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CRD# 151978
2915 Piedmont Road, NE
Suite B
Atlanta, Georgia 30305
(404) 442-2772
February 3, 2026 Brochure
This brochure provides information about the qualifications and business practices of Covey Capital
Advisors, LLC (“Covey Capital”). If you have any questions about the contents of this brochure, please
contact us at (404) 442-2772 or smayo@coveycap.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any state
authority.
www.AdviserInfo.sec.gov
.
Covey Capital is an investment advisory firm registered with the appropriate regulatory authority.
Registration does not imply a certain level of skill or training. Additional information about Covey
Capital also is available on the SEC’s website at
Item 2 – Summary of Material Changes
This Brochure is prepared in the revised format required beginning in 2011. Registered Investment
Advisers are required to use this format to inform clients of the nature of advisory services provided,
types of clients served, fees charged, potential conflicts of interest and other information. The
Brochure requirements include providing a Summary of Material Changes (the “Summary”)
reflecting any material changes to our policies, practices, or conflicts of interest made since our last
required “annual update” filing. In the event of any material changes, such Summary is provided to
all clients within 120 days of our fiscal year-end. Our last annual update was filed on March 20, 2025.
Of course, our complete Brochure is available to you at any time upon request.
Material changes to Covey Capital Advisors, LLC’s Part 2A since the last annual update are as follows:
No material changes.
Item 3 - Table of Contents
Page
Item 2 - Summary of Material Changes ................................................................................................. 1
Item 4 - Advisory Business ........................................................................................................................ 3
Item 5 - Fees and Compensation .............................................................................................................. 4
Item 6 - Performance-Based Fees and Side-By-Side Management ..................................................... 4
Item 7 - Types of Clients ............................................................................................................................ 4
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 5
Item 9 - Disciplinary Information............................................................................................................ 6
Item 10 - Other Financial Industry Activities and Affiliations ............................................................ 6
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 6
Item 12 - Brokerage Practices ................................................................................................................. 7
Item 13 - Review of Accounts .................................................................................................................... 9
Item 14 - Client Referrals and Other Compensation............................................................................. 9
Item 15 - Custody
Item 16 - Investment Discretion
.................................................................................................................................................................... 9
Item 17 - Voting Client Securities
................................................................................................................................... 10
Item 18 – Financial Information
………………………………………………………….………………………………….10
.................................................................................................................................. 11
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Item 4 - Advisory Business
General Information
Covey Capital Advisors, LLC (“Covey Capital”) was formed in 2007 and provides investment advisory
services on a discretionary basis to our clients, primarily individuals (including high net worth
individuals), family offices, and foundations.
Scott Mayo is the sole principal owner of Covey Capital. Please see Brochure Supplement Exhibit A
for more information on Mr. Mayo, who formulates investment advice and has discretionary
authority over client accounts.
As of December 31, 2025, Covey Capital managed $156,459,403 on a discretionary basis.
SERVICES PROVIDED
•
At the outset of each client relationship, Covey Capital spends time with the client, asking questions,
discussing the client’s investment experience and financial circumstances, and reviewing options for
the client. Based on its reviews, Covey Capital generally develops with each client:
•
a financial outline for the client based on the client’s financial circumstances and goals, and
the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments Covey Capital will make
discretionary investments on behalf of the client to meet those goals. The Profile and the Plan are
discussed regularly with each client but are not necessarily written documents.
Portfolio Management
As described above, at the beginning of our relationship, we meet with you, gather information and
perform research and analysis as necessary to develop your Investment Plan. The Investment Plan
will be updated from time to time when requested by you, or when determined to be necessary or
advisable by us based on updates to your financial or other circumstances.
Individual Retirement Advice
When Covey Capital makes investment recommendations to a client regarding a retirement plan
account or individual retirement account, Covey Capital is acting as a fiduciary 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 Covey Capital makes money or is
otherwise compensated creates some conflicts with the client’s financial interests, so Covey Capital
operates under a special rule that requires it to act in the client’s best interest and not put Covey
Capital’s interest ahead of the client.
•
Under this special rule's provisions, Covey Capital must:
•
Meet a professional standard of care when making investment recommendations (give prudent
advice) to each specified client;
Never put its financial interests ahead of the client’s when making recommendations (give loyal
advice);
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•
•
•
•
Item 5 - Fees and Compensation
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in the client’s best
interest;
Charge no more than what is reasonable for its services; and
Give basic information about its conflicts of interest.
