Overview
- Headquarters
- Beaumont, TX
- Average Client Assets
- $3.7 million
- SEC CRD Number
- 150407
Fee Structure
Primary Fee Schedule (BEAUMONT ASSET MANAGEMENT, L.L.C. ADV BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | $10,000,000 | 0.60% |
| $10,000,001 | $20,000,000 | 0.40% |
| $20,000,001 | and above | 0.20% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $42,000 | 0.84% |
| $10 million | $72,000 | 0.72% |
| $50 million | $172,000 | 0.34% |
| $100 million | $272,000 | 0.27% |
Clients
- HNW Share of Firm Assets
- 80.70%
- Total Client Accounts
- 493
- Discretionary Accounts
- 493
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting
Regulatory Filings
Primary Brochure: BEAUMONT ASSET MANAGEMENT, L.L.C. ADV BROCHURE (2026-03-05)
View Document Text
Cover Page - Item 1
2911 Toccoa Street, Suite B
Beaumont, TX 77703
409-899-9569
www.beaumontasset.com
March 5, 2026
FORM ADV PART 2A BROCHURE
This brochure provides information about the qualifications and business practices of Beaumont Asset
Management, L.L.C. 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. Please contact us if you
have any questions about the contents of this brochure.
Additional information about Beaumont Asset Management, L.L.C. is available on the SEC's website at
www.adviserinfo.sec.gov by searching CRD# 150407.
Beaumont Asset Management, L.L.C. is a registered investment adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a certain level
of skill or training.
Form ADV Part 2A Brochure
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this
brochure. If there are any material changes to an adviser's disclosure brochure, the adviser is required
to notify you and provide you with a description of the material changes.
Since our last annual updating amendment filing dated March 21, 2025, we have amended this
brochure to disclose the following changes material changes to report.
On March 5, 2026, as part of our firm’s annual updating amendment filing, we updated this
brochure to include disclosure on the maximum fixed fee that we may charge for stand-alone
financial planning and consulting services. Please refer to Item 5 of this brochure for more
information and contact us if you have any questions above this change.
Clients can request a copy of our firm’s ADV Part 2 Brochure and/or contact us with any questions at
409-899-9569.
If you would like to receive a complete copy of our current brochure free of charge at any time, please
find our contact information on the cover page of this brochure.
Form ADV Part 2A Brochure
Page 3
Table of Contents - Item 3
Contents
Cover Page - Item 1 ................................................................................................................................................... 1
Material Changes - Item 2 ......................................................................................................................................... 2
Table of Contents - Item 3 ......................................................................................................................................... 3
Advisory Business - Item 4 ......................................................................................................................................... 4
Fees and Compensation - Item 5 ............................................................................................................................... 6
Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................................... 7
Types of Clients - Item 7 ............................................................................................................................................ 7
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ..................................................................... 7
Disciplinary Information - Item 9 ............................................................................................................................. 11
Other Financial Industry Activities or Affiliations - Item 10 .................................................................................... 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ............................ 11
Brokerage Practices - Item 12 ................................................................................................................................. 12
Review of Accounts - Item 13 .................................................................................................................................. 13
Client Referrals and Other Compensation - Item 14 ............................................................................................... 14
Custody - Item 15 .................................................................................................................................................... 14
Investment Discretion - Item 16 .............................................................................................................................. 14
Voting Client Securities - Item 17 ............................................................................................................................ 15
Financial Information - Item 18 ............................................................................................................................... 15
IRA Rollover Services Disclosure .............................................................................................................................. 15
Privacy Policy Notice ............................................................................................................................................... 17
Form ADV Part 2A Brochure
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Advisory Business - Item 4
Description of Firm
Beaumont Asset Management, L.L.C. (“BAM”) is a registered investment adviser based in Beaumont,
Texas. We are organized as a limited liability company under the laws of the State of Texas. Francis
Coker, Jeffrey Oliverio, and Marco Rimassa are the owners of our firm. Beaumont Asset Management,
L.L.C. has been providing advisory services since 2009.
