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Brochure
Form ADV Part 2A
Item 1 - Cover Page
JAMISON PRIVATE WEALTH MANAGEMENT, INC.
CRD# 109040
12630 Crabapple Road
Suite 300
Milton, Georgia 30004
(678) 323-3454
www.jamisonwealth.com
February 16, 2026
This brochure provides information about the qualifications and business practices of Jamison
Private Wealth Management, Inc. If you have any questions about the contents of this brochure,
please contact us at (678) 323-3454 or bjamison@jamisonwealth.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.
Jamison Private Wealth Management, Inc. 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 Jamison Private Wealth Management, Inc. also is available on the SEC’s
website at
Item 2 - Material Changes
This section requires that we provide 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 February 11, 2025, and
any material changes are reported below. Of course, the complete Brochure is available to clients at
any time upon request.
Material changes include:
•
Robert Jamison transferred his ownership shares to Peyton Jamison.
Item 3 - Table of Contents
Page
Item 1 - Cover Page ............................................................................................................................................................ 1
Item 2 - Material Changes ................................................................................................................................................ 1
Item 3 - Table of Contents ............................................................................................................................................... 2
Item 4 - Advisory Business ............................................................................................................................................. 3
Item 5 - Fees and Compensation .................................................................................................................................. 4
Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................ 5
Item 7 - Types of Clients................................................................................................................................................... 5
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 5
Item 9 - Disciplinary Information ................................................................................................................................ 8
Item 10 - Other Financial Industry Activities and Affiliations ......................................................................... 8
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 8
Item 12 - Brokerage Practices ....................................................................................................................................... 9
Item 13 - Review of Accounts ...................................................................................................................................... 10
Item 14 - Client Referrals and Other Compensation .......................................................................................... 10
Item 15 - Custody .............................................................................................................................................................. 11
Item 16 - Investment Discretion ................................................................................................................................. 11
Item 17 - Voting Client Securities............................................................................................................................... 12
Item 18 - Financial Information .................................................................................................................................. 12
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Item 4 - Advisory Business
General Information
Jamison Private Wealth Management, Inc. (“JPWM”) (formerly Diversified Financial Planning, Inc.)
was formed in 1988 and provides portfolio management and general consulting services to its clients.
Brochure Supplements
, Exhibit A, for
Peyton Jamison is the principal owner of JPWM. Please see
more information on Mr. Jamison and other individuals who formulate investment advice and have
direct contact with clients or have discretionary authority over client accounts.
As of January 21, 2026, JPWM managed $997,101,647 on a discretionary basis, and $55,472,234 of
assets on a non-discretionary basis.
SERVICES PROVIDED
JPWM provides discretionary and non-discretionary investment advisory services, which may
include, but are not limited to, the review of client investment objectives and goals, recommending
asset allocation strategies of managed assets among investment products and/or preparing written
investment strategies. At the outset of each client relationship, JPWM spends time with the client,
asking questions, discussing the client’s investment experience and financial circumstances, and
reviewing options for the client. Our investment advice is tailored to meet our clients’ needs and
investment objectives and JPWM will assist clients in determining the suitability of the portfolio(s)
for the client.
Where JPWM provides general consulting services, JPWM will work with the client to prepare an
appropriate summary of the specific project(s) to the extent necessary or advisable under the
circumstances.
Portfolio Management
As described above, at the beginning of a client relationship, JPWM meets with the client, gathers
information, and performs research and analysis as necessary to develop the client’s investment plan.
The investment plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by JPWM based on updates to the client’s financial or other
circumstances.
To implement the client’s investment plan, JPWM will manage the client’s investment portfolio on a
discretionary basis or a non-discretionary basis. As a discretionary investment adviser, JPWM will
have the authority to supervise and direct the portfolio without prior consultation with the client.
Clients who choose a non-discretionary arrangement must be contacted prior to the execution of any
trade in the account(s) under management. This may result in a delay in executing recommended
trades, which could adversely affect the performance of the portfolio. This delay also normally means
the affected account(s) will not be able to participate in block trades, a practice designed to enhance
the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary
arrangement, the client retains the responsibility for the final decision on all actions taken with
respect to the portfolio.
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Notwithstanding the foregoing, clients may impose certain written restrictions on JPWM in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should note, however, that restrictions
imposed by a client may adversely affect the composition and performance of the client’s investment
portfolio. Each client should also note that his or her investment portfolio is treated individually by
giving consideration to each purchase or sale for the client’s account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk
tolerance may differ, and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of JPWM.
