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Bourne Lent Asset Management, Inc.
Form ADV Part 2A – Disclosure Brochure
Effective: January 28, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Bourne Lent Asset Management, Inc. (“Bourne Lent” or the “Advisor”). If you have any questions about
the content of this Disclosure Brochure, please contact the Advisor at (845) 855-1590 or by email at
lisa@bournelent.com.
Bourne Lent is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about Bourne Lent to assist you in determining whether to retain the Advisor.
Additional information about Bourne Lent and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 111114.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Bourne Lent. For convenience, the Advisor has combined these documents into a single disclosure
document.
Bourne Lent believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Bourne Lent encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 5, 2026.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 111114. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (845) 855-1590 or by
email at lisa@bournelent.com.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 5
D. Wrap Fee Programs ........................................................................................................................................................ 5
E. Assets Under Management ............................................................................................................................................. 5
Item 5 – Fees and Compensation ......................................................................................................................... 5
A. Fees for Advisory Services.............................................................................................................................................. 5
B. Fee Billing........................................................................................................................................................................ 6
C. Other Fees and Expenses .............................................................................................................................................. 6
D. Advance Payment of Fees and Termination ................................................................................................................... 6
E. Compensation for Sales of Securities ............................................................................................................................. 7
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 7
Item 7 – Types of Clients ....................................................................................................................................... 7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 7
A. Methods of Analysis ........................................................................................................................................................ 7
B. Risk of Loss ..................................................................................................................................................................... 7
Item 9 – Disciplinary Information .......................................................................................................................... 8
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 9
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 9
A. Code of Ethics ................................................................................................................................................................. 9
B. Personal Trading with Material Interest ........................................................................................................................... 9
C. Personal Trading in Same Securities as Clients ............................................................................................................. 9
D. Personal Trading at Same Time as Client ...................................................................................................................... 9
Item 12 – Brokerage Practices .............................................................................................................................. 9
A. Recommendation of Custodian[s] ................................................................................................................................... 9
B. Aggregating and Allocating Trades ............................................................................................................................... 10
Item 13 – Review of Accounts ............................................................................................................................. 10
A. Frequency of Reviews ................................................................................................................................................... 10
B. Causes for Reviews ...................................................................................................................................................... 11
C. Review Reports ............................................................................................................................................................. 11
Item 14 – Client Referrals and Other Compensation ........................................................................................ 11
A. Compensation Received by Bourne Lent ...................................................................................................................... 11
B. Compensation for Client Referrals ................................................................................................................................ 12
Item 15 – Custody ................................................................................................................................................. 12
Item 16 – Investment Discretion ......................................................................................................................... 12
Item 17 – Voting Client Securities ....................................................................................................................... 12
Item 18 – Financial Information ........................................................................................................................... 12
Privacy Policy ....................................................................................................................................................... 19
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Bourne Lent Asset Management, Inc. (“Bourne Lent” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a corporation under the laws of
the State of New Jersey. The Advisor has been in business since 1983. The original name of the firm was Bourne
Management Inc. In 1998, Bourne Management Inc. invested in Bourne Fissell & Stenstrom, LLC which was closed
in June of 2000. In July of 2000, the name of the firm was changed to Bourne Stenstrom Capital Management, Inc.
and in 2008 the firm's name was changed to, Bourne Stenstrom Lent Asset Management, Inc. In 2015, the Firm's
name was changed to Bourne Lent Asset Management, Inc. Bourne Lent is owned and operated by Donald Bourne
(President) and John Lent (Portfolio Manager, Secretary and Chief Compliance Officer). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by Bourne
Lent.
B. Advisory Services Offered
Bourne Lent offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and municipal entities (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Bourne Lent's fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
Bourne Lent provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. Bourne Lent works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Bourne Lent will then construct an investment
portfolio, primarily consisting of individual equities and individual bonds. The Advisor may also utilize exchange-
traded funds (“ETFs”) or mutual funds to achieve the Client’s investment goals. to meet the needs of its Clients.