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we," "our," and "us" refer to Beaumont Asset
Management, L.L.C. and the words "you," "your," and "client" refer to you as either a client or
prospective client of our firm. You may see the term Associated Person throughout this brochure, which
refers to anyone from our firm who is an officer, an employee, and all individuals providing investment
advice on behalf of our firm. Where required, such persons are properly registered as investment
adviser representatives.
Currently, we offer the following investment advisory services, personalized for each individual Client:
• Portfolio Management Services
• Financial Planning and Consulting Services
• Pension Consulting Services
Portfolio Management Services
BAM offers portfolio management services to Clients where we manage our client’s investments within
the larger context of the client’s overall wealth planning process. At the start of the service, an
Associated Person will have one or more consultations with the Client to determine the Client’s
investment objectives, risk tolerance, and other relevant information. We will also use the information
we gather from our consultations to create an investment strategy. The ongoing financial planning
advice and services will depend on each individual client’s individual needs and circumstances.
If you engage our firm for portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the number of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is granted by the advisory agreement
you sign with our firm and within the agreement with your custodian. In our sole discretion, we may
accept instructions from you that limit our discretionary authority (for example, limiting the types of
securities that can be purchased or sold for your account). Such requests must be presented to our firm
in writing.
Financial Planning and Consulting Services
We offer financial planning and consulting services that typically involve providing a variety of advisory
services to clients regarding the management of their financial assets based upon an analysis of their
individual needs. Services can range from broad-based financial planning with
investment
recommendations and a written financial plan to consultative or single subject planning.
Form ADV Part 2A Brochure
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Financial planning and consulting services are based on your financial situation at the time we present
our recommendations to you, and on the financial information you provide to us. You must promptly
notify our firm if your financial situation, goals, objectives, or needs change. You are under no obligation
to act on our financial consulting recommendations. Should you choose to act on any of our
recommendations, you are not obligated to implement such recommendations through any of our
other investment advisory services, and you may act on our recommendations by placing securities
transactions with any brokerage firm.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as: Diversification; Asset allocation; Risk tolerance; and
Time horizon. Our educational seminars may include other investment-related topics specific to the
particular plan. We may also provide additional types of retirement plan consulting services to plans on
an individually negotiated basis. All services, whether discussed above or customized for the plan based
upon requirements from the plan fiduciaries (which may include additional plan-level or participant-
level services) shall be detailed in a written agreement and be consistent with the parameters set forth
in the plan documents.
Types of Investments
We primarily offer advice on equity securities, debt securities, mutual fund shares, and exchange traded
funds. Additionally, we may advise you on any type of investment that we deem appropriate based on
your stated goals and objectives. We may also provide advice on any type of investment held in your
portfolio at the inception of our advisory relationship. You may request that we refrain from investing
in particular securities or certain types of securities, and such requests must be delivered to us in
writing.
Since our investment strategies and advice are based on each client’s specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
We do not participate in a wrap fee program.
Assets Under Management
As of December 31, 2025, we manage approximately $365,197,944 in client assets on a discretionary basis.
Form ADV Part 2A Brochure
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Fees and Compensation - Item 5
Portfolio Management Services Fees
Our annual fee for portfolio management services is based on a percentage of the assets in your
account and is set forth in the following blended tiered fee schedule:
Assets Under Management
First $1,000,000
Next $4,000,000
Next $5,000,000
Next $10,000,000
$20,000,000 or above
Annual Maximum Fee*
1.00%
0.80%
0.60%
0.40%
0.20%
*This is a blended tiered fee schedule. For example, the applicable management fee for a client with $2,500,000
would be as follows: the first $1,000,000 would be billed at an annual rate of 1.00%; and, the next $1,500,000
would be billed at an annual rate of 0.80%.
We reserve the right to negotiate fixed percentage of assets fee not to exceed 1% of the portfolio
balance. We may house-hold accounts to secure lower fees, which may extend to related clients not
part of the same house-hold but are family.
