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Item 1 – Cover Page
Bason Asset Management
355 S. Teller St. Suite 200
Lakewood, CO 80226
(720) 446-8555
www.basonasset.com
February 19, 2026
Bason Asset Management
Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Bason Asset
Management. Please contact James Osborne, President at (720) 446-8555 or james@basonasset.com,
if you have any questions about the contents of this brochure. 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.
Additional information about Bason Asset Management is available on the SEC’s website at:
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD
number. The CRD number for Bason Asset Management is 165450.
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Item 2 – Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually when material changes occur
since the previous release of the Firm Brochure.
Material Changes since the Last Update
There have been no material changes to this filing since the most recent update on 2/17/2025.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by
telephone at: 720-446-8555 or by email at: james@basonasset.com.
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Item 3 – Table of Contents
Item 4 - Advisory Business ........................................................................................................4
Item 5 - Fees and Compensation ...............................................................................................4
Item 6 - Performance- Based Fees .............................................................................................5
Item 7 - Types of Clients ........................................................................................................... 5
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 5
Item 9 - Disciplinary Information ...............................................................................................6
Item 10 - Other Financial Industry Activities and Affiliations ..................................................... 6
Item 11 - Code of Ethics Participation or Interest in Client Transactions and Personal Trading ...6
Item 12 - Brokerage Practices ....................................................................................................7
Item 13 - Review of Accounts ....................................................................................................7
Item 14 - Client Referrals and Other Compensation ...................................................................8
Item 15 - Custody ......................................................................................................................8
Item 16 - Investment Discretion ................................................................................................8
Item 17 - Voting Client Securities ..............................................................................................8
Item 18 - Financial Information .................................................................................................9
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Item 4 - Advisory Business
Bason Asset Management (Bason) was formed in 2012 in Lakewood, Colorado. The principal owner is
James Osborne. We have no public or privately-owned affiliated companies. Bason provides portfolio
management and financial planning services, including investment advice to individuals and families
and ERISA retirement plans. Portfolio management services, provided under Bason’s Asset
Management Agreement, include initially reviewing clients’ existing investment portfolios and other
data, developing an investment policy statement, providing investment recommendations consistent
with clients’ stated financial objectives, and implementing these recommendations at a third-party
custodian (see Custody on page 8). Portfolio management services also include the ongoing
monitoring of the investment portfolio, including quarterly account performance reporting, asset
allocation analysis and updating, rebalancing and tax-loss harvesting recommendations, and annual
portfolio review meetings with clients. Investment recommendations are primarily limited to open-
end mutual funds and exchange-traded funds, but we also serve to help clients with existing positions
in individual stocks. We do not advise our clients to invest in individual stocks and bonds.
All client portfolios are customized and built for each individual relationship, although many clients
will hold similar securities and allocations. The portfolio construction process begins with a discussion
of the client's goals and risk tolerance to determine a suitable long-term investment portfolio. We do
not participate in wrap fee programs and investment management fees are not linked to a client's
portfolio value.
Bason provides fiduciary services, including 3(21) and 3(38) fiduciary services, to ERISA retirement
plans, including profit sharing 401(k) plans and defined benefit plans. These services include
investment plan offering review and selection, model portfolio development, monitoring and
Reporting includes plan
management and regular compliant reporting to plan sponsors.
benchmarking and 408(b)(2) fee and service disclosure.
Financial planning services include retirement income planning, education funding planning, stock
compensation planning, insurance needs analysis, multi-generational financial planning, and
philanthropic planning.
When Bason provides investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. Bason operates under a special rule that requires us to act in your best interest
and not put our interest ahead of yours.
As of January 31, 2026, Bason had assets under management of $$845,906,132 in discretionary assets
and $$2,898,000 in non-discretionary assets.
Item 5 - Fees and Compensation
Bason Asset Management is compensated only by the fees paid by its clients. Bason and its
representatives are not affiliated with a broker/dealer or insurance broker, and as such do not carry
licenses necessary to receive securities or insurance commissions. Fees for services provided under
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Bason’s Asset Management Agreement currently include an initial flat fee for initial portfolio design
and set-up that ranges from $1,500 and $3,000 depending upon the scope and complexity of the
services required and an ongoing annual fee of $5,800 per client or $1,450 per quarter. Unless
waived, the flat fee for initial portfolio design and set-up is due at the time Bason provides the client
with the initial planning recommendations, and such fee is payable by check or ACH. Ongoing annual
fees for services provided under Bason’s Asset Management Agreement are paid quarterly in
advance, and should a client terminate the relationship with Bason, the unearned portion of the
retainer fee will be refunded. Clients terminating their contract with Bason within the first five days
are entitled to a full refund. Clients may elect to pay this fee directly or have the fee deducted
quarterly from investment accounts. Please refer to Item 15 for information regarding fees deducted
from investment accounts. Our fees are not tied to the value of the client’s investment portfolio. We
feel strongly that this structure is the most equitable to investors and helps to reduce the conflicts of
the asset-gathering model. Bason's retainer fee is negotiable under certain circumstances.
