Overview
- Total Firm Assets
- $108 million
- Average High-Net-Worth Client Portfolio Size
- $2.8 million
Fee Structure
Primary Fee Schedule (JWM FORM ADV PART 2A - 20260715)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $2,000,000 | 1.00% |
| $2,000,001 | $10,000,000 | 0.80% |
| $10,000,001 | and above | 0.60% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,250 | 1.12% |
| $5 million | $45,250 | 0.90% |
| $10 million | $85,250 | 0.85% |
| $50 million | $325,250 | 0.65% |
| $100 million | $625,250 | 0.63% |
Clients
- High-Net-Worth Share of Firm Assets
- 85.03%
- Number of High-Net-Worth Clients
- 33
- Total Client Accounts
- 208
- Discretionary Accounts
- 208
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 171884
Additional Brochure: JWM FORM ADV PART 2A - 20260715 (2026-07-16)
View Document Text
Item 1 – Cover Page
Jayco Wealth Management, Inc.
2020 Howell Mill Road NW/Suite C-280
Atlanta, GA 30318
(404) 731-7592
www.jaycowealth.com
Form ADV Part 2A
Firm Brochure
July 15, 2026
This brochure provides information about the qualifications and business practices of Jayco Wealth
Management, Inc. Please contact our President, Jennifer Kramer, at (404) 731-7592 if you have any questions
about the content of this brochure.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (SEC) or any state securities administrator. Additional information about Jayco Wealth
Management, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment
Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which
is 171884.
While the firm and its associates may be registered and/or licensed within a particular jurisdiction, registration
and/or licensing does not imply an endorsement by any regulatory authority, nor certain level of skill or training
on the part of the firm or its associated personnel.
Jayco Wealth Management, Inc.
Form ADV Part 2A – 07/15/2026
Page 1 of 25
Item 2 – Material Changes
This Form ADV Part 2A firm brochure has been revised pursuant to Jayco Wealth Management, Inc.’s
registration as an investment adviser with the SEC, superseding previous versions. This document has been
modified to address disclosure requirements for an SEC-registered firm and therefore clients and prospective
clients are encouraged to review the document in its entirety. Updates include our reportable assets under
management (Item 4), fee processing (Item 5), revised risk statements (Item 8), how we serve client accounts
(Items 15), and our investment authority (Item 16), among others. As with all firm documents, clients and
prospective clients are encouraged to review this brochure in its entirety and are encouraged to ask questions at
any time prior to or throughout the engagement.
While this registration transition does not change the scope of services we provide or our fiduciary obligation to
clients, certain regulatory oversight and disclosure requirements regarding activities involving investment
advisers now fall under SEC rules rather than Georgia and other state-level jurisdictions where we operate.
Our firm may at any time update this document and either send a copy of its updated brochure or provide a
summary of material changes to its brochure and offer an electronic or hard copy form of the updated brochure.
Clients are also able to download this brochure from the SEC’s at www.adviserinfo.sec.gov or by contacting our
firm at (404) 731-7592 to request a copy at any time.
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Item 3 – Table of Contents
Item 1 – Cover Page ...................................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................................ 2
Item 3 – Table of Contents ........................................................................................................................................... 3
Item 4 - Advisory Business ............................................................................................................................................. 4
Item 5 - Fees and Compensation ................................................................................................................................... 8
Item 6 - Performance-Based Fees and Side-By-Side Management ............................................................................. 11
Item 7 - Types of Clients .............................................................................................................................................. 11
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 11
Item 9 - Disciplinary Information ................................................................................................................................. 16
Item 10 - Other Financial Industry Activities and Affiliations ...................................................................................... 16
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................ 16
Item 12 - Brokerage Practices ..................................................................................................................................... 18
Item 13 - Review of Accounts ...................................................................................................................................... 22
Item 14 - Client Referrals and Other Compensation ................................................................................................... 23
Item 15 – Custody ....................................................................................................................................................... 23
Item 16 - Investment Discretion .................................................................................................................................. 24
Item 17 - Voting Client Securities ................................................................................................................................ 24
Item 18 - Financial Information ................................................................................................................................... 25
Important Information
Throughout this document Jayco Wealth Management, Inc. shall also be referred to as “the firm,” “firm,” “our,”
“we” or “us.” The client or prospective client may be also referred to as “you,” “your,” etc., and refers to a client
engagement involving a single person as well as two or more persons and may refer to natural persons and legal
entities. The term “advisor” and “adviser” are used interchangeably where accuracy in identification is necessary
(i.e., internet address, etc.).