Our fees are based upon your assets under management as set forth in the above fee schedule. We
may charge fees either monthly in arrears or quarterly in arrears depending on the client account. In
all instances the client agreement will evidence the terms of relationship, including when fees are due
and payable. Fees typically will be deducted from the client's account(s) monthly (quarterly for annuity
assets) within ten (10) days following the end of the month or quarter for which said fees will be
incurred. Our fees are calculated by multiplying the assets under management by the relevant percent
and dividing such product by twelve (12) for accounts payable monthly or four (4) for accounts payable
quarterly. Accounts opened in mid-month or mid-quarter will be assessed at a pro-rated management
fee. Fees for the initial month or quarter will be adjusted pro-rata based upon the number of calendar
days in the respective calendar month or quarter that the Agreement goes into effect. All advisory fees
are negotiable.
At the inception of portfolio management services, the first pay period’s fees will be calculated on a
pro-rata basis. The portfolio management agreement between the Client and BAM will continue in
effect until either party terminates in accordance with the terms of the portfolio management
agreement. You will incur a pro rata charge for services rendered prior to the termination of the
portfolio management agreement, which means you will incur advisory fees only in proportion to the
number of days in the quarter for which you are a client.
Fees are subject to change with 30 days' written notice. Notwithstanding the above, certain clients of
our firm with pre-existing relationships may initially be charged fees, which are less than those set out
above. Concerning employee-related accounts and certain other accounts; our advisory fees may be
less, depending upon a number of factors, including portfolio size, length of employment and
relationship to the employee. Either party may terminate the Portfolio Management agreement upon
written notice. You will be entitled to a pro-rata refund of any pre-paid monthly fee based upon the
number of days remaining in the month after termination.
Form ADV Part 2A Brochure
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Financial Planning and Consulting Services
We charge a fixed fee ranging up to $5,000 for financial planning and consulting services. Typically, the
first half of the fee is due in advance of services rendered with the remaining balance payable upon
completion of the contracted services. Clients may terminate their Financial Planning agreement within
three days of the date of acceptance without penalty. After the three-day period, the initial plan
development fee is non-refundable. For the remaining balance, the Client may terminate the plan
development process but then they will incur a pro rata charge for the services actually rendered prior
to such termination, not to exceed six (6) hours of assessed time at an hourly rate up to $250 per hour.
Either party may terminate the agreement by written notice to the other. Any unearned fees will be
refunded to the client upon termination.
Additional Fees and Expenses
As described above, the fees are charged as described and are not based on a share of capital gains of
the funds of any advisory Client. All fees paid to BAM for investment advisory services are separate
and distinct from the fees and expenses charged to shareholders by mutual funds or exchange traded
funds. These fees and expenses are described in each fund's prospectus. These fees generally include a
management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales
charges, you may pay an initial or deferred sales charge. Clients should review the fees charged by the
funds and the fees charged by BAM to fully understand the total amount of fees charged and to
evaluate the cost of advisory services being provided.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s
assets. Side-by-side management refers to managing accounts that pay performance-based fees
alongside those that do not pay performance-based fees. Our firm and Associated Persons do not
accept performance-based fees.
Types of Clients - Item 7
We provide our investment advisory services to individuals and high net worth individuals, pension and
profit-sharing plans (retirement plans), trusts, estates, charitable organizations, corporations, and
other business entities.
In general, we do not require a minimum dollar amount to open and maintain an advisory account;
however, we have the right to terminate your account if it falls below a minimum size which, in our sole
opinion, is too small to manage effectively.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
Our investment strategies and advice may vary depending on your specific financial situation. As such,
we determine investments and allocations based on your predefined objectives, risk tolerance, time
Form ADV Part 2A Brochure
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horizon, financial horizon, financial information, liquidity needs, and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio.
We may use one or more of the following methods of analysis when providing investment advice to
you:
• Fundamental Analysis – Fundamental analysis is a method of evaluating a company or security
by attempting to measure its intrinsic value. In other words, trying to determine a company’s
or a security’s true value by looking at all aspects of the business, including both tangible factors
(e.g., machinery buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand”
names, etc.). Fundamental analysis also involves examining related economic factors (e.g.,
overall economy and industry conditions, etc.), financial factors (e.g., company debt, interest
rates, management salaries, and bonuses, etc.), qualitative factors (e.g., management
expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity
and price-to-equity ratios). The end goal of performing fundamental analysis is to produce a
value that an investor can compare with the security's current price in hopes of determining
what sort of position to take with that security (underpriced = buy, overpriced = sell or short).
