is also available on the SEC’s website at
www.adviserinfo.sec.gov. You may search this site using a unique identifying number,
known as a CRD number. 1808 Capital Partners’ CRD Number is 332702.
Item 2: Summary of Material Changes
This Brochure dated March 25, 2026, is the annual Form ADV Part 2A filing for 1808 Capital
Partners. We will provide you with an updated brochure at least annually, as required, and
based on any material changes. We will provide this brochure at any time without charge.
The following material changes occurred since the last annual filing dated February 28, 2025:
•
Item 4: Updated regulatory assets under management as of December 31, 2025 and
added a third party trading platform.
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Item 3: Table of Contents
Item 1: Cover Page
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Item 2: Summary of Material Changes
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Item 3: Table of Contents
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Item 4: Advisory Business
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Item 5: Fees and Compensation
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Item 6: Performance
Based Fees and Side
by
Side Management
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Item 7: Types of Clients
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
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Item 9: Disciplinary Information
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Item 10: Other Financial Industry Activities and Affiliations
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Item 12: Brokerage Practices
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Item 13: Review of Accounts
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Item 14: Client Referrals and Other Compensation
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Item 15: Custody
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Item 16: Investment Discretion
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Item 17: Voting Client Securities
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Item 18: Financial Information
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Item 4: Advisory Business
Firm Description
One8zero8, LLC, a North Carolina limited liability company, was formed in 2021. One8zero8,
LLC, doing business as 1808 Capital Partners (“1808 Capital” or “Adviser” or “Firm” registered
with the SEC in 2024. The principal owners are George Hall II, Chief Compliance Officer, and
David Anderson, Chief Operating Officer.
Advisory Services
1808 Capital was founded to provide individuals, high net worth individuals, banking or thrift
institutions, charities, and corporations with comprehensive wealth management services. 1808
Capital tailors its service offering to meet the needs of each client it serves. Based upon the
direction of the client, the Adviser helps coordinate and implement strategies across the
following wealth management areas: financial planning, investment advisory, and estate
planning. When working with clients, the Adviser will utilize a priorities-based approach that
enables the client to make informed decisions and work towards agreed-upon goals and
objectives.
Investment Advisory Services
As described above, the Adviser provides investment advice to clients based on the individual
needs, objectives, and risk tolerance of the client. Through discussions, interviews, and
questionnaires, 1808 Capital will assist clients in determining their investment objectives. This
may include creating an Investment Policy Statement (“IPS”), financial plan, or making other
recommendations based on the client’s objectives, risk tolerance, liquidity needs, and any
other issues related to the client’s financial situation. 1808 Capital will meet with clients
periodically to update this information when requested by the client or when determined to be
necessary or advisable by the Adviser based on changes to the client’s financial or other
circumstances.
1808 Capital will design customized, strategic asset allocations and provide a framework for the
management and oversight of the portfolio. Implementation of the client’s investment strategy is
typically through a diversified portfolio comprised of both passive and active strategies. Portfolios
may include equities, mutual funds, ETFs, and some bonds. Written reports for individual
accounts, as well as household/portfolio summaries will be provided monthly by Raymond
James, member New York Stock Exchange/SIPC, or any other custodian the firm contracts with,
along with annual summary statements. Raymond James will also provide all tax related
documents annually. Periodically, and at the client’s request, 1808 Capital will provide
performance summary reporting and will at least annually provide such reports. Those reports
are sourced and populated via Raymond James’ performance reporting software.
Clients may impose certain written restrictions on the Adviser in the management of their
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investment portfolios, such as prohibiting the inclusion of certain types of investments in an
investment portfolio or prohibiting the sale of certain investments held in the account at the
commencement of the relationship. Each client should note, however, that restrictions
imposed by a client may adversely affect the composition and performance of the client’s
investment portfolio. Each client should also note that his or her investment portfolio is treated
individually by considering each purchase or sale for the client’s account. For these and other
reasons, performance of client investment portfolios within the same investment objectives,
goals and/or risk tolerance may differ, and clients should not expect that the composition or
performance of their investment portfolios would necessarily be consistent with similar clients
of the Adviser.