Separately Managed Accounts
Clients pay a management fee at the rate of 1.0% per annum of the net asset value of the account, for
Covey Capital’s investment management and administrative services (the “Management Fee”).
Management fees are payable quarterly in advance and are calculated based on the value of the
account on the last day of the prior quarter. Fees are debited directly from client accounts when
authorized. Clients may contribute cash or securities into a managed account or withdraw managed
assets at any time upon notice. If management begins after the start of a quarter, fees will be prorated
according to the number of calendar days the account was managed for that quarter.
Either Covey Capital or the client may terminate their investment advisory agreement at any time,
subject to the written notice requirements in the agreement. In the event of termination, any paid
but unearned fees will be promptly refunded to the client based on the number of calendar days that
the account was managed, and any fees due to Covey Capital from the client will be invoiced or
deducted from the client’s account prior to termination.
Covey Capital may, at its discretion, make exceptions to the foregoing or negotiate special fee
arrangements where Covey Capital deems it appropriate under the circumstances.
Item 12 – Brokerage Practices
General Fee Information
Fees paid to Covey Capital are exclusive of all custodial and transaction costs paid to the client’s
custodian, brokers or other third-party consultants. Please see
for
additional information. Fees paid to Covey Capital are also separate and distinct from the fees and
expenses charged by mutual funds, ETFs (exchange-traded funds) or other investment pools to their
shareholders (generally including a management fee and fund expenses, as described in each fund’s
prospectus or offering materials). The client should review all fees charged by funds, brokers, Covey
Capital and others to fully understand the total amount of fees paid by the client for investment and
financial-related services.
Item 6 - Performance-Based Fees and Side-By-Side Management
At this time, Covey Capital does not offer any performance-based fee arrangements. “Side by Side
Management” refers to a situation in which the same firm manages accounts that are billed based on
a percentage of assets under management and at the same time manages other accounts for which
fees are assessed on a performance fee basis. Because Covey Capital has no performance-based fee
Item 7 - Types of Clients
accounts, it has no side-by-side management.
Covey Capital provides discretionary investment advisory services to high net worth individuals,
family partnerships, foundations, charitable organizations, or other sophisticated investors. With
some exceptions, the minimum portfolio value eligible for such investment advisory services is
$1,000,000. Minimum annual fees may apply. Under certain circumstances and in its sole discretion,
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Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Covey Capital may negotiate such minimums.
Methods of Analysis and Investment Strategies
When consistent with the objectives and risk tolerance levels of a client, Covey Capital invests client
accounts via a separately managed account in individual stocks, ETFs, and fixed income instruments.
Additional investment types are considered for appropriateness as authorized in each client’s
investment advisory agreement.
Covey Capital’s investment philosophy is predicated on the belief that fundamental research and
analysis along with sound judgment should drive favorable investment outcomes over time. Covey
Capital evaluates the current intrinsic value of a security, as well as the expected rate at which
intrinsic value may grow over time. This is generally accomplished through a variety of analytical
approaches, both qualitative and quantitative. Covey will seek to identify and invest in opportunities
that it believes exhibit discrepancies between current trading prices and the true intrinsic value of
the security, resulting in a favorable expected return scenario. Covey believes that a portfolio of
investments acquired at a discount to intrinsic value should provide a margin of safety reducing the
likelihood of a permanent loss of invested capital while creating the opportunity for generation of
positive absolute returns. Intrinsic value is highly dynamic over time based on qualitative and
quantitative inputs.
Risk of Loss
While Covey Capital seeks to diversify clients’ investment portfolios across the equities markets in
an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can
be no assurance that client investment portfolios will be able to fully meet their investment objectives
and goals, or that investments will not incur losses.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks.
While Covey Capital manages client investment portfolios based on Covey
Capital’s experience, research and proprietary methods, the value of client investment portfolios will
change daily based on the performance of the underlying securities in which they are invested.
Accordingly, client investment portfolios are subject to the risk that Covey Capital allocates assets to
asset classes that are adversely affected by unanticipated market movements, and the risk that Covey
Capital’s specific investment choices could not meet investment objectives.
Covey Capital selects various types of investments, generally described below, depending on the
identified investment objectives of each client.
