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Part 2A of Form ADV - Brochure
Davenport Watts & Drake Investment Advisors, LLC
234 W School St.
Ridgeland, MS 39157
(601) 898-8069
(601) 853-8087 Fax
www.DavenportWattsDrake.com
This brochure provides information about the qualifications and
business practices of DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC. If you have any questions about the contents of this
brochure, please contact us at: (601) 898-8069 and/or via email at
ellen@davenportwattsdrake.com. The information in this brochure
has not been approved or verified by the United States Securities and
Exchange Commission (SEC), or by any state securities authority.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC is
an SEC registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training.
Additional information about DAVENPORT WATTS & DRAKE
INVESTMENT ADVISORS, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov. DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC’s CRD# is 127506 and SEC File# is 801-123626.
April 2026
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Davenport Watts & Drake Investment Advisors, LLC
Item 2 - Material Changes
Annual Update
Davenport Watts & Drake Investment Advisors, LLC amends this brochure at
least annually and will include material changes occurring since the previous
release of the Firm Brochure.
Material Changes since the Last Update
Three (3) changes have occurred since the release of the Firm Brochure on
March 10, 2025 and the Annual Update on March 7, 2026.
(1) Assets Under Management have been updated to $157 million.
(2) The number of clients has been updated to 214.
(3) Ellen M. Hazlewood is registered as an Investment Advisor
Representative through the Securities and Exchange Commission.
Full Brochure Available
Whenever you would like to receive a copy of our Firm Brochure, please
contact us by telephone at (601) 898-8069 or by email at
ellen@davenportwattsdrake.com.
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Item 1: Cover Page..…………………………………………………………………………i
Item 2: Material Changes……………………………………….………………………….ii
Item 3: Table of Contents..…………………………………………………………………iii
Item 4: Advisory Business…………………………………………………………….......1
Item 5: Fees and Compensation ..………………………………………………………..3
Item 6: Performance-Based Fees ……………………………………………………….. 5
Item 7: Types of Clients …………………………………………………………………… 5
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss …………... 5
Item 9: Disciplinary Information …………………………………………………………. 7
Item 10: Other Financial Industry Activities and Affiliations ………………………… 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading …………………………………………………………………………… 7
Item 12: Brokerage Practices ……………………………………………………………… 8
Item 13: Review of Accounts ………………………………………………………………. 9
Item 14: Client Referrals and Other ……………………………………………………… 9
Item 15: Custody……………………………………………………………………………. 10
Item 16: Investment Discretion…………………………………………………………… 10
Item 17: Voting Client Securities…………………………………………………………. 11
Item 18: Financial Information...………….……………………………………………….11
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Item 4 - Advisory Business
A Firm Description
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC, was
founded in 2003.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC provides
personalized confidential financial planning and investment management to
individuals and small businesses. The scope of services provided includes
retirement plans, trusts, estate planning, cash flow management, tax
planning, insurance review, investment management, education funding, and
business continuation.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC maintains
client accounts with independent custodians and manages the investment of
assets for its clients. The process of investment management results in a
written evaluation of each client’s individual situation. This document outlines
the guidelines for investing the client’s assets and trading authorization for
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC.
Periodic reviews are communicated to provide reminders of the specific
courses of action that need to be taken. More frequent reviews occur but are
not necessarily communicated to the client unless immediate changes are
recommended.
Other professionals (e.g., lawyers, accountants, insurance agents, etc.) will
be engaged on behalf of the client or directly by the client as needed.
Conflicts of interest will be disclosed to the client in the unlikely event they
should occur.
The initial meeting is free of charge and is considered an exploratory
interview to determine the extent to which financial planning and investment
management will benefit the client.
Principal Owners
Tom S. Davenport is a 100% member.
B Types of Advisory Services
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC provides
investment advisory services, also known as asset management services,
and furnishes investment advice through consultations.
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On more than an occasional basis, DAVENPORT WATTS & DRAKE
INVESTMENT ADVISORS, LLC furnishes advice to clients on matters not
involving securities, such as financial planning matters, taxation issues, and
trust services that often include estate planning.
C Tailored Relationships
Investment policy statements are created that reflect stated goals and
objectives. Clients may impose restrictions on investing in certain securities or
types of securities.
Agreements will not be assigned without client consent.
D DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
participate in wrap fee programs.
E As of December 2025, DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC managed approximately $157 million in assets for
approximately 214 clients. Approximately $157 million is managed on a
discretionary basis, and $0 is managed on a non-discretionary basis.
Asset Management
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC manages
the assets of its clients using the core strategies of asset allocation, asset
diversification, and periodic rebalancing, with a long-term perspective while
minimizing income taxes and expenses.
The investments used are primarily no-load mutual funds and exchange-
traded funds. Individual equities are sometimes utilized at the request of the
client.
Types of Agreements: Investment Advisor Services Agreement (IASA)
The Investment Advisors Services Agreement provided with DAVENPORT
WATTS & DRAKE INVESTMENT ADVISORS, LLC covers the scope of work
and fee to the client in writing prior to the start of the relationship. An
Investment Advisors Services Agreement may include cash flow
management; insurance review; investment management; education
planning; retirement planning; estate planning; and tax advice, as well as the
implementation of recommendations within each area.
The agreement defines the management of assets in relation to the client’s
needs.
The Investment Advisor Services Agreement fee is based on a percentage of
the investable assets according to the following schedule:
1.00% annualized on the first $1,000,000 of account value; and
0.75% annualized on amounts above $1,000,000 of account value.
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Current client relationships exist where the fees are higher or lower than the
fee schedule above.
Within the first 5 days of entering into an Investment Advisor Services
Agreement, clients may terminate the IASA with no penalty.
After the initial five (5) calendar days period, the Investment Advisor Services
Agreement may be terminated at any time by written notice to the other party.
At termination, fees will be billed on a pro rata basis for the portion of the fee
computation period. The portfolio value at the completion of the prior full
billing period is used as the basis for the fee computation, adjusted for the
number of days during the billing period prior to termination.
Retainer Agreement
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
work on Retainer Agreements in lieu of an IASA.
Tax Preparation Agreement
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
do tax return preparation.
Hourly Planning Engagements
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
provide hourly planning services. Everything is a flat or asset-based fee.
Termination of Agreement
Within the first 5 days of entering into an Investment Advisor Services
Agreement, clients may terminate the IASA with no penalty. After this period,
a Client may terminate any of the aforementioned agreements at any time by
notifying DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC in
writing and paying for the time spent and progress made on the investment
advisory engagement prior to notification of termination. If the client made an
advance payment, DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC would refund any unearned portion of the advance
payment.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC may
terminate any of the aforementioned agreements at any time by notifying the
client in writing. If the client made an advance payment, DAVENPORT
WATTS & DRAKE INVESTMENT ADVISORS, LLC will refund any unearned
portion of the advance payment.
Item 5 - Fees and Compensation
A Description
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC bases its
fees on a percentage of assets under management.
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DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC, in its sole
discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning
capacity, anticipated additional assets, related accounts, account
composition, negotiations with clients, etc.)
Financial plans are priced according to the degree of complexity associated
with the client’s situation.
All fees are negotiable.
B Fee Billing
Investment management fees are billed monthly, in arrears, meaning that we
invoice clients after the billing period has ended. Fees are deducted directly
from accounts, and clients give consent in advance to the billing process
through their IASA. Clients are encouraged to compare fees itemized on their
custodial investment statements to their fee agreement.
If charged, fees for financial plans are due upon delivery of the financial plan.
C Other Fees
Custodians may charge transaction fees on trades of securities. No part of
these fees is received by DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC.
D Prepaid Fees/Refunds
As client fees are paid in arrears, there are no prepaid fees and/or refunds
due.
E Davenport Watts & Drake Investment Advisors, LLC and its related persons
do not accept compensation for the sale of securities or other investment
products.
Past Due Accounts and Termination of Agreement
As fees are drawn directly from clients’ investment accounts, there are no
past due accounts.
However, DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC
reserves the right to terminate any financial planning engagement where a
client has willfully concealed or refused to provide pertinent information about
financial situations when necessary and appropriate, in DAVENPORT
WATTS & DRAKE INVESTMENT ADVISORS, LLC’s judgment, to providing
proper financial advice.
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Item 6 - Performance-Based Fees
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of
managed securities.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
use a performance-based fee structure because of the potential conflict of
interest. Performance-based compensation may create an incentive for the
adviser to recommend an investment that may carry a higher degree of risk to
the client than is appropriate.