Wealth Management and Estate Planning Services
1808 Capital offers wealth management, financial planning, and estate planning services and
will provide ongoing services related to the following areas:
• Financial planning
• Estate/trust/gift planning and review
• Debt review
• Cash projections and net worth planning
Statements and other reports will be provided to the client on a monthly basis by the custodian.
1808 Capital will provide the client with performance reporting using the custodian’s
performance reporting software. These reports will be provided annually, and as requested by
the client.
Third-Party Platform
1808 Capital provides an additional service of a third-party platform for discretionary accounts
not directly held in our custody. This platform is for implementing tax efficient asset allocation
and opportunistic rebalancing strategies on behalf of a client. We regularly review the available
investment options in these accounts, monitor them, and rebalance and implement our
strategies in the same way we do other accounts, though using different tools as necessary.
The third-party platform allows 1808 Capital to manage client accounts on a discretionary basis
without having to obtain and maintain a client’s login credentials. Clients using the platform will
receive a link allowing them to connect their account(s) to the platform. Once a client account
is connected to the platform, 1808 Capital will monitor and rebalance or reallocate investments
in that account in the same way as we do for other (non-held away) accounts, though using
different tools. When clients engage 1808 Capital in this capacity, they are responsible for
keeping the Pontera platform link active, so that 1808 Capital will be able to access and manage
the respective account(s) without delay. If 1808 Capital determines that a platform link has
become inactive, 1808 Capital will use its best efforts to notify the client to resolve the issue.
As of December 31, 2025, the Adviser has $643,983,735 in assets under management on a
discretionary basis and $573,150 in assets under management on a non-discretionary basis.
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Item 5: Fees and Compensation
Investment Advisory, Wealth Management and Estate Planning Fees (“Advisory Fees”)
1808 Capital offers fee-only advisory services based upon assets under management and
charges an annual fee of up to 2% based on assets under management. Advisory fees are
negotiable and detailed in each client’s advisory agreement. We may group multiple accounts
of a client (or group of related clients) together for Advisory Fee billing purposes. Fees may
change over time and as discussed below, different Advisory Fee schedules may apply to
different types of clients, strategies and advisory arrangements. When appropriate, 1808
Capital reserves the right to offer alternative fee schedules.
The actual Advisory Fee charged to a particular client is disclosed in the investment advisory
agreement between the Adviser and each client. Factors considered in determining the Advisory
Fees charged include but are not limited to the complexity of the client’s portfolio; assets to be
placed under management; anticipated future assets; related accounts; portfolio style;
account composition; or other special circumstances or requirements. The Advisory Fee is
typically deducted directly from each client’s account, if authorized by the client. Otherwise,
clients are invoiced for their quarterly Advisory Fee.
Clients generally will pay the Advisory Fee quarterly in advance, however, this is subject to the
discretion of 1808 Capital and they may charge fees in arrears in some cases. Clients should
review their individual investment management agreement for information on their specific
fees. If an account is opened after the start of a quarter, Advisory Fees will be prorated
accordingly. Subsequently, the quarterly Advisory Fee is based on the value of the assets in the
account(s) on the last business day of the previous calendar quarter. If the investment advisory
agreement is terminated before the end of the calendar quarter in which an Advisory Fee has
been paid, the Adviser will provide a refund of the unearned Advisory Fee to the client based on
the number of days in the quarter prior to the termination date that assets remain in any account
you established through 1808 Capital and its relationships with third party custodians.
1808 Capital also charges fixed fees, or fees on an hourly basis for certain services.
In addition to the Advisory Fee, there are additional costs and expenses imposed by companies
other than the Adviser and may include, but may not be limited to, mutual fund and
exchange-traded fund (“ETF”) management fees and expenses, brokerage fees paid to clear
transactions, mark-ups/mark-downs on fixed income trades, annual fees paid for custodial
services, spreads paid to market makers, fees for trades executed away from the custodian,
wire transfer fees and other fees and taxes on brokerage accounts and securities transactions.
If clients are custodied and traded through Raymond James, 1808 Capital covers the trading
fees for clients.
Separate Account Manager Fees
When a Manager is utilized, the Manager’s fees will either be included in the Advisory Fee
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charged by the Adviser or billed to the client separately by the Manager. This arrangement will
be outlined in the agreement with the Separate Account Manager.