Equity Market Risks.
Covey Capital may invest portions of client assets directly into equity
investments, primarily stocks, or into pooled investment funds that invest in equity securities. Risks
associated with these investments include, without limitation, the risks that stock values will decline
due to daily fluctuations in the markets, and that stock values will decline over longer periods (e.g.,
bear markets) due to general market declines in the stock prices for all companies, regardless of the
prospects of any individual security.
Risks of Investments in ETFs and Other Investment Pools.
As described above, Covey Capital may invest
client portfolios in ETFs and other investment pools (“pooled investment funds”). Investments in
pooled investment funds are generally less risky than investing in individual securities because of
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their diversified portfolios; however, these investments are still subject to risks associated with the
markets in which they invest. In addition, pooled investment funds’ success will be related to the
skills of their particular managers and their performance in managing their funds. Pooled investment
funds are also subject to risks due to regulatory restrictions applicable to registered investment
Fixed Income Risks.
companies under the Investment Company Act of 1940.
Covey Capital may invest portions of client assets directly into fixed income
instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds
and notes. While investing in fixed income instruments, either directly or through pooled investment
funds, is generally less volatile than investing in stock (equity) markets, fixed income investments
nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks
that changes in interest rates will devalue the investments), credit risks (risks of default by
borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance
to maturity).
Foreign Securities Risks.
Covey Capital may invest in non-U.S. markets and securities, and may also
take positions in non-U.S. currencies. Investments in non-U.S. instruments involve risks and
considerations not present in U.S. investments. Currency exchange rates can be affected
unpredictably by controls or restrictions imposed by U.S. or foreign central banks or other
governmental agencies in joint or unilateral efforts to alter exchange rate trends. Political
developments in the United States or abroad may also affect currency exchange rates. There may be
less publicly available information about foreign companies than U.S. companies. Non-U.S.
companies may not be subject to accounting, auditing, and financial reporting standards, practices
and requirements comparable to those applicable to U.S. companies. Non-U.S. investment may be
less liquid and more volatile than U.S. investments. In many non-U.S. markets there may be less
government supervision of exchanges, brokers and issuers than in the United States.
Item 9 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of Covey Capital or the integrity of
Item 10 - Other Financial Industry Activities and Affiliations
Covey Capital’s management.
Covey Capital has no disciplinary events to report.
Neither Covey Capital nor its Management Person has any other financial industry activities or
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
affiliations to report.
Code of Ethics and Personal Trading
Covey Capital has adopted a Code of Ethics (“the Code”), the full text of which is available to any client
upon request. Covey Capital’s Code has several goals. First, the Code is designed to assist Covey
Capital in complying with applicable laws and regulations governing its investment advisory
business. Under the Investment Advisers Act of 1940, Covey owes fiduciary duties to its clients.
Pursuant to these fiduciary duties, the Code requires persons associated with Covey Capital
(managers, officers and employees) to act with honesty, good faith and fair dealing in working with
clients. In addition, the Code prohibits such associated persons from trading or otherwise acting on
insider information.
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Next, the Code sets forth guidelines for professional standards for Covey Capital’s associated persons.
Under the Code’s Professional Standards, Covey Capital expects its associated persons to put the
interests of its clients first, ahead of personal interests. In this regard, Covey Capital associated
persons are not to take inappropriate advantage of their positions in relation to Covey Capital clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time Covey Capital’s associated persons may invest in
the same securities recommended to clients. Under its Code, Covey Capital has adopted procedures
designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s
personal trading policies include procedures for limitations on personal securities transactions of
associated persons, reporting and review of such trading. These policies are designed to discourage
and prohibit personal trading that would disadvantage clients.
Participation or Interest in Client Transactions
As outlined above, Covey Capital has adopted procedures to protect client interests when its
associated persons invest in the same securities as those selected for or recommended to clients. In
the event of any identified potential trading conflicts of interest, Covey Capital’s goal is to place client
interests first.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and
the trade is not filled in its entirety, the associated person’s shares will be allocated pro rata with
other client accounts in accordance with Covey Capital’s written policy.
Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, we
seek “best execution” for your trades, which includes a combination of factors, without limitation,
quality of execution, services provided and commission rates. Therefore, we may use or recommend
the use of brokers who do not charge the lowest available commission in the recognition of research
and securities transaction services, or quality of execution. Research services received with
transactions may include proprietary or third-party research (or any combination) and may be used
in servicing any or all of our clients. Therefore, research services received may not be used for the
account for which the particular transaction was affected.