Item 7 - Types of Clients
Description
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC provides
investment advice to individuals, businesses, qualified retirement plans,
trusts, or charitable organizations.
Client relationships vary in scope and length of service.
Account Minimums
The minimum account size is $50,000.00 of assets under management.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC has the
discretion to waive the account minimum.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
A Methods of Analysis
Security analysis methods include fundamental analysis with decisions based
on a company or fund’s health, its competitive advantages and
disadvantages, and its market. Therefore, we align ourselves with investment
analysts who share this philosophy. They include Advisor Intelligence and
Advisors Asset Management.
B Investment Strategies
The primary investment strategies used on client accounts are strategic asset
allocation with periodic rebalancing. In addition, portfolios are diversified to
control the risk associated with markets. A long-term perspective is taken
when considering investments, and income taxes are minimized when
applicable.
The investment strategy for a specific client is based upon the objectives
stated by the client during consultations. The client may change these
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objectives at any time. Each client signs an Investment Policy Statement that
documents their objectives and their desired investment strategy.
C Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to
bear. Our investment approach constantly keeps the risk of loss in mind.
Investors face the following investment risks:
●
Interest-rate Risk: Fluctuations in interest rates may cause investment
prices to fluctuate. For example, when interest rates rise, yields on
existing bonds become less attractive, causing their market values to
decline.
● Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of
risk is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic, and social
conditions may trigger market events.
●
Inflation Risk: When any type of inflation is present, a dollar today will
not buy as much as a dollar next year, because purchasing power is
eroding at the rate of inflation.
● Currency Risk: Overseas investments are subject to fluctuations in the
value of the dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk.
● Reinvestment Risk: This is the risk that future proceeds from
investments may have to be reinvested at a potentially lower rate of
return (i.e., interest rate). This primarily relates to fixed income
securities.
● Business Risk: These risks are associated with a particular industry or
a particular company within an industry. For example, oil-drilling
companies depend on finding oil and then refining it, a lengthy
process, before they can generate a profit. They carry a higher risk of
profitability than an electric company, which generates its income from
a steady stream of customers who buy electricity no matter what the
economic environment is like.
● Liquidity Risk: Liquidity is the ability to readily convert an investment
into cash. Generally, assets are more liquid if many traders are
interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
● Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of
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financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
Item 9 - Disciplinary Information
A We are required to disclose all material facts regarding any legal or
B disciplinary event that would be material to your evaluation of our firm
C or the integrity of our management. No principal or person associated
with our firm has any information to disclose which is applicable to
this Item.
Item 10 - Other Financial Industry Activities and Affiliations
Financial Industry Activities
A DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC is
registered as an investment advisory firm. No members of the firm are
registered, or have an application pending to register, as a broker-dealer.
B No members of the firm are registered, or have an application pending
to register as a futures commission merchant, commodity pool operator,
a commodity trading advisor, or an associated person of the foregoing
entities.
Affiliations
C DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does
not have arrangements that are material to its advisory or its clients
D with a related person who is a broker-dealer, investment company, other
investment advisor, financial planning firm, commodity pool operator,
commodity trading adviser or futures commission merchant, banking or
thrift institution, accounting firm, law firm, insurance company or agency,
pension consultant, real estate broker or dealer, or any entity that creates or
packages limited partnerships.
Item 11 - Code of Ethics, Participation, or Interest in Client Transactions
and Personal Trading
A Code of Ethics
The employees of DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC have committed to a Code of Ethics that is available for
review by clients and prospective clients. The firm will provide a copy of the
Code of Ethics to any client or prospective client upon request.
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B DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC and
related persons do not recommend to clients, or buy or sell for client
accounts, securities in which the firm or related person has a material
financial interest.
Participation or Interest in Client Transactions
C DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC and its
employees may buy or sell securities that are also held by clients.
Employees may not trade their own securities ahead of client trades.
Employees comply with the provisions of the DAVENPORT WATTS &
DRAKE INVESTMENT ADVISORS, LLC Policies & Procedures.