The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall
portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
Bourne Lent’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Bourne Lent will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Bourne Lent evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Bourne Lent may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Bourne Lent may recommend specific positions to increase sector or asset class weightings. The Advisor
may recommend employing cash positions as a possible hedge against market movement. Bourne Lent may
recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 4
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
At no time will Bourne Lent accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
C. Client Account Management
Prior to engaging Bourne Lent to provide investment advisory services, each Client is required to enter into a
written agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor
and the Client. These services may include:
• Establishing an Investment Strategy – Bourne Lent, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Bourne Lent will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Bourne Lent will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – Bourne Lent will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Bourne Lent does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Bourne Lent.
E. Assets Under Management
As of December 31, 2025, Bourne Lent manages $ 343,920,884 in Client assets, $341,633,900 of which are
managed on a discretionary basis and $2,286,984 on a non-discretionary basis. Clients may request more current
information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, either in advance or at the end of each calendar quarter, pursuant to the
terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the calendar quarter, or prior calendar quarter. Investment advisory fees are based on the
following schedule:
Annual Rate (%)
Assets Under Management ($)
Up to $2,000,000
Over $2,000,000
1.00%
0.60%
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. Certain legacy clients may be
billed under a different fee schedule. The Client’s fees will take into consideration the aggregate assets under
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 5
management with the Advisor. All securities held in accounts managed by Bourne Lent will be independently valued
by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning or end of the respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4) to the total assets under management with Bourne Lent at the end of the prior
quarter, or each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the
Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees.
Clients provide written authorization permitting advisory fees to be deducted by Bourne Lent to be paid directly from
their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms
provided by the Custodian.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Bourne Lent, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for
mutual funds and other types of investments. The fees charged by Bourne Lent are separate and distinct from
these custody and execution fees.
In addition, all fees paid to Bourne Lent for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of Bourne
Lent, but would not receive the services provided by Bourne Lent which are designed, among other things, to assist
the Client in determining which products or services are most appropriate for each Client’s financial situation and
objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by
Bourne Lent to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for
additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Bourne Lent may be compensated for its investment management services either in advance of the quarter in which
services are rendered or at the end of the quarter after services are provided. Either party may terminate the
investment advisory agreement, at any time, by providing advance written notice to the other party. The Client may
also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at
no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to
the point of termination and such fees will be due and payable by the Client. For services paid in advance, upon
termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of
termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable
without the Client’s prior consent.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 6
E. Compensation for Sales of Securities
Bourne Lent does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Bourne Lent does not charge performance-based fees for its investment advisory services. The fees charged by
Bourne Lent are as described in Item 5 above and are not based upon the capital appreciation of the funds or
securities held by any Client.
Bourne Lent does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Bourne Lent offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and municipal entities. Bourne Lent generally requires a minimum relationship size of
$500,000 to effectively implement its investment process, which may be waived at the Advisor’s sole discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Bourne Lent primarily employs a fundamental analysis in developing investment strategies for its Clients. Research
and analysis from Bourne Lent are derived from numerous sources, including financial media companies, third-
party research materials, Internet sources, and review of company activities, including annual reports,
prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
As noted above, Bourne Lent generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Bourne Lent will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Bourne
Lent may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or
the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Bourne Lent will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment
strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 7
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Fixed Income Risks
Fixed Income securities are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that
bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity,
and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a
lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation
increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit
default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company
defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s
downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its
debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available
market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Bourne Lent or its management persons.
Bourne Lent values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with the Advisor’s firm name or CRD# 111114.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 8
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Bourne Lent and its management persons is to provide investment advisory services to its
Clients. Neither Bourne Lent nor its Advisory Persons are involved in other business endeavors. Bourne Lent does
not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of
its Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Bourne Lent has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Bourne Lent (“Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each
Client. Bourne Lent and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client.