This method of security analysis is considered the opposite of technical analysis. Fundamental
analysis is about using real data to evaluate a security's value. Although most analysts use
fundamental analysis to value stocks, this method of valuation can be used for just about any
type of security. The risk associated with fundamental analysis is that information obtained
may be incorrect and the analysis may not provide an accurate estimate of earnings, which may
be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing
fundamental analysis may not result in favorable performance.
We may use one or more of the following investment strategies when advising you on investments:
investments
• Long-Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year. Using
a long-term purchase strategy generally assumes the financial markets will go up in the long
term which may not be the case. There is also the risk that the segment of the market that you
are invested in or perhaps just your particular investment will go down over time even if the
overall financial markets advance. Purchasing
long-term may create an
opportunity cost - "locking up" assets that may be better utilized in the short-term in other
investments.
• Short-Term Purchases – securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the
securities' short-term price fluctuations. Using a short-term purchase strategy generally
assumes that we can predict how financial markets will perform in the short term which may
be very difficult and will incur a disproportionately higher amount of transaction costs
compared to long-term trading. Many factors can affect financial market performance in the
short term (such as short-term interest rate changes, cyclical earnings announcements, etc.)
but may have a smaller impact over longer periods of time.
Investing in securities involves the risk of loss that clients should be prepared to bear. Clients should
fully understand the nature of the contractual relationship(s) into which they are entering and the
Form ADV Part 2A Brochure
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extent of their risk exposure. Certain investment strategies may not be suitable for many members of
the public. You should carefully consider whether the strategies employed would be appropriate for
you in light of your experience, objectives, financial resources, and other relevant circumstances.
Recommendation of Particular Types of Securities
As disclosed under the “Advisory Business” section in this brochure, we primarily offer advice on equity
securities, corporate debt securities, mutual fund shares, and exchange traded funds. Additionally, we
may advise you on any type of investment that we deem appropriate based on your stated goals and
objectives. Each type of security has its own unique set of risks associated with it and it would not be
possible to list here all of the specific risks of every type of investment. Even within the same type of
investment, risks can vary widely. However, in very general terms, the higher the anticipated return of
an investment, the higher the risk of loss associated with it.
General Investment Risk: All investments come with the risk of losing money. Investing involves
substantial risks, including complete possible loss of principal plus other losses and may not be suitable
for many members of the public. Investments, unlike savings and checking accounts at a bank, are not
insured by the government to protect against market losses. Different market instruments carry
different types and degrees of risk and you should familiarize yourself with the risks involved in the
particular market instruments in which you intend to invest.
Loss of Value: There can be no assurance that a specific investment will achieve its investment
objectives and past performance should not be seen as a guide to future returns. The value of
investments and the income derived may fall as well as rise and investors may not recoup the original
amount invested. Investments may also be affected by any changes in exchange control regulation, tax
laws, withholding taxes, international, political and economic developments, and governmental
economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income
securities may fall in value if interest rates change. Generally, the prices of debt securities rise when
interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually
more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the
issuer(s) may not make required interest payments. An issuer suffering an adverse change in its
financial condition could lower the credit quality of a security, leading to greater price volatility of the
security. A lowering of the credit rating of a security may also offset the security's liquidity, making it
more difficult to sell. Funds investing in lower quality debt securities are more susceptible to these
problems and their value may be more volatile.
Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to
high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible
to sell the investment at all.
Risks Associated with Investing in Equities: Investments in equities generally refer to buying shares of
stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if
the value of the stock increases. There is an innate risk involved when purchasing a stock that it may
decrease in value and the investment may incur a loss.