General Consulting and Tax Preparation Services
In addition to the foregoing services, JPWM may provide general consulting services to clients. These
services are generally provided on a project basis, and may include, without limitation, minimal cash
flow planning for certain events such as education expenses or retirement, estate planning analysis,
income tax planning analysis and review of a client’s insurance portfolio, as well as other matters
specific to the client as and when requested by the client and agreed to by JPWM. The scope and fees
for consulting services will be negotiated with each client at the time of engagement for the applicable
Item 5 - Fees and Compensation
project.
Item 12 - Brokerage Practices
General Fee Information
Fees paid to JPWM 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 JPWM 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, JPWM and others to
fully understand the total amount of fees paid by the client for investment and financial- related
services.
Portfolio Management Fees
The annual fee is based on a percentage of assets under management, not to exceed 1.00%.
Certain assets classes, such as cash, money market mutual funds, certificates of deposit and other
short-term cash equivalents, are not generally included in the fee calculation. JPWM may impose a
minimum portfolio value and/or a minimum annual fee. JPWM may, at its discretion, make exceptions
to the foregoing, negotiate special fee arrangements and/or discount or waive fees where JPWM
deems it appropriate under the circumstances. Additionally, JPWM may aggregate account values
per household in order to offer fee discounts based on the total amount of assets under management.
Portfolio management fees are generally payable quarterly, in arrears. If management begins after
the start of a quarter, fees will be prorated accordingly. Additionally, fees are adjusted for deposits
and withdrawals during the billing cycle. With client authorization and unless other arrangements
are made, fees are normally debited directly from client account(s).
JPWM does not utilize a written agreement with its clients. All arrangements are agreed to verbally
and may be terminated by either party at any time, subject to any written notice requirements to
which both parties have agreed. In the event of termination, any paid but unearned fees will be
promptly refunded to the client based on the number of days that the account was managed, and any
fees due to JPWM from the client will be invoiced or deducted from the client’s account prior to
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termination.
General Consulting Fees
For those clients who do not require the continuous management services of JPWM, fees are charged
hourly at the rate of $280. These charges are invoiced monthly, in arrears. The rate is not negotiable.
For large projects or at client request, JPWM may provide the client with an estimate prior to
Item 6 - Performance-Based Fees and Side-By-Side Management
beginning work.
JPWM does not have 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 JPWM has no performance-based fee accounts, it has no side-by-side
Item 7 - Types of Clients
management.
JPWM serves individuals, pension and profit sharing plans, corporations, trusts, estates and
charitable organizations. JPWM may impose a minimum portfolio value and/or a minimum annual
fee for conventional investment advisory services. Under certain circumstances and in its sole
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
discretion, JPWM may negotiate such minimums.
Methods of Analysis
JPWM will primarily invest in common stocks, and to a more limited degree will invest in mutual
funds and ETFs. Treasury bills, CDs and bonds are utilized on an even more limited basis.
In selecting individual stocks for an account, JPWM generally applies traditional fundamental
analysis including, without limitation, the following factors:
o
o
o
o
Financial strength ratios;
Price-to-earnings ratios;
Dividend yields; and
Growth rate-to-price earnings ratios
JPWM will incorporate other methods of analysis, such as:
Cyclical Analysis
– is a type of technical analysis that involves evaluating recurring price
patterns and trends.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors, including,
without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings
for safety and returns, and other factors.
Fixed income investments may be used as a holding place for funds waiting to be invested, as a
strategic investment, as an instrument to fulfill liquidity or income needs in a portfolio, or to add a
component of capital preservation. JPWM may evaluate and select individual bonds or bond funds
based on a number of factors including, without limitation, rating, yield and duration.
Investment Strategies:
JPWM’s strategic approach is to invest each portfolio in accordance with the Plan that has been
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developed specifically for each client. This means that the following strategies may be used in varying
combinations over time for a given client, depending upon the client’s individual circumstances.
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold
within a relatively short period of time, generally less than one year, to take advantage of the
securities’ short-term price fluctuations.
Short Sales – a securities transaction in which an investor sells securities he or she borrowed
in anticipation of a price decline. The investor is then required to return an equal number of
shares at some point in the future. A short seller will profit if the stock goes down in price.