Our firm maintains a business continuity and succession plan that is integrated within the organization to ensure
it appropriately responds to events that pose a significant disruption to its operations. A statement concerning
the current plan is available under separate cover upon request.
The business and disciplinary history, if any, of an investment advisory firm and its representatives, may be
obtained by reviewing information available on the SEC’s website at www.adviserinfo.sec.gov.
Jayco Wealth Management, Inc.
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Item 4 - Advisory Business
Description of the Firm
Jayco Wealth Management, Inc. is a Georgia corporation formed in May of 2014. The firm’s original registration
as an investment adviser began in 2014, followed by the firm’s registration with the SEC in 2026. The firm is
notice-filed in Georgia, and the firm and its personnel are exempt from notice filing or registration in other
jurisdictions where our investment advisory business activities are conducted.1 We are not a subsidiary of, nor
do we control, another financial services industry entity.
Jennifer C. Kramer, CPA, CFP® is our firm’s President, Chief Compliance Officer (supervisor) and majority
shareholder. Additional information about Ms. Kramer and her professional experience may be found in her Form
ADV Part 2B brochure supplement that accompanies this firm brochure.
Description of Advisory Services Offered
Jayco Wealth Management, Inc. provides a broad range of investment advisory solutions to its clients. For those
interested in areas such as cash flow and budgeting, education funding, retirement and estate planning, risk
management, tax planning, divorce planning and business consultation services, as well as periodic investment
advice, we offer our financial planning services. We also provide ongoing and continuous supervision of our
clients’ accounts through our portfolio management services offering. Our services do not include sponsoring or
managing an investment program involving wrapped (bundled) fees.
An initial interview is conducted by a representative of our firm to discuss your current situation, long-term
goals, and the scope of services that may be provided to you. During or prior to this meeting the prospective
client will be provided with our Form ADV Part 3 (Form CRS), Form ADV Part 2A firm brochure, privacy policy
statement, as well as the Form ADV Part 2B brochure supplement about their investment adviser
representative. Should you wish to engage Jayco Wealth Management, Inc. for its services, you must first
execute our client engagement agreement. Thereafter discussion and analysis will be conducted to determine
your financial needs, goals, holdings, etc. Depending on the scope of the engagement, you may be asked to
provide copies of the following documents early in the process:
• wills, codicils, and trusts
• insurance policies
• mortgage information
• tax returns
• current financial specifics including W-2s or 1099s
• information on current retirement plans and benefits provided by your employer
• divorce decree or separation agreement
• statements reflecting current investments in retirement and non-retirement accounts
• employment or other business agreements you may have in place, and
• completed risk profile questionnaires or other forms provided by our firm.
Our ability to provide our advisory services depends on access to important information about our clients, and it
is important that the information and financial statements you provide are accurate. Our firm may, but is not
1 State jurisdictions where a firm is currently notice filed can be determined via the SEC’s website at www.adviserinfo.sec.gov.
Jayco Wealth Management, Inc.
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obligated to, verify the information you have provided which will then be used in the financial planning or
investment advisory process. In addition, it is necessary that you provide us with an adequate level of
information and supporting documentation throughout the term of the engagement, including, but not limited
to source of funds, income levels, and an account holder or their legal agent’s authority to act on behalf of the
account, among other information. This helps us determine the appropriateness of our planning and/or
investment strategies for your portfolio.
Financial Planning Services
Our financial planning services may be as broad-based or narrowly focused as you desire. The incorporation of
most or all the noted components allows not only a more thorough analysis but also an in depth view of your
plans to assist you in reaching your goals and objectives. If several or all the services described are provided
together, the total time needed to complete these services may be less than the time it would take to complete
each service separately because of the efficiency gained by combining more than one service.