Form ADV Part 2A Brochure
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Risks Associated with Fixed Income: When investing in bonds, there is the risk that the issuer will
default on the bond and be unable to make payments. Further, individuals who depend on set amounts
of periodically paid income face the risk that inflation will erode their spending power. Fixed-income
investors receive set, regular payments that face the same inflation risk.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective
investment systems that pool money from many investors and invest in stocks, bonds, short-term
money market instruments, other mutual funds, other securities, or any combination thereof. The fund
will have a manager that trades the fund's investments in accordance with the fund's investment
objective. While mutual funds generally provide diversification, risks can be significantly increased if
the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates on a particular
type of security (i.e., equities) rather than balancing the fund with different types of securities. The
returns on mutual funds can be reduced by the costs to manage the funds. In addition, while some
mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds do
charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in ETFs carries the risk of
capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in
these securities are not guaranteed or insured by the FDIC or any other government agency. Detailed
information about the risks associated with each ETF is provided in the relevant ETF’s prospectus.
Cryptocurrency Risk*: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”,
“digital currency,” or “digital assets,” is designed to act as a medium of exchange. Cryptocurrency is an
emerging asset class. There are thousands of cryptocurrencies, the most well-known of which is bitcoin.
Certain of the firm’s clients may have exposure to bitcoin or another cryptocurrency, directly or
indirectly through an investment such as an ETF or other investment vehicles. Cryptocurrency operates
without central authority or banks and is not backed by any government. Cryptocurrencies may
experience very high volatility and related investment vehicles may be affected by such volatility. As a
result of holding cryptocurrency, certain of the firm’s clients may also trade at a significant premium or
discount to NAV. Cryptocurrency is also not legal tender. Federal, state or foreign governments may
restrict the use and exchange of cryptocurrency, and regulation in the U.S. is still developing. The
market price of many cryptocurrencies, including bitcoin, has been subject to extreme fluctuations. If
cryptocurrency markets continue to be subject to sharp fluctuations, investors may experience losses
if the value of the client’s investments decline. Similar to fiat currencies (i.e., a currency that is backed
by a central bank or a national, supra-national or quasi-national organization), cryptocurrencies are
susceptible to theft, loss and destruction. Cryptocurrency exchanges and other trading venues on which
cryptocurrencies trade are relatively new and, in most cases, largely unregulated and may therefore be
more exposed to fraud and failure than established, regulated exchanges for securities, derivatives and
other currencies. The SEC has issued a public report stating U.S. federal securities laws require treating
some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers or malware. Due to relatively recent launches, most cryptocurrencies have a limited
trading history, making it difficult for investors to evaluate investments. Generally, cryptocurrency
transactions are irreversible such that an improper transfer can only be undone by the receiver of the
Form ADV Part 2A Brochure
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cryptocurrency agreeing to return the cryptocurrency to the original sender. Digital assets are highly
dependent on their developers and there is no guarantee that development will continue or that
developers will not abandon a project with little or no notice. Third parties may assert intellectual
property claims relating to the holding and transfer of digital assets, including cryptocurrencies, and
their source code. Any threatened action that reduces confidence in a network’s long-term ability to
hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are
uncertain and an investment in cryptocurrency may produce income that is not treated as qualifying
income for purposes of the income test applicable to regulated investment companies. Certain
cryptocurrency investments may be treated as a grantor trust for U.S. federal income tax purposes, and
an investment by the firm’s clients in such a vehicle will generally be treated as a direct investment in
cryptocurrency for tax purposes and “flow-through” to the underlying investors.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us or the integrity of our management.
There is no history of reportable material legal or disciplinary events by our firm or our management
persons.
Other Financial Industry Activities or Affiliations - Item 10
We do not have any relationship or arrangement that is material to our advisory business or to our
clients with any of the types of entities listed below.
• broker-dealer, municipal securities dealer, or government securities dealer or broker;
• investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or "hedge fund," and
offshore fund);
• other investment adviser or financial planner;
• futures commission merchant, commodity pool operator, or commodity trading adviser;
• banking or thrift institution;
• lawyer or law firm;
• pension consultant;
• real estate broker or dealer; and/or,
• sponsor or syndicator of limited partnerships.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our firm.