Risk of Loss
While JPWM seeks to diversify clients’ investment portfolios across various asset classes consistent
with their Investment Plans 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 lose money.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks.
While JPWM manages client investment portfolios based on JPWM’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 JPWM allocates assets to asset classes that are
adversely affected by unanticipated market movements, and the risk that JPWM’s specific investment
choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described above, JPWM may
invest client portfolios in mutual funds, ETFs and other investment pools (“pooled investment
funds”). Investments in pooled investment funds are generally less risky than investing in
individual securities because of 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 companies under the Investment Company Act of 1940.
Equity Market Risks.
JPWM will generally invest portions of client assets directly into equity
investments, primarily stocks, or into pooled investment funds that invest in the stock market. As
noted above, while pooled investments have diversified portfolios that may make them less risky
than investments in individual securities, funds that invest in stocks and other equity securities are
nevertheless subject to the risks of the stock market. These risks 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 (i.e., bear markets) due to general market declines in the stock prices for
all companies, regardless of any individual security’s prospects.
Fixed Income Risks.
JPWM 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
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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).
Real Estate Investment Trusts (REIT) Risks.
JPWM may recommend investments in REITS. There may
be risks related to REIT investments such as the following: Lack of a public trading market creates
illiquidity and valuation complexities, distributions are not guaranteed and may exceed operating
cash flow, distributions and REIT status may carry tax consequences, early redemption is often
restrictive and may be expensive, fees may be complex, diversification can be limited, REITS carry
real estate risk and are generally regarded as long term investments. Investors should be aware that
some REITS are unaudited. Not all states require private investments to provide audited financial
statements to investors. Investors should understand that when there are no audited financials
produced, JPWM cannot independently verify the value of the security. In such cases, we would rely
on the managing partner to value it accurately.
Master Limited Partnership (MLP) Risks.
An MLP is a type of business venture that exists in the from
of a publicly traded limited partnership. It combines the tax benefits of a partnership (profits are
only taxed when investors receive distributions) with the liquidity of a public company. One risk is
that the governance and standard of care can favor the sponsor. Most listed companies must have a
majority of independent directors on their boards, but the GP of an MLP is only required to have
independent directors on its audit committee. Also, MLPs can opt for a lower standard of care (or
duties owed by the GP’s directors to the owners/investors) than the more stringent fiduciary
standard generally owed to shareholders of corporations under state law. Lack of independence and
lower standards of care are factors that could influence the decisions made by the GP’s directors,
possibly to the detriment of the limited partners of the MLP. Another risk is that the sponsor’s
relationship with the MLP and with the GP creates inherent conflicts of interest. These conflicts arise
most frequently in transactions between the sponsor and the MLP, such as when the sponsor wants
to sell assets to the MLP or if the sponsor decides to merge the MLP into the GP. If the GP opts for the
lower standard of care discussed above, it may consider its own interests ahead of the interests of
the MLP and its limited partners and resolve conflicts in a manner favorable to itself. Lastly, as most
MLPs are focused on a single industry or industry segment, investors have concentrated exposure to
the volatility of that industry or segment. Changes in the price of commodities in that industry could
impact the amount of income that an MLP generates or the ability of the MLP to maintain or expand
its operations. Because most MLPs are currently in the energy sector, particularly in the pipeline or
energy storage industries, MLPs can be acutely sensitive to shifts in oil and gas prices, as noted above.
Foreign Securities Risks.
JPWM may invest portions of client assets into pooled investment funds that
invest internationally. While foreign investments are important to the diversification of client
investment portfolios, they carry risks that may be different from U.S. investments. For example,
foreign investments may not be subject to uniform audit, financial reporting or disclosure standards,
practices or requirements comparable to those found in the U.S. Foreign investments are also subject
to foreign withholding taxes and the risk of adverse changes in investment or exchange control
regulations. Finally, foreign investments may involve currency risk, which is the risk that the value
of the foreign security will decrease due to changes in the relative value of the U.S. dollar and the
security’s underlying foreign currency.
Artificial Intelligence and Machine Learning Risk.
Certain service providers utilized by the Firm to
service client accounts have artificial intelligence components. The use of artificial intelligence and
machine learning includes increased risk of data inaccuracies and security vulnerabilities. Due to the
rapid advancement of machine learning technologies, future risks related to artificial intelligence are
unpredictable. As a measure to mitigate these risks to our clients, the Firm performs periodic due
diligence of our service providers for assurance that the service providers have appropriate controls
in place to protect our clients’ information and to limit data inaccuracies when artificial intelligence
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is used by the service provider.