It is the obligation of Bourne Lent’s Supervised Persons to adhere not only to the specific provisions of the Code,
but also to the general principles that guide the Code. The Code covers a range of topics that address employee
ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (845) 855-1590 or via
email at lisa@bournelent.com.
B. Personal Trading with Material Interest
Bourne Lent allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Bourne Lent does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. Bourne Lent does not have a
material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Bourne Lent allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Bourne Lent requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Bourne Lent allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards.
At no time will Bourne Lent, or any Supervised Person of Bourne Lent, transact in any security to the
detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Bourne Lent does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Bourne Lent to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, Bourne Lent does not have the discretionary authority to negotiate commissions on behalf of Clients on a
trade-by-trade basis.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 9
Where Bourne Lent does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by Bourne Lent. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Bourne Lent may recommend the Custodian based on criteria such as,
but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and
its reputation and/or the location of the Custodian’s offices.
Bourne Lent will generally recommend that Clients establish their account[s] at Fidelity Clearing and Custody
Solutions and related divisions of Fidelity Investments, Inc., or Raymond James and Associates,
Inc., member NYSE/SIPC, each a FINRA-registered broker-dealer and members SIPC. Fidelity Investments, Inc. or
Raymond James and Associates member NYSE/SIPC will serve as the Client’s “qualified custodian”. Bourne Lent
maintains institutional relationships with Fidelity Investments, Inc. and Raymond James and Associates member
NYSE/SIPC whereby the Advisor receives economic benefits from Fidelity Investments, Inc. or Raymond James
and Associates member NYSE/SIPC. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Bourne Lent does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - Bourne Lent does not receive any compensation from any third party in connection with
the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Bourne Lent will place
trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are
traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any
security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a
security into one Client account from another Client’s account[s]). Bourne Lent will not be obligated to select
competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction
costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Bourne Lent will execute its transactions through the
Custodian as authorized by the Client. Bourne Lent may aggregate orders in a block trade or trades when
securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading
day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold
by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or
other written statement. This must be done in a way that does not consistently advantage or disadvantage any
particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by the advisory persons of Bourne
Lent, under the supervision of John Lent, Chief Compliance Officer of Bourne Lent. Formal reviews are generally
conducted at least annually or more frequently depending on the needs of the Client.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 10
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Bourne Lent if changes occur in the
Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may
be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Bourne Lent
Bourne Lent is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Bourne Lent does not receive commissions or other compensation from product sponsors, broker-dealers or
any un-related third party. Bourne Lent may refer Clients to various unaffiliated, non-advisory professionals (e.g.
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, Bourne Lent may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platforms
Raymond James and Associates member NYSE/SIPC – Bourne Lent has established institutional relationship with
Raymond James and Associates member NYSE/SIPC to assist the Advisor in managing Client account[s]. Access
to the Raymond James and Associates member NYSE/SIPC platform is provided at no charge to the Advisor. The
Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Raymond James and Associates member NYSE/SIPC.
The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties
to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware,
however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits
may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software,
systems support, or services.
Fidelity Investments, Inc. – As noted in item 12, Bourne Lent has established an institutional relationship with Fidelity
Investments, Inc. to assist the Advisor in managing Client account[s]. As part of the arrangement, Fidelity Investments,
Inc. also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage
services, including research services obtained by Fidelity Investments, Inc. directly from independent research
companies. The Advisor may also receive additional services and support from Fidelity Investments, Inc.. As a result
of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the
use of Fidelity Investments, Inc.'s services. The Advisor examined this conflict of interest when it chose to enter into
the relationship with Fidelity Investments, Inc. and has determined that the relationship is in the best interests of the
Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12
above.