Clients may incur fees from the custodian selected to provide services related to record keeping, tax
reporting and statement production. These fees may include IRA and retirement account annual fees,
nominal trade ticket charges or banking fees. No portion of these fees is retained by or remitted to
Bason.
Clients who choose not to engage Bason for services under the Asset Management Agreement may
choose to engage Bason for financial planning services on a per-project basis. A typical project
engagement fee is $3,000 - $4,000 and is billed in arrears not less frequently than quarterly. Clients
may terminate this agreement within 5 calendar days of signing and receive a full refund of any
unearned fees paid. Clients otherwise terminating this agreement outside of the 5-day window will
receive a pro-rated refund of unearned fees.
Item 6 - Performance-based fees
As Bason is committed to a passive investment philosophy, we do not charge performance-based fees.
Item 7 - Types of Clients
Our firm works primarily with individuals and families but also serves retirement plans, foundations,
endowments, and other non-profit organizations.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Research proves that passive investing works for all investors, regardless of size or scope. Our
investment strategy begins with a general long-term acceptance of the Efficient Market Hypothesis,
which states that the primary driver of a portfolio’s risk and return characteristics is determined by
asset allocation, and not security selection. As countless studies have proven, active management as a
whole underperforms the market portfolio and attempting to pick investments or investment
managers which will outperform the market is more an act of luck than skill. To protect our clients
from the needless costs of active management and the inevitable underperformance that results,
clients are advised to invest in passive strategies, also known as index funds. The primary vehicles
recommended to Bason clients are mutual funds, which includes exchange-traded mutual funds.
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As with any stock-based investment, mutual funds, including passively managed mutual funds, carry
the risk of losses. While we can reduce company-specific risk through diversification, eliminate
manager-risk with passive portfolios and reduce overall portfolio volatility with a broad mix of stocks,
bonds, and other assets, we cannot eliminate the risk of fluctuation that comes with investing in
stocks and bonds. It is always possible in any given week, month, or year that an investor’s portfolio
value could be less than the previous period. The Efficient Market Hypothesis dictates that it is this
market risk that offers investors potential long-term rewards, so we aim to reduce other previously
mentioned risks wherever possible.
Item 9 - Disciplinary Information
Neither James Osborne nor any employees of Bason have ever been convicted of, pled guilty or no
contest to any felony or misdemeanor in a criminal or civil action in any foreign or domestic court.
Neither James Osborne nor any employees of Bason have ever been part of a proceeding before the
SEC or any other industry regulatory agency. Neither James Osborne nor any employees of Bason
have ever been part of a self-regulatory organization’s proceeding.
Item 10 - Other Financial Industry Activities and Affiliations
Neither James Osborne or any employees of Bason are registered, or applying to register, as a broker-
dealer, or registered representative of a broker-dealer, or futures commissions merchant, commodity
pool operator, or commodity trading advisor.
Neither James Osborne or any employee of Bason has a relationship with a broker dealer, municipal
securities dealer, government securities dealer or broker, investment company, outside investment
adviser, banking or thrift institution, accounting firm, law firm, insurance agency, pension consultant,
real estate broker, sponsor, or syndicator of limited partnerships.
Bason receives no compensation from outside investment advisers and receives no compensation
other than the fees paid by the firm’s clients.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
As a Registered Investment Adviser, Bason has a fiduciary duty to its clients. In the simplest of terms
this means that our first obligation is to put the client’s needs above all other interests or conflicts.
Bason takes our fiduciary duty very seriously and has built our business model around our obligation
to minimize conflicts of interest with our clients and to truly make recommendations that our in their
best interests.
Bason’s owner and employees will adhere to all federal and state securities laws and regulations. All
Bason related persons will be held to the highest standard of conduct and shall not withhold pertinent
information from clients regarding securities recommendations, act to deceive or defraud any client
or outside party, or otherwise partake in any activity with the intent to deceive or defraud any
regulatory body, government office or client.
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Bason’s owner and employees may buy or sell securities for themselves which are also recommended
to clients, which represents a conflict of interest. In efforts to avoid conflicts of interest, Bason
monitors and supervises the personal securities transactions of all employees and its owner.
Monitoring is conducted by James Osborne, President and Chief Compliance Officer of Bason. Bason
retains records of all securities transactions conducted by employees and owners. For compliance
purposes with regulations, all employees and the owner are considered “access persons” whose
transactions will be monitored.