Form ADV Part 2A Brochure
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Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary
duties of honesty, good faith, and fair dealing with you. All persons associated with our firm are
expected to adhere strictly to these guidelines. Persons associated with our firm are also required to
report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the phone
number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend
to you or securities in which you are already invested. A conflict of interest exists in such cases because
we could be in a position to trade ahead of you and potentially receive more favorable prices than you
will receive. In efforts to mitigate this conflict of interest, it is our policy that neither our firm nor
persons associated with our firm shall have priority over your account in the purchase or sale of
securities. As a fiduciary, it is our firm's obligation to act in our client's best interest.
Brokerage Practices - Item 12
Brokerage Recommendations
For clients engaging our firm for portfolio management services, we typically require clients to open
one or more custodial accounts in their own name at a qualified custodian that we have a relationship,
such as Fidelity Brokerage Services, LLC ("Fidelity"). If you do not direct our firm to execute transactions
through a qualified custodian to whom we have an existing relationship with, we reserve the right to
not accept your account.
In recommending a broker dealer we will endeavor to select those brokers or dealers that will provide
quality services at reasonable fees. The reasonableness of such fees is based on several factors,
including the broker's ability to provide professional services, competitive commission rates, volume
discounts, execution price negotiations, the custodian's reputation, execution capabilities, and
responsiveness to our clients. We believe that Fidelity provides quality execution services based on
factors noted above.
Research and Other Soft Dollar Benefits
As a registered investment adviser, we may have access to research products and services from your
account custodian and/or other brokerage firms. These products may include financial publications,
information about particular companies and industries, research software, and other products or
services that provide lawful and appropriate assistance to our firm in the performance of our
investment decision-making responsibilities. Such research products and services are provided to all
investment advisers that utilize the service platforms of these firms and considered a benefit to our
Form ADV Part 2A Brochure
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firm, but are not considered to have been paid with soft dollars. To the extent our firm receives any
research products and/or services from your acting custodian/broker-dealer, a conflict of interest arises
in that such research and/or services might not directly benefit client accounts. In effort to mitigate this
conflict of interest it is our firm's policy to use such research or services to assist in making investment
decisions on behalf of client accounts or to assist with our overall responsibility for servicing client
accounts, respectively. Clients should also be aware that the commissions charged by a particular
broker-dealer for a particular transaction or set of transactions may be greater than the amounts
another broker who did not provide research services or products might charge. As a registered
investment adviser our firm and representatives of our firm have a fiduciary duty to act in our client's
best interest.
Trade Errors
In the event a trading error occurs in your account, and we are responsible for that error, our policy is
to restore your account to the position it should have been in had the trading error not occurred.
Depending on the circumstances, corrective actions may include canceling the trade, adjusting an
allocation, and/or reimbursing the account.
Brokerage for Client Referrals
We do not receive Client referrals from broker-dealers and custodians with which we have an
institutional advisory arrangement. Also, we do not receive other benefits from a broker-dealer in
exchange for Client referrals.
Block Trades
We may combine multiple orders for shares of the same securities purchased for advisory accounts we
manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of
the shares to participating accounts in a fair and equitable manner. The distribution of the shares
purchased is typically proportionate to the size of the account, but it is not based on account
performance or the amount or structure of management fees. Subject to our discretion regarding
factual and market conditions, when we combine orders, each participating account pays an average
price per share for all transactions and pays a proportionate share of all transaction costs. Accounts
owned by our firm or persons associated with our firm may participate in aggregated trading with your
accounts; however, they will not be given preferential treatment.
Review of Accounts - Item 13
Portfolio Management Services
Francis Coker (Managing Member, Owner, Investment Adviser Representative), Marco Rimassa
(Owner, Investment Adviser Representative) or the assigned Investment Adviser Representative to your
account will be responsible for monitoring your managed account(s) on an ongoing basis and
conducting account reviews (at least annually and upon your request) to ensure that the advisory
services provided to you are consistent with your stated investment needs and objectives. Additional
reviews may be conducted based on various circumstances, including, but not limited to: contributions
and withdrawals; year-end tax planning; market moving events; security specific events; and/or,
changes in your risk/return objectives.
Form ADV Part 2A Brochure
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You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s).