D Personal Trading
The Chief Compliance Officer of DAVENPORT WATTS & DRAKE
INVESTMENT ADVISORS, LLC is Tom S. Davenport. He reviews all
employee trades each quarter. His trades are reviewed by Henry M. Drake,
Jr. The personal trading reviews ensure that the personal trading of
employees do not affect the markets, and that clients of the firm receive
preferential treatment. Since most employee trades are small mutual fund
trades or exchange-traded fund trades, the trades do not affect the securities
markets.
Item 12 - Brokerage Practices
A Selecting Brokerage Firms
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does
not have any affiliation with product sales firms. Specific custodian
recommendations are made to clients based on their need for such services.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC
recommends custodians based on the proven integrity and financial
responsibility of the firm and the best execution of orders at reasonable
commission rates.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
receive fees or commissions from any of these investment arrangements.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
participate in soft dollar or directed brokerage commission arrangements.
Through its relationships with custodians, DAVENPORT WATTS & DRAKE
INVESTMENT ADVISORS LLC receives certain services and products, such
as fundamental research reports, technical and portfolio analyses, pricing
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services, economic forecasting, and general market information, historical
data base information and computer software that assist investment advisors’
representatives in the investment management process. These soft dollar
benefits are known as “safe harbor” benefits as described under section
28(e) of the Securities Exchange Act of 1934 and are available to all clients
equally.
B Order Aggregation
Most trades are mutual funds or exchange-traded funds where trade
aggregation does not garner any client benefit.
Item 13 - Review of Accounts
A Periodic Reviews
Account reviews are performed as needed by the Investment Advisory Team.
Account reviews are performed more frequently when market conditions
dictate.
B Review Triggers
Other conditions that may trigger additional account review include changes
in the tax laws, new investment information, and changes in a client's own
situation.
C Regular Reports
Account reviewers are members of the firm's Investment Advisory Team.
They are instructed to consider the client's current security positions and the
likelihood that the performance of each security will contribute to the
investment objectives of the client.
Investment clients receive periodic communications on at least an annual
basis. The updates may include a net worth statement, portfolio statement,
and a summary of objectives and progress towards meeting those objectives.
Item 14 - Client Referrals and Other Compensation
A Incoming Referrals
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC has been
fortunate to receive many client referrals over the years. The referrals came
from current clients, estate planning attorneys, accountants, employees,
personal friends of employees and other similar sources. The firm does not
compensate referring parties for these referrals.
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B Referrals Out
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
accept referral fees or any form of remuneration from other professionals
when a prospect or client is referred to them.
Other Compensation
We receive commissions from prior placements of insurance and, with two
licensed insurance persons on staff, could represent our clients should future
insurance be needed. If we choose to seek outside assistance with insurance
placement, we will disclose any type of remuneration to the client. No other
compensation is received.
Item 15 – Custody
Account Statements
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC
may be deemed to have custody when directly deducting fees from client
accounts but does not otherwise have custody of client assets.
Clients receive account statements from the custodian of their accounts. We
encourage clients to carefully review their fee calculations and compare their
fee agreement with the advisor fees itemized on the statement from the
custodian.
Item 16 - Investment Discretion
Discretionary Authority for Trading
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC accepts
discretionary authority to manage securities accounts on behalf of clients.
DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC has the
authority to determine, without obtaining specific client consent, the securities
to be bought or sold, and the amount of the securities to be bought or sold.
However, DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC
consults with the client prior to each trade to obtain concurrence if a blanket
trading authorization has not been given.
The client approves the custodian to be used and any commission rates paid
to the custodian. DAVENPORT WATTS & DRAKE INVESTMENT
ADVISORS, LLC does not receive any portion of the transaction fees or
commissions paid by the client to the custodian on certain trades.
Discretionary trading authority facilitates placing trades in your accounts on
your behalf to promptly implement the investment policy that you have
approved in writing.
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Item 17 - Voting Client Securities
Proxy Votes
A DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
vote proxies on securities. Clients are expected to vote their own proxies.
B When assistance on voting proxies is requested, DAVENPORT WATTS &
DRAKE INVESTMENT ADVISORS, LLC will provide recommendations to
the client. If a conflict of interest exists, it will be disclosed to the client.
Item 18 - Financial Information
Financial Condition
A DAVENPORT WATTS & DRAKE INVESTMENT ADVISORS, LLC does not
have any financial impairment that will preclude the firm from meeting
contractual commitments to clients.
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