General Information on Compensation and Other Fees and Expenses
Although 1808 Capital has established the Advisory Fee schedule above, the Adviser retains the
discretion to negotiate or waive certain fees on a client-by-client basis. Client facts,
circumstances and needs are considered in determining a negotiated Advisory Fee schedule.
The specific annual Advisory Fee schedule is identified in the agreement between 1808 Capital
and each client.
The Adviser will bill you directly for our services, or you may authorize us to have your Advisory
Fees deducted directly from your account. This authorization will be included in the advisory
agreement and custodian account opening documents that you will execute to engage our
services.
Your custodian will provide you with statements that show the amount of the Advisory Fees paid
directly to us. Your custodian does not verify the accuracy of our Advisory Fee calculations.
Clients are advised that if securities transferred into the client’s account are sold, there may be
transaction costs, fees assessed at the mutual fund level (i.e., contingent deferred sales
charge), and/or potential tax ramifications. 1808 Capital will cover the transaction fees charged
by Raymond James, however there may be fees charged to the client account if the account is
held a custodian other than Raymond James.
Please see Item 12 - Brokerage Practices, in this brochure which further describes the factors
that 1808 Capital considers in selecting or recommending broker-dealers for client transactions
and determining the reasonableness of their compensation (e.g., commissions), if applicable.
Item 6: Performance-Based Fees and Side-by-Side Management
Neither the Adviser nor any of its officers or investment adviser representatives accept
performance-based fees. “Side by Side Management” refers to a situation in which the same
firm manages accounts that are charged on a performance fee basis and at the same time
manages accounts that are charged another type of fee, such as an hourly or flat fee or an asset-
based fee.
Item 7: Types of Clients
Types of Clients
1808 Capital provides advisory services primarily to individuals, high net worth individuals,
banking or thrift institutions, charities, and corporations. Generally, 1808 Capital has an account
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minimum of $1,000,000 but reserves the right to waive it or take on smaller accounts.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
Adviser’s investment process begins with determining the appropriate strategic asset
allocation for each client. Asset allocation involves translating the client’s circumstances,
objectives, and constraints into an appropriate portfolio for achieving the client’s goals within
the client’s tolerance for risk. Asset class targets will be defined by the following asset classes:
Equity, mutual funds, ETFs, bonds, private placements, and alternatives. After asset allocation
is determined, the next step in our process is to determine the specific investments that will be
used to implement the targeted allocations.
1808’s methodology for investment allocation across client portfolios is centered around a
thorough review of specific securities under consideration. 1808 Capital leverages a number of
different platforms for research due diligence from publicly available and subscription-based
industry periodicals, third-party financial data services, SEC registered company filings, general
financial market news and commentary, and private label memorandums, agreements and
offering documents, as well as other information readily available related to a specific security.
The approach is focused on meeting long-term financial objectives. The Firm makes its
investment recommendations based on maintaining a broadly diversified portfolio for clients
which included a variety of market sectors and asset classes.
1808’s investment strategies follow a bottom-up investment approach designed to focus on
individual securities and the qualities that those investments can bring to a broader, diversified
portfolio allocation that prioritizes managing risk through appropriate asset allocation and
diversification. While macroeconomic and general market data are helpful barometers of
overall investor sentiment, 1808 Capital does not rely heavily on such macro themes to make
individual security selections. The strategy prioritizes managing risk through appropriate asset
allocation and diversification. The Firm’s methodology uses a strategic approach by focusing
on the mix of asset classes that align with the client’s personalized financial goals. Once an
asset allocation is determined, 1808 Capital recommends specific investments to balance the
client’s portfolio to the prescribed asset allocation and sub-allocation.
Portfolio decisions rely on information provided by the client such as rate of savings, percentage
of income needed in retirement, portfolio withdrawals, tax rates, taxable capital gains and
losses, college costs, and market returns, to develop an investment strategy tailored to each
client’s individual needs.
Mutual funds and ETFs are evaluated and selected based on a variety of factors, including, as
applicable and without limitation, portfolio management team philosophy, investment
selection process, past adherence to stated process, past performance, internal fee structure,
strength and reputation of fund sponsor, overall ratings for safety and returns, portfolio
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manager, consistency of performance, and other factors.