Covey Capital recommends that you establish a brokerage account with the Schwab Advisor Services
division of Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer, member SIPC to
maintain custody of your assets. We may also place trades for your accounts at Schwab, or may in
some instances, consistent with our duty to seek best execution and specific agreement with each
client, elect to execute trades elsewhere. Although we may recommend that each client establish an
account at Schwab, it is ultimately your decision as to where the assets are held in custody. Covey
Capital is independently owned and operated and is not affiliated with Schwab or any other qualified
custodian.
Schwab provides us with access to their institutional trading and custody services, which are
typically not available to Schwab’s retail investors. These services generally are available to
independent investment advisers on an unsolicited basis, at no charge to them. Schwab’s brokerage
services include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors or
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would require a significantly higher minimum initial investment. These services are not soft dollar
arrangements, but are part of the institutional platform offered by Schwab.
For our client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions and other transaction-
related or asset-based fees for securities trades that are executed through Schwab or that settle into
Schwab accounts. Schwab is also compensated by earning interest on uninvested cash in your
account. Schwab Advisor Services also makes available to Covey Capital other products and services
that benefit us but may not directly benefit our clients’ accounts. Many of these products and services
may be used to service all or some substantial number of Covey accounts, including accounts not
maintained at Schwab.
Schwab’s products and services that assist Covey Capital in managing and administering your
accounts include software and other technology that (i) provide access to client account data (such
as trade confirmations and account statements); (ii) facilitate trade execution and allocate
aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market
data; (iv) facilitate payment of our fees from your accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
The benefits received through participation in these programs do not necessarily depend upon the
proportion of transactions directed to Schwab. The benefits are received by Covey Capital, in part
because of commission revenue generated for Schwab by our clients. This means that the investment
activity in client accounts is beneficial to us, because Schwab does not assess a fee to Covey Capital
for these services. This creates an incentive for us to continue to recommend Schwab to our clients.
While it may be possible to obtain similar custodial, execution and other services elsewhere at a
lower cost, we believe that Schwab provides an excellent combination of these services.
Directed Brokerage
Clients may direct Covey Capital to use a particular broker for custodial or transaction services on
behalf of the client’s portfolio. In directed brokerage arrangements, the client is responsible for
negotiating the commission rates and other fees to be paid to the broker. Accordingly, a client who
directs brokerage should consider whether such designation may result in certain costs or
disadvantages to the client, either because the client may pay higher commissions or obtain less
favorable execution, or the designation limits the investment options available to the client.
The arrangements that Covey Capital has with Schwab is designed to maximize efficiency and to be
cost effective. By directing brokerage arrangements, the client acknowledges that these economies
of scale and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that a client chooses to use the brokerage
and/or custodial services of these alternative service providers may in fact result in a certain degree
of delay in executing trades for their account(s) and otherwise adversely affect management of their
account(s).
By directing Covey Capital to use a specific broker or dealer, clients who are subject to ERISA confirm
and agree with Covey Capital that they have the authority to make the direction, that there are no
provisions in any client or plan document which are inconsistent with the direction, that the
brokerage and other goods and services provided by the broker or dealer through the brokerage
transactions are provided solely to and for the benefit of the client’s plan, plan participants and their
beneficiaries, that the amount paid for the brokerage and other services have been determined by
the client and the plan to be reasonable, that any expenses paid by the broker on behalf of the plan
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are expenses that the plan would otherwise be obligated to pay, and that the specific broker or dealer
is not a party in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We typically direct trading in your account as and when trades are appropriate, without regard to
activity in other client accounts. However, from time to time and consistent with our duty of best
execution, we may aggregate trades together for multiple client accounts. Moreover, such aggregated
or “blocked” trades may include shares or units intended to be purchased or sold for accounts that
are affiliated with our principals or employees (“Affiliated Accounts”).
Each client that participates in an aggregated order will participate at the average share price
obtained in that block trade, with transaction costs generally shared pro-rata based on each client’s
participation in the transaction. On occasion, owing to the size of a particular account’s pro rata share
of an order or other factors, the commission or transaction fee charged could be above or below a
breakpoint in a pre-determined commission or fee schedule set by the executing broker, and
therefore transaction charges may vary among accounts. Also, accounts may be excluded from a
block trade due to tax considerations, client direction or other factors making the account’s
Item 13 - Review of Accounts
participation ineligible or impractical.