The Advisor receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity Investments, Inc.. The software and related systems
support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at
all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits
from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this
Custodian over one that does not furnish similar software, systems support, or services. In addition, Fidelity
Investments, Inc. has provided the Advisor with financial support in the launch of the Advisor and reimbursements for
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 11
various third-party service providers.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16 – Investment Discretion
Bourne Lent generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to
by Bourne Lent. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of
such authority will be evidenced by the Client's execution of an investment advisory agreement containing all
applicable limitations to such authority. All discretionary trades made by Bourne Lent will be in accordance with
each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Bourne Lent may accept the authority to vote Client’s securities (i.e., proxies) on their behalf. When Bourne Lent
accepts such responsibility, it will cast proxy votes in a manner it believes is consistent with the best interest of its
Clients. At any time Clients may contact Bourne Lent to request information about how the Advisor voted proxies
for that Client’s securities.
A brief summary of Bourne Lent’s proxy voting policies and procedures is as follows: Unless there is an unusual
circumstance or an extraordinary proposal on the ballot, the shares will be voted with the management. The
Advisor believes in the management of the companies that the Advisor chooses for investments and usually vote
the shares the Advisor controls with the management’s guidance. Should there be such occurrence where the
shares are not voted with management, the principals of the firm will agree as to what the vote by Bourne Lent will
be.
Where Bourne Lent is responsible for voting proxies on behalf of a Client, the Client cannot direct the Advisor’s vote
on a particular solicitation. The Client, however, can revoke Bourne Lent’ authority to vote proxies. In situations
where there may be a conflict of interest in the voting of proxies due to business or personal relationships that
Bourne Lent maintains with persons having an interest in the outcome of certain votes, the Advisor will take
appropriate steps, to ensure that proxy voting decisions are made in what it believes is the best interest of its
Clients and are not the product of any such conflict.
Item 18 – Financial Information
Neither Bourne Lent, nor its management, have any adverse financial situations that would reasonably impair the
ability of Bourne Lent to meet all obligations to its Clients. Neither Bourne Lent, nor any of its Advisory Persons,
have been subject to a bankruptcy or financial compromise. Bourne Lent is not required to deliver a balance sheet
along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to
be performed six months or more in the future.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 12
Form ADV Part 2B – Brochure Supplement
for
Donald W. Bourne
President
Effective: January 28, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Donald W. Bourne (CRD# 4368990) in addition to the information contained in the Bourne Lent Asset Management,
Inc. (“Bourne Lent” or the “Advisor”, CRD# 111114) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Bourne Lent Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (845) 855-1590 or by email at lisa@bournelent.com.
Additional information about Mr. Bourne is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4368990.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 13
Item 2 – Educational Background and Business Experience
Donald W. Bourne, born in 1962, is dedicated to advising Clients of Bourne Lent as the President. Mr. Bourne
earned a degree in Economics from Allegheny College in 1985. Mr. Bourne Additional information regarding Mr.
Bourne’s employment history is included below.
Employment History:
President, Bourne Lent Asset Management, Inc.
01/1991 to Present
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Bourne. Mr. Bourne has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Bourne.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Bourne.
However, we do encourage you to independently view the background of Mr. Bourne on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
4368990.
Item 4 – Other Business Activities
Mr. Bourne is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Bourne does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Bourne is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Bourne does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Bourne serves as the President of Bourne Lent and is supervised by John Lent, the Chief Compliance Officer.
Lent can be reached at (845) 855-1590.
Bourne Lent has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bourne Lent. Further, Bourne Lent is subject to regulatory
oversight by various agencies. These agencies require registration by Bourne Lent and its Supervised Persons. As
a registered entity, Bourne Lent is subject to examinations by regulators, which may be announced or
unannounced. Bourne Lent is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 14
Form ADV Part 2B – Brochure Supplement
for
John J. Lent
Portfolio Manager, Secretary and Chief Compliance Officer
Effective: January 28, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John
J. Lent (CRD# 2224794) in addition to the information contained in the Bourne Lent Asset Management, Inc.
(“Bourne Lent” or the “Advisor”, CRD# 111114) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Bourne Lent Disclosure Brochure or this
Brochure Supplement, please contact us at (845) 855-1590 or by email at lisa@bournelent.com.