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 JPWM or the integrity of JPWM’s
Item 10 - Other Financial Industry Activities and Affiliations
management. JPWM has no disciplinary events to report.
The Firm offers tax preparation services to its clients; however, clients are not obligated to use
this service. Representatives of the firm are qualified as Certified Public Accountants to provide
these services.
No representatives of JPWM are currently registered with any broker dealer.
Neither JPWM nor its representatives are registered as a Futures Commission Merchant,
Commodity Pool Operator, or a Commodity Trading Advisor.
JPWM does not have any other financial industry activities or affiliations.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
JPWM has adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request.
JPWM’s Code has several goals. First, the Code is designed to assist JPWM in complying with
applicable laws and regulations governing its investment advisory business. Under the Investment
Advisers Act of 1940, JPWM owes fiduciary duties to its clients. Pursuant to these fiduciary duties,
the Code requires persons associated with JPWM (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.
Next, the Code sets forth guidelines for professional standards for JPWM’s associated persons. Under
the Code’s Professional Standards, JPWM expects its associated persons to put the interests of its
clients first, ahead of personal interests. In this regard, JPWM associated persons are not to take
inappropriate advantage of their positions in relation to JPWM clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time, JPWM’s associated persons may invest in the same
securities recommended to clients. Under its Code, JPWM 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 and pre-clearance of certain types of personal trading activities.
These policies are designed to discourage and prohibit personal trading that would disadvantage
clients. The Code also provides for disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
JPWM has established procedures designed to prevent conflicts between trades in client accounts
and trades in the personal accounts of persons associated with JPWM. However, in the event of any
identified potential trading conflicts of interest, JPWM’s goal is to place client interests first.
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Consistent with the foregoing, JPWM maintains policies regarding participation in initial public
offerings (IPOs) and private placements in order to comply with applicable laws and avoid conflicts
with client transactions. If a JPWM associated person wishes to participate in an IPO or invest in a
private placement, he or she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
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 removed from the block,
and the balance of shares will be allocated among client accounts in accordance with JPWM’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, JPWM
seeks “best execution” for client trades, which is a combination of a number of factors, including,
without limitation, quality of execution, services provided and commission rates. Therefore, JPWM
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 JPWM’s clients. Therefore, research services received may not
be used for the account for which the particular transaction was affected.
JPWM may recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(“Schwab”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to maintain
custody of clients’ assets. JPWM may also affect trades for client accounts at Schwab, or may in some
instances, consistent with JPWM’s duty of best execution and specific agreement with each client,
elect to execute trades elsewhere. Although JPWM may recommend that clients establish accounts at
Schwab, it is ultimately the client’s decision to custody assets with Schwab. JPWM is independently
owned and operated and is not affiliated with Schwab.
Schwab Advisor Services provides JPWM with access to its institutional trading, custody, reporting
and related services, which are typically not available to Schwab retail investors. Schwab also makes
available various support services. Some of those services help JPWM manage or administer our
clients’ accounts while others help JPWM manage and grow our business. These services generally
are available to independent investment advisors on an unsolicited basis, at no charge to them. These
services are not soft dollar arrangements but are part of the institutional platform offered by Schwab.
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 would require a significantly higher minimum initial investment.
For JPWM 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 Advisor Services also makes available to JPWM other products and
services that benefit JPWM but may not directly benefit its clients’ accounts. Many of these products
and services may be used to service all or some substantial number of JPWM accounts, including
accounts not maintained at Schwab.
Schwab’s products and services that assist JPWM in managing and administering clients’ 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
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orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate payment
of JPWM’s fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and
client reporting.
Schwab Advisor Services also offers other services intended to help JPWM manage and further
develop its business enterprise. These services may include: (i) technology, compliance, legal and
business consulting; (ii) publications and conferences on practice management and business
succession; and (iii) access to employee benefits providers, human capital consultants and insurance
providers. Schwab may make available, arrange and/or pay third-party vendors for the types of
services rendered to JPWM. Schwab Advisor Services may discount or waive fees it would otherwise
charge for some of these services or pay all or a part of the fees of a third-party providing these
services to JPWM. Schwab Advisor Services may also provide other benefits such as educational
events or occasional business entertainment of JPWM personnel. In evaluating whether to
recommend that clients custody their assets at Schwab, JPWM may take into account the availability
of some of the foregoing products and services and other arrangements as part of the total mix of
factors it considers and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict of interest.