Financial Planning and Consulting Services
For financial planning and consulting services, please refer to the Agreement that you sign with our firm
for more details on any account reviews that we may perform as part our engagement.
Client Referrals and Other Compensation - Item 14
BAM has brokerage and clearing arrangements with Fidelity and we may receive additional benefits
from Fidelity in the form of electronic delivery of Client information, electronic trading platforms,
institutional trading support, proprietary and/or third-party research, continuing education, practice
management advice, and other services provided by custodians for the benefit of investment advisory
Clients. Please refer to Item 12 above for more information about the receipt of additional benefits
from broker-dealers/account custodians.
Custody - Item 15
Where we directly debit your account(s) for the payment of our advisory fees, BAM is deemed to
exercise “limited” custody over your funds or securities. We do not have physical custody of any of your
funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other
independent, qualified custodian, such as Fidelity. You will receive account statements from the
independent, qualified custodian(s) holding your funds and securities at least quarterly. The account
statements from your custodian(s) will indicate the amount of our advisory fees deducted from your
account(s) each billing period. The custodian holding Client assets will not verify the calculation of the
advisory fees. You should carefully review account statements for accuracy. If you have questions
regarding your account or if you did not receive a statement from your custodian, please contact us.
With respect to third party standing letters of authorization (“SLOA”) where a client grants us authority
to direct custodians to disburse funds to one or more third party accounts, we are deemed to have
custody pursuant to Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and
oversight in place to comply with the no-action letter issued by the SEC on February 21, 2017 (the “SEC
no-action letter”). We are not required to comply with the surprise examination requirements of the
Custody Rule if we comply with the representations noted in the SEC no-action letter. Where our firm
acts pursuant to a SLOA, we believe we are making a good faith effort to comply with the
representations noted in the SEC no-action letter. Additionally, since many of the representations
noted in the SEC no-action letter involve the qualified custodian’s operations, we will collaborate
closely with our custodian(s) to ensure that the representations are met.
Investment Discretion - Item 16
BAM offers portfolio management services on a discretionary basis only. Clients must grant
discretionary authority in the management agreement. Discretionary authority extends to the types
Form ADV Part 2A Brochure
Page 15
and amounts of securities to be bought and sold in Client accounts. Apart from the ability to withdraw
management fees, BAM does not have the ability to withdraw funds or securities from the Client’s
account. The Client provides BAM discretionary authority via a limited power of attorney in the
management agreement and in the contract between the Client and the custodian. If you wish, you
may limit our discretionary authority, for example, by setting a limit on the type of securities that can
be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please
refer to the “Advisory Business” section in this brochure for more information on our discretionary
management services.
Voting Client Securities - Item 17
BAM does not vote proxies. It is the Client's responsibility to vote proxies. Clients will receive proxy
materials directly from the custodian. Questions about proxies may be made via the contact
information on the cover page of this brochure.
Financial Information - Item 18
In this section, we are required to provide you with certain financial information or disclosures about
BAM’s, financial condition. BAM does not require the prepayment of over $1,200, six or more months
in advance. Additionally, BAM has no financial commitment that impairs its ability to meet contractual
and fiduciary commitments to Clients, and it has not been the subject of a bankruptcy proceeding of
this brochure.
IRA Rollover Services Disclosure
In conjunction with the advisory services offered, we may provide recommendations related to the
rollover of funds from an employer sponsored retirement plan. A plan participant leaving employment
has several options with respect to their employer sponsored retirement plans. Each choice offers
advantages and disadvantages, depending on desired investment options and services, fees and
expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's
unique financial needs and different retirement plans. The complexity of these choices may lead an
investor to seek assistance from us.
When our firm or our Associated Person(s) recommends to an investor to roll over plan assets into an
Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset-based fee
as a result. In most cases, we do not receive an asset-based fee if assets are retained in the plan. Often,
account fees and expenses will increase because fees will apply to assets rolled over to an IRA and
ongoing services will be extended to these assets. Thus, while there is arguably an economic incentive
to encourage an investor to roll over plan assets into an IRA, we cannot and do not place our interests
ahead of yours.