Additional information about Mr. Lent is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2224794.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 15
Item 2 – Educational Background and Business Experience
John J. Lent, born in 1946, is dedicated to advising Clients of Bourne Lent as a Portfolio Manager, Secretary and
Chief Compliance Officer. Mr. Lent earned an MBA from Fairleigh Dickinson in 1976 Mr. Lent also earned a
bachelors degree from Dayton College in 1968. Additional information regarding Mr. Lent’s employment history is
included below.
Employment History:
06/2006 to Present
Portfolio Manager, Secretary and Chief Compliance Officer,
Bourne Lent Asset Management, Inc.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Lent. Mr. Lent has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Lent.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Lent.
However, we do encourage you to independently view the background of Mr. Lent on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2224794.
Item 4 – Other Business Activities
Mr. Lent is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Lent does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Lent is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Lent does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Lent serves as a Portfolio Manager, Secretary and Chief Compliance Officer of Bourne Lent. Mr. Lent can be
reached at (845) 855-1590.
Bourne Lent has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bourne Lent. Further, Bourne Lent is subject to regulatory
oversight by various agencies. These agencies require registration by Bourne Lent and its Supervised Persons. As
a registered entity, Bourne Lent is subject to examinations by regulators, which may be announced or
unannounced. Bourne Lent is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 16
Form ADV Part 2B – Brochure Supplement
for
Kevin A. Stickle
Investment Advisor Representative
Effective: January 28, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Kevin
A. Stickle (CRD# 7216503) in addition to the information contained in the Bourne Lent Asset Management, Inc.
(“Bourne Lent” or the “Advisor”, CRD# 111114) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Bourne Lent Disclosure Brochure or this
Brochure Supplement, please contact us at (845) 855-1590 or by email at lisa@bournelent.com.
Additional information about Mr. Stickle is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 7216503.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 17
Item 2 – Educational Background and Business Experience
Kevin A. Stickle, born in 1996, is dedicated to advising Clients of Bourne Lent as an Investment Advisor
Representative. Mr. Stickle earned a Bachelor’s Degree from University of Arizona in 2019. Additional information
regarding Mr. Stickle’s employment history is included below.
Employment History:
Investment Advisor Representative, Bourne Lent Asset Management, Inc.
Account Executive, The Millennium Alliance
Operations Representative, Charles Schwab
Sales Agent, New York Life
Lifeguard, Borough Of Monmouth Beach
09/2023 to Present
07/2022 to 05/2023
03/2020 to 05/2022
10/2019 to 03/2020
05/2011 to 09/2019
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Stickle. Mr. Stickle has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Stickle.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Stickle.
However, we do encourage you to independently view the background of Mr. Stickle on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
7216503.
Item 4 – Other Business Activities
Mr. Stickle is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Stickle does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Stickle is dedicated to the investment advisory activities of Bourne Lent’s Clients. Mr. Stickle does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Stickle serves as an Investment Advisor Representative of Bourne Lent and is supervised by John Lent, the
Chief Compliance Officer. Mr. Lent can be reached at (845) 855-1590.
Bourne Lent has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Bourne Lent. Further, Bourne Lent is subject to regulatory
oversight by various agencies. These agencies require registration by Bourne Lent and its Supervised Persons. As
a registered entity, Bourne Lent is subject to examinations by regulators, which may be announced or
unannounced. Bourne Lent is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 18
Privacy Policy
Effective: January 28, 2026
Our Commitment to You
Bourne Lent Asset Management, Inc. (“Bourne Lent” or the “Advisor”) is committed to safeguarding the use of
personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor,
as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Bourne Lent (also referred to as "we", "our"
and "us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or servicing
of our relationship with you.
Bourne Lent does not sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management of
our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 19
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Bourne Lent does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Bourne Lent or
the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Bourne Lent does not disclose and does not intend to disclose, non-
public personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at (845) 855-1590 or via email at lisa@bournelent.com.
Bourne Lent Asset Management, Inc.
12 E. Main Street, Pawling, NY 12564
Phone: (845) 855-1590 * Fax: (845) 855-1542
www.bournelent.com
Page 20