Managed portfolios are reviewed at least annually but may be reviewed more often if requested by
the client, upon receipt of information material to the management of the portfolio, or at any time
such review is deemed necessary or advisable by Covey Capital. R. Scott Mayo, Covey Capital’s
Managing Member and Portfolio Manager, reviews all accounts and monitors portfolio holdings in
light of trading activity, significant corporate developments and any other activity dictating a change
in portfolio positions.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account.
Separately Managed Accounts may receive statements quarterly. These written reports normally
include a summary of portfolio holdings and performance results. Additional reports are available
upon client request.
Item 14 - Client Referrals and Other Compensation
12 - Brokerage Practices
As noted above, we receive an economic benefit from Schwab in the form of support products and
services it makes available to Covey Capital and other independent investment advisers whose
clients maintain accounts at Schwab. These products and services, how they benefit our firm, and
. The availability of
the related conflicts of interest are described in Item
Schwab’s products and services to Covey Capital is based solely on its participation in the programs
and not on the provision of any particular investment advice. Neither Schwab nor any other party is
paid to refer clients to Covey Capital.
Item 15 - Custody
Schwab is the custodian for the majority of client accounts managed by Covey Capital. From time to
time however, you may select an alternate custodian or broker to hold accounts in custody. In any
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case, it is the custodian’s responsibility to provide clients with confirmations of trading activity, tax
forms and at least quarterly account statements. Clients are advised to review this information
carefully, and to notify Covey Capital of any questions or concerns. Clients are also asked to promptly
notify Covey Capital if the custodians fail to provide statements on each account held.
From time to time and in accordance with Covey Capital’s agreement with clients, Covey Capital will
provide additional reports. The account balances reflected on these reports should be compared to
the balances shown on the brokerage statements to ensure accuracy. At times, there may be small
differences due to such things as the timing of dividend reporting and pending trades and other
Item 16 - Investment Discretion
similar issues.
Item 4 – Advisory Business,
discretionary accounts
As described in
Covey manages portfolios on a discretionary basis. Prior
to managing a client’s assets, Covey Capital enters into an investment management agreement or
, a
other agreement that sets forth the scope of Covey Capital’s discretion. For
Limited Power of Attorney (“LPOA”) is executed by the client, giving Covey Capital the authority to
carry out various activities in the account, generally including the following: trade execution and the
withdrawal of advisory fees directly from the account. Covey Capital then directs investment of the
client’s portfolio using its discretionary authority. You may limit the terms of the LPOA to the extent
consistent with your investment advisory agreement with us and the requirements of your custodian.
The discretionary relationship is further described in the agreement between Covey Capital and the
client.
Item 17 - Voting Client Securities
Where Covey Capital has authority to vote proxies, Covey Capital will seek to vote proxies in the best
interest of the client(s) holding the applicable securities when votes are deemed material. In voting
proxies, Covey Capital considers factors that it believes relate to the client’s investment(s) and
factors, if any, that are set forth in written instructions from the client.
for
When deemed material, Covey Capital believes that voting proxies in accordance with the following
guidelines, with respect to such routine items, is in the best interests of our clients. Accordingly,
Covey Capital generally votes
:
•
•
•
•
•
•
The election of directors (where no corporate governance issues are implicated);
Proposals that strengthen the shared interests of shareholders and management;
The selection of independent auditors based on management or director recommendation,
unless a conflict of interest is perceived;
Proposals that Covey believes may lead to an increase in shareholder value;
Management recommendations adding or amending indemnification provisions in charter or
by-laws; and
Proposals that maintain or increase the rights of shareholders.
against
When deemed material, Covey Capital will generally vote
any proposals that it believes will
have a negative impact on shareholder value or rights. If Covey Capital perceives a conflict of interest,
its policy is to notify affected clients so that they may choose the course of action they deem most
appropriate.
A copy of our complete policy, as well as records of proxies voted, is available to clients upon request.
As required under the Advisers Act, such records are maintained for a period of five (5) years.
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Item 18 - Financial Information
Covey Capital does not require or solicit prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore has no financial items to disclose.
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