Form ADV Part 2A Brochure
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A rollover may also result in the assessment of other levels of fees and expenses, including, but not
limited to, investment-related expenses imposed by other service providers and mutual fund managers
not affiliated with us, as well as other fees and expenses charged by the custodian, third-party
administrator, and/or record-keeper. We make no representations or warranties relating to any costs
or expenses associated with the services provided by any third parties, and you understand that these
fees are in addition to the fee paid to us for the rollover advice.
In cases where we provide you with rollover advice as defined by the Department of Labor, which may
also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and
we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential
liabilities in connection with assets not related to the rollover and investments that are not managed
by us. When we provide 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. The way we make money creates some conflicts with your interests. In accordance with
various rules and regulations, we must act in your best interest and we must not put our interests ahead
of your interests. Additionally, we must: meet a professional standard of care when making investment
recommendations (give prudent advice); never put our financial interests ahead of yours when making
recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and
investments; follow polices, and procedures designed to ensure that we give advice that is in your best
interest; charge no more than is reasonable for our services; and give you basic information about any
conflicts of interest.
We rely on all information you provide to us, whether financial or otherwise, without independent
verification. We request that you promptly notify us in writing of any material change in the financial
and other information provided to us, and to promptly provide any such additional information as may
be reasonably requested by us.
Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future
performance, any specific level of performance, or the success of any recommendations or strategies
that we may take or recommend for you, or the success of our overall recommendations. Investment
recommendations are subject to various market, currency, economic, political, and business risks, and
that investment decisions will not always be profitable.
Form ADV Part 2A Brochure
Page 17
Privacy Policy Notice
Beaumont Asset Management, L.L.C. has adopted this privacy policy with recognition that protecting the privacy
and security of the personal information we obtain about our customers is an important responsibility. We also
know that you expect us to service you in an accurate and efficient manner. To do so, we must collect and maintain
certain personal information about you. We want you to know what information we collect and how we use and
safeguard that information.
Information We Collect: We collect certain nonpublic information about you ("Customer Information"). The
essential purpose for collecting Customer Information is to allow us to provide advisory services to you. Customer
Information we collect may include:
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Information that you provide on applications or other forms. This Customer Information may include
personal and household information such as income, spending habits, investment objectives, financial
goals, statements of account, and other records concerning your financial condition and assets, together
with information concerning employee benefits and retirement plan interests, wills, trusts, mortgages
and tax returns.
Identifying information such as your name, age, address, social security number, etc.
Information about your transactions with us, or others (e.g., broker-dealers, clearing firms, or other
chosen investment sponsors).
Information we receive from consumer reporting agencies (e.g., credit bureaus), as well as other various
materials we may use to provide an appropriate recommendation or to fill a service request.
Security of Your Information: We restrict access to your nonpublic personal information to those employees who
need to know that information to service your account. We maintain physical, electronic and procedural
safeguards that comply with applicable federal or state standards to protect your nonpublic personal information.
Information We Disclose: We do not disclose the nonpublic personal information we collect about our customers
to anyone except: (i) in furtherance of our business relationship with them and then only to those persons
necessary to effect the transactions and provide the authorized services (such as broker-dealers, custodians,
independent managers etc.); (ii) to persons assessing our compliance with industry standards (e.g., professional
licensing authorities, consultants, etc.); (iii) our attorneys, accountants, and auditors; or (iv) as otherwise provided
by law. We are permitted by law to disclose the nonpublic personal information about you to governmental
agencies and other third parties in certain circumstances (such as third parties that perform administrative or
marketing services on our behalf or for joint marketing programs). These third parties are prohibited to use or
share the information for any other purpose.
Former Clients: If you decide to close your account(s) or become an inactive customer, we will adhere to our
privacy policies, which may be amended from time to time.
Changes to Our Privacy Policy: In the event there were to be a material change to our privacy policy regarding
how we use your confidential information, we will provide written notice to you. Where applicable, you would be
given an opportunity to limit or opt-out of such disclosure arrangements.
Questions: If you have questions about this privacy notice or about the privacy of your customer information,
please contact us at 409-899-9569.