Fixed income investments may be used to fulfill liquidity or income needs in a portfolio, or to
add a component of capital preservation. The Adviser may evaluate and select individual
bonds or bond funds based on a number of factors including, without limitation, rating, yield
and duration.
Investment Strategies
The Adviser’s strategic approach is to invest each portfolio based on the individual needs, goals
and objectives and risk tolerance of the client and employing a long-term approach which
means that securities are purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
While the
Adviser seeks to diversify clients’ investment portfolios across various asset classes
consistent with their objectives in an effort to reduce risk of loss, all investment portfolios are
subject to risks. Accordingly, there can be no assurance that client investment portfolios will
be able to fully meet their investment objectives and goals, or that investments will not lose
money. Investing in securities involves a risk of loss that clients should be prepared to bear.
Strategy and Securities Risks
Economic Conditions. Changes in economic conditions, including, for example, interest rates,
inflation rates, employment conditions, competition, technological developments, political
and diplomatic events and trends, and tax laws may adversely affect the business prospects
or perceived prospects of companies. While the Adviser or a Manager performs due diligence
on the companies in whose securities it invests, economic conditions are not within the control
of the Adviser, or the Manager and no assurances can be given that the Adviser or the Manager
will anticipate adverse developments.
Risks of Investments in Mutual Funds and ETFs. As described above, the Adviser and any
Managers may invest client portfolios in mutual funds and exchange-traded funds (“ETFs”).
These types investment funds are generally less risky than investing in individual securities
because of their diversified portfolios; however, these investments are still subject to risks
associated with the sectors or markets in which they invest. In addition, the funds’ success will
be related to the skills of the funds’ investment managers and their performance in managing
their funds. These funds are also subject to risks due to regulatory restrictions applicable to
registered investment companies under the Investment Company Act of 1940, as amended.
Equity Market Risks. The Adviser and any Managers will generally invest portions of client
assets directly into equity investments, primarily stocks, or into pooled investment funds that
invest in the stock market. As noted above, while pooled investment funds have diversified
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portfolios that may make them less risky than investments in individual securities, funds that
invest in stocks and other equity securities are nevertheless subject to the risks of the stock
market. These risks include, without limitation, the risks that stock values will decline due to
daily fluctuations in the markets, and that stock values will decline over longer periods (e.g.,
bear markets) due to general market declines in the stock prices for all companies, regardless
of any individual security’s prospects.
Fixed Income Risks. The Adviser and any Managers may invest portions of client assets directly
into fixed income instruments, such as bonds and notes, or may invest in pooled investment
funds that invest in bonds and notes. While investing in fixed income instruments, either
directly or through pooled investment funds, is generally less volatile than investing in stock
(equity) markets, fixed income investments nevertheless are subject to risks. These risks
include, without limitation, interest rate risks (risks that changes in interest rates will devalue
the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds
or notes will change value from the time of issuance to maturity).
Alternative Risks. The Adviser and any Managers may invest portions of client assets into
alternative investments. Assets in this building block are allocated to investments which seek
to generate returns by capturing risk premia generally not available in the public market arena.
The primary goal of alternatives is to provide additional diversification to portfolios with
relatively limited correlation to equity and fixed income markets. Alternative asset classes may
have risk and return characteristics that embody a hybrid of equity and fixed income
characteristics.
Private Placement Risks. The Adviser and any Managers may invest portions of client assets
into private placements. Under the Securities Act of 1933, any offer to sell securities must either
be registered with the SEC or meet an exemption. Issuers and broker-dealers most commonly
conduct private placements under Regulation D of the Securities Act of 1933 (Rules 504, 505 or
506), but there also are other exemptions than those allowed by Reg D. A security offering
exempt from registration with the SEC is sometimes referred to as a private placement or
an unregistered offering.
Private and public companies engage in private placements to raise funds from investors.
and other private investment funds also engage in private placements.