Directed Brokerage
JPWM does not generally allow directed brokerage accounts.
Aggregated Trade Policy
JPWM typically directs trading in individual client accounts as and when trades are appropriate based
on the client’s Investment Plan, without regard to activity in other client accounts. However, from
time to time, JPWM may aggregate trades together for multiple client accounts, most often when
these accounts are being directed to sell the same securities. If such an aggregated trade is not
completely filled, JPWM will allocate shares received (in an aggregated purchase) or sold (in an
aggregated sale) across participating accounts on a pro rata or other fair basis; provided, however,
that any participating accounts that are owned by JPWM or its officers, directors, or employees will
Item 13 - Review of Accounts
be excluded first.
Managed portfolios are reviewed at least quarterly 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 JPWM. These factors may include but are not limited
to, the following: change in general client circumstances (marriage, divorce, retirement); or
economic, political or market conditions. Peyton Jamison, JPWM’s President, reviews all accounts.
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. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. JPWM will provide additional
Item 14 - Client Referrals and Other Compensation
written reports as needed or requested by the client.
JPWM does not compensate any individual or firm for client referrals. In addition, JPWM does not receive
compensation for referring clients to other professional service providers.
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Item 15 - Custody
Any investment advisor having custody or access to customer funds or securities must comply with
certain rules and regulations designed to protect the clients’ assets. Rule 206(4)-2 of the Investment
Advisers Act of 1940 details strict requirements governing investment advisors that have “custody”
over client securities or funds. With written authorization to do so, JPWM directly debits your
account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your
accounts causes JPWM to exercise limited custody over your funds or securities.
Standing Letters of Authorization -
Some clients may execute limited powers of attorney or other
standing letters of authorization that permit JPWM to transfer money from their account with the
client’s independent qualified Custodian to third parties. This authorization to direct the Custodian
may be deemed to cause our firm to exercise limited custody over your funds or securities and for
regulatory reporting purposes, we are required to keep track of the number of clients and accounts
for which we may have this ability. We do not have physical custody of any of your funds and/or
securities. Your funds and securities will be held with a bank, broker-dealer, or other independent,
qualified custodian. You will receive account statements from the independent, qualified
custodian(s) holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate any transfers that may have taken place within your account(s) each billing
period. You should carefully review account statements for accuracy.
Schwab is the custodian of nearly all client accounts at JPWM. From time to time, however, clients
may select an alternate broker to hold accounts in custody. In any 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
JPWM of any questions or concerns. Clients are also asked to promptly notify JPWM if the custodian
fails to provide statements on each account held.
From time to time and in accordance with JPWM’s arrangement with clients, JPWM 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. There may at times be small
Item 16 - Investment Discretion
differences due to the timing of dividend reporting and pending trades.
Item 4 - Advisory Business
discretionary accounts
, JPWM will accept clients on either a discretionary or
As described in
non-discretionary basis. For
, a Limited Power of Attorney (“LPOA”) is
executed by the client, giving JPWM the authority to carry out various activities in the account,
generally including the following: trade execution; the ability to request checks on behalf of the client;
and the withdrawal of advisory fees directly from the account. JPWM then directs investment of the
client’s portfolio using its discretionary authority. The client may limit the terms of the LPOA to the
extent consistent with the client’s arrangement with JPWM and the requirements of the client’s
custodian.
non-discretionary
For
accounts, the client also generally executes an LPOA, which allows JPWM to
carry out trade recommendations and approved actions in the portfolio. However, in accordance with
the arrangement between JPWM and the client, JPWM does not implement trading recommendations
or other actions in the account unless and until the client has approved the recommendation or
action. As with discretionary accounts, clients may limit the terms of the LPOA, subject to JPWM’s
arrangement with the client and the requirements of the client’s custodian.
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Item 17 - Voting Client Securities
As a policy and in accordance with JPWM’s client arrangement, JPWM does not vote proxies related
to securities held in client accounts. The custodian of the account will normally provide proxy
materials directly to the client. Clients may contact JPWM with questions relating to proxy
Item 18 - Financial Information
procedures and proposals; however, JPWM generally does not research particular proxy proposals.
JPWM does not require nor solicit prepayment of more than $1,200 in fees per client, six months or
more in advance, and therefore has no disclosure required for this item.
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