As a matter of principle, Bason’s owner and employees are to withhold public comment regarding
advice on individual securities, as to avoid conflicts of interest when these comments may enrich the
Bason associated person.
Item 12 - Brokerage Practices
In general, price (cost of commissions) and trade execution are the primary drivers of a decision to
recommend broker-dealers for client transactions. We work primarily with Charles Schwab
Institutional but can work with a variety of broker-dealer custodians at our client’s request.
Soft dollars: Bason may receive an economic benefit from external sources in the form of the support
products and services they make available to us and other independent investment advisors. The
availability to us of an external source's products and services is not based on our offering particular
investment advice or buying particular holdings for our clients. Bason does receive research or
products and services from Schwab in connection with client securities transactions. This includes
securities research and a trading platform. As a practice, Bason does not rely on the research provided
by Charles Schwab. The trading platform provides significant business efficiency which benefits our
clients. As well, it is very common for custodial broker-dealers to provide trading access to client
accounts. All broker-dealers that our clients work with provide investment transaction and pricing
data so that we are able to accurately track investment performance.
Bason does not receive client referrals from any broker-dealers.
Directed Brokerage: While Bason would permit clients to request directed brokerage, the majority of
our clients are individuals who generally have transactions executed at Schwab. Bason does not
encourage directed brokerage, which is more common for mutual fund or pension fund managers
regularly trading equities.
Trade Aggregation: We manage individual portfolios and not “model” portfolios. However, we will
aggregate ETF trades, when possible, to obtain best execution. If Bason decides to purchase or sell the
same security for several clients at approximately the same time, allocations are done in an equitable
fashion, typically on a pro rata basis.
Item 13 - Review of Accounts
James Osborne or the assigned advisor for each client reviews each client’s portfolio no less
frequently than once per quarter. At the end of each quarter Bason generates an updated Asset
Allocation analysis and trailing period performance report for all investment management clients. The
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Asset Allocation report is then compared to the client’s signed Investment Policy Statement to analyze
the variance from the target portfolio allocation. Additionally, performance is compared to broad
market averages to ensure that the client is capturing as much of the long-term return of the market
as possible. Clients will also receive quarterly statements from their custodian (i.e. Charles Schwab).
Accounts are also reviewed during an annual portfolio review meeting with the firm’s clients.
Item 14 - Client Referrals and Other Compensation
No one outside of Bason’s owner and employees provides investment advice to Bason clients
(exclusive of outside relationships our clients may choose to have). Bason does not compensate
outside parties for client referrals. This includes existing clients or other outside professionals (such
as CPAs, attorneys, etc.). Bason does not share revenue or pay “finders fees” for client referrals.
Item 15 - Custody
Bason does not take physical custody of client assets or provide custodial services apart from
authorized fee withdrawals. All clients work with a third-party custodian for handling of cash and
securities, from which clients receive monthly (or quarterly) brokerage statements, and tax reporting.
Clients of Bason are encouraged to regularly compare their portfolio values reporting on Bason
quarterly portfolio reports with the statements generated by the custodian to ensure accuracy. Clients
who elect to have fees deducted from custodial accounts recognize that this fee is $5,800 per year,
billed quarterly at $1,450 and is charged in advance. Clients will sign a management agreement to
authorize this fee deduction. Clients will receive quarterly invoices detailing this fee and its
calculation, as well as quarterly statements from the custodian showing this fee debited from their
accounts.
The Firm may, at times, have constructive custody of assets to the extent is uses standing letters of
authorizations (“SLOA’s) for third-party money movement with the client’s custodian.
Item 16 - Investment Discretion
As outlined in our Asset Management Agreement, Bason accepts discretionary authority over clients’
investment portfolio under our management, including the type of security and number of shares.
However, we prefer to discuss all transactions with clients before any trades are placed in client
accounts. Having discretion over mutual fund and ETF trades allows us to be more flexible for those
clients who prefer not to discuss each trade with us.
Item 17 - Voting Client Securities
Bason does not proxy vote for our clients’ investment positions. Clients will receive proxy solicitations
directly from the custodian. We are happy to discuss these solicitations with our clients.
Further, we will have no power, authority, responsibility, or obligation to take any action with regard
to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other
litigation or proceeding relating to securities held at any time in a client account, including without
limitation, to file proofs of claim or other documents related to such proceeding, or to investigate,
initiate, supervise, or monitor class action or other litigation involving client assets.
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Item 18 - Financial Information
Bason does not collect asset management fees for a period of greater than one quarter and is not
required to disclose a balance sheet. Bason has no outstanding liabilities or financial impairments
that would inhibit our ability to provide promised services to clients. Bason does not require or solicit
prepayment of fees of more than $1,200 per client, six months or more, in advance.
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