Hedge Funds
No public or other market to buy or sell such private placement securities is available or may
ever develop in the future. Private placements, including private equity, venture capital or
private investment funds, including investments in managers, secondary transactions, and co-
investments, are often speculative, highly illiquid, lack transparency, lack daily pricing, involve
a high degree of risk and have high fees and expenses that could reduce returns. Therefore, they
are intended for long-term investors who can accept such risks. Also, restrictions on
transferring interests in private placements may exist, meaning that selling out of investments
may be difficult, if not impossible, and that prospective or existing investors should be prepared
to retain their investments in the fund until the fund liquidates. Private placements may borrow
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money or use leverage for a variety of purposes, which involves a high degree of risk including
the risk that losses may be substantial. Lastly, the possibility of partial or total loss of a private
placement's capital exists, and prospective investors should not subscribe unless they can
readily bear the consequences of such loss.
Generally speaking, private placements are not subject to some of the laws and regulations that
are designed to protect investors, including the comprehensive disclosure requirements that
apply to registered offerings. Private placement memoranda typically are not reviewed by any
regulator and may not present the investment and related risks in a balanced light. Although all
issuers relying on a Regulation D exemption are required to file a document called a Form D
(including brief information about the issuer, its management and promoters, and the offering
itself) no later than 15 days after they first sell the securities in the offering, such Form D filing
does not constitute registration. Form D filings can be searched on the SEC’s website
at sec.gov/edgar/searchedgar/webusers.htm.
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 a client’s evaluation of the Adviser or the integrity
of the Adviser’s management. The Adviser has no disciplinary events to report.
Item 10: Other Financial Industry Activities and Affiliations
Adviser’s management persons are not registered, nor do any management persons have an
application pending to register, as a broker-dealer or a registered representative of a broker-
dealer. Adviser’s management persons are not registered, nor do any management persons
have an application pending to register, as a futures commission merchant, commodity pool
operator, a commodity trading Adviser, or an associated person of the foregoing entities.
Adviser receives no additional compensation directly or indirectly from the third-party
investment managers it recommends or engages to manage portions of your portfolios.
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics and Personal Trading
The Adviser has adopted a Code of Ethics (the “Code”), the full text of which is available to you
upon request. The Code is designed to assist the Adviser in complying with applicable laws and
regulations governing its investment advisory business. Under the Investment Advisers Act of
1940, as amended, the Adviser owes fiduciary duties to its clients. Pursuant to these fiduciary
duties, the Code requires Adviser associated persons to act with honesty, good faith, and fair
dealing in working with clients. In addition, the Code prohibits associated persons from trading
or otherwise acting on insider information.
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The Code sets forth guidelines for professional standards for the Adviser’s associated persons
(managers, officers, and employees). Under the Code’s Professional Standards, the Adviser
expects its associated persons to put the interests of its clients first, ahead of personal
interests. In this regard, Adviser associated persons are not to take inappropriate advantage of
their positions in relation to Adviser clients.
The Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, the Adviser’s associated persons may
invest in the same securities recommended to clients. This may create a conflict of interest
because associated persons of the Adviser may invest in securities ahead of or to the exclusion
of the Adviser clients. Under its Code, the Adviser has adopted procedures designed to reduce
or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated
persons, including prohibiting trading by an associated person in any security within a certain
period before any client account trades or considers trading the same security and the creation
of a restricted securities list, reporting and review of personal trading activities and pre-
clearance of certain types of personal trading activities. These policies are designed to
discourage and prohibit personal trading that would disadvantage clients. The Code also
provides for disciplinary action as appropriate for violations. 1808 Capital will provide a copy of
the Firm’s Code of Ethics to any client or prospective client upon request.
Participation or Interest in Client Transactions
As outlined above, the Adviser has adopted procedures to protect client interests when its
associated persons invest in the same securities as those selected for or recommended to
clients. In the event of any identified potential trading conflicts of interest, the Adviser’s goal is
to place client interests first.
The Code contains policies regarding participation in initial public offerings (IPOs”) and private
placements to comply with applicable laws and avoid conflicts with client transactions. If an
associated person wishes to participate in an IPO or invest in a private placement, he/she must
submit a pre-clearance request and obtain the approval of the CCO.
Item 12: Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, the
Adviser seeks “best execution” for client trades, which is a combination of a number of factors,
including, without limitation, quality of execution, services provided and fees charged. As
mentioned in Item 5 – Fees and Compensation of this Brochure, 1808 Capital will cover any
transaction fees charged by Raymond James, however there may be transaction fees charged to
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the client account if the account is held a custodian other than Raymond James.
Directed Brokerage
Clients may direct the Adviser to use a particular broker for custodial or transaction services on
behalf of the client’s portfolio. In directed brokerage arrangements, the client is responsible for
negotiating the commission rates and other fees to be paid to the broker. Accordingly, a client
who directs brokerage should consider whether such designation may result in certain costs or
disadvantages to the client, either because the client may pay higher commissions or obtain less
favorable execution, or the designation limits the investment options available to the client.
The arrangement that the Adviser has with Raymond James is designed to maximize efficiency
and to be cost effective. By directing brokerage arrangements, the client acknowledges that these
economies of scale and levels of efficiency are generally compromised when alternative brokers
are used. While every effort is made to treat clients fairly over time, the fact that a client chooses
to use the brokerage and/or custodial services of alternative service providers may in fact result
in a certain degree of delay in executing trades for their account(s) and otherwise adversely affect
management of their account(s). By directing the Adviser to use a specific broker or dealer, clients
who are subject to ERISA confirm and agree with the Adviser that they have the authority to make
the direction, that there are no provisions in any client or plan document which are inconsistent
with the direction, that the brokerage and other goods and services provided by the broker or
dealer through the brokerage transactions are provided solely to and for the benefit of the client’s
plan, plan participants and their beneficiaries, that the amount paid for the brokerage and other
services have been determined by the client and the plan to be reasonable, that any expenses
paid by the broker on behalf of the plan are expenses that the plan would otherwise be obligated
to pay, and that the specific broker or dealer is not a party in interest of the client or the plan as
defined under applicable ERISA regulations.
Aggregated Trade Policy
The Adviser generally performs customized investment management services for various
clients and does not typically aggregate trades.
Item 13: Review of Accounts
Reviews
Managed portfolios are reviewed on at least an annual basis by the CCO, COO and the Firm’s
Investment Advisory Representatives. Additional reviews are conducted upon client request.
Other factors that could trigger a review include receipt of information material to the
management of the portfolio, or at any time such review is deemed necessary or advisable by
the Adviser, such as a change in client circumstances or, economic, political or market
conditions.
Reporting
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The Adviser also prepares and provides account performance reports to clients at least
annually. From time to time and in accordance with the Adviser’s investment advisory
agreement with clients, the Adviser will provide additional reports. These reports are in addition
to the account statements provide by custodians.
Item 14: Client Referrals and Other Compensation
1808 Capital does not maintain any referral arrangements, nor do we receive any other
compensation for advisory services from other parties who are not clients.
Item 15: Custody
Client assets are maintained at a qualified custodian in accounts registered to clients. The
custodian sends account statements directly to clients at least quarterly and clients should
carefully review those custodian statements. 1808 Capital also provides reports that include a
statement urging clients to compare the custodian account statements they receive against
reports they receive from 1808.
Item 16: Investment Discretion
As described in Item 4 - Advisory Business, 1808 Capital will manage the client’s investment
portfolio on a discretionary or non-discretionary basis pursuant to an investment advisory
agreement with the client. As a discretionary investment adviser, the Adviser will have the
authority to supervise and direct the portfolio without prior consultation with the client.
Clients who choose a non-discretionary arrangement must be contacted prior to the execution
of any trade in the account(s) under management. This may result in a delay in executing
recommended trades, which could adversely affect the performance of the portfolio. In a non-
discretionary arrangement, the client retains the responsibility for the final decision on all
actions taken with respect to the portfolio.
Discretionary authority is covered in each client’s investment advisory agreement.
Item 17: Voting Client Securities
The Adviser will not accept authority to vote client securities. The custodian of the client’s
assets will send all proxies directly to the client, so that the client may vote the proxies.
Clients may contact the Adviser with questions relating to proxy procedures and proposals;
however, the Adviser generally does not research particular proxy proposals.
Item 18: Financial Information
The Adviser 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.
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The Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance; and therefore, is not required to provide a balance sheet to clients.
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