Cash Flow Analysis and Debt Management
A review of your income and expenses will be conducted to determine your current surplus or deficit and project
your future estimated cash flow position. Based upon the results, we will provide advice on prioritizing how any
surplus should be used, or how to reduce expenses if they exceed your income. In addition, advice on the
prioritization of which debts to repay may be provided, based upon such factors as the debt’s interest rate and any
income tax ramifications. Recommendations may also be made regarding the appropriate level of cash reserves
for emergencies and other financial goals. These recommendations are based upon a review of cash accounts
(such as money market funds) for such reserves and may include strategies to save desired reserve amounts.
Risk Management
A risk management review includes an analysis of your exposure to major risks that could have a significant
adverse impact on your financial picture, such as premature death, disability, property and casualty losses, or
the need for long-term care planning. Advice may be provided on ways to minimize such risks and about
weighing the costs of purchasing insurance versus the benefits of doing so and, likewise, the potential cost of
not purchasing insurance (“self-insuring”). We are not an insurance agency, nor do we have licensed insurance
agents on staff, but we will assist clients in finding a licensed agent if they are interested in acquiring an
insurance contract. We are not compensated for these introductions.
Employee Benefits
A review is conducted and analysis is made as to whether you, as an employee, are taking maximum advantage of
your employee benefits. We will also offer advice on your employer-sponsored retirement plan and/or stock
options, along with other benefits that may be available to you.
Retirement Planning
Retirement planning services typically include projections of the client’s retirement situation given their current
set of circumstances. In situations where projections show room for improvement, it is often necessary to
illustrate alternative retirement scenarios to adjust variables such as retirement date, spending amounts, savings
percentage, retirement income replacement percentages, to assess which scenario yields the most beneficial
results. In addition, if you are near retirement or already retired, advice may be given on appropriate distribution
strategies to minimize the risk of utilizing all retirement assets prematurely.
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Tax Planning Strategies
Advice may include ways to minimize current and future income taxes as a part of your overall financial planning
picture. For example, recommendations may be offered as to which type of account(s) or specific investments
should be owned based in part on their “tax efficiency,” with consideration that there is always a possibility of
future changes to federal, state or local tax laws and rates that may impact your situation.
College Funding
Advice involving college funding may include projecting the amount that will be needed to achieve post-
secondary education funding goals, along with savings strategies and the “pros-and-cons” of various college
savings vehicles that are available. We are also available to review your financial picture as it relates to eligibility
for financial aid or the best way to contribute to grandchildren, if appropriate.
Estate Planning
Our review typically includes an analysis of your exposure to estate taxes and your current estate plan, which may
include whether you have a will, powers of attorney, trusts and other related documents. We may assess ways to
minimize or avoid future estate taxes by implementing appropriate estate planning strategies such as the use of
applicable trusts. We generally recommend that you consult with a qualified attorney when you initiate, update,
or complete estate planning activities. We may provide you with contact information for attorneys who specialize
in estate planning when you wish to hire an attorney for such purposes (we are not compensated for these
introductions). From time to time, we will participate in meetings or phone calls between you and your attorney
with your approval or request.
Divorce Planning
Separation or divorce can have a major impact on your goals and plans. We will work with you to help you gain an
understanding of your unique situation and provide you with a realistic financial picture so that you are in a better
situation to communicate with legal counsel, a mediator or soon to be ex-spouse. We can assist in the completion
of cash flow and net worth projections, budgetary analysis, division of property, as well as help you to understand
what the consequences and/or benefits are involving a settlement.
Investment Consultation
Investment consultation services often involve providing information on the types of investment vehicles
available, employee retirement plans and/or stock options, investment analysis and strategies, asset selection and
portfolio design, as well as limited assistance if your investment account if it is maintained at another
broker/dealer or custodian. The strategies and types of investments that may be recommended are further
discussed in Item 8 of this brochure.
Business Consultation
We are available to assist small businesses in a variety of ways including business strategy, practice management,
general financial advice, debt management, as well as assisting you with matters involving coordination with your
financial institution, attorney or accounting firm.
Process Implementation
We provide services to assist clients in implementing processes and systems to improve operations and financial
efficiency.
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A broad-based plan is an endeavor that requires detail; therefore, certain variables can affect the cost involved in
the development of the plan: the quality of your own records, complexity and number of current investments,
diversity of insurance products and employee benefits you currently hold, size of the potential estate, and special
needs of the client or their dependents, among others. We may concentrate on reviewing only a specific area
(modular planning) per your request, such as an employer retirement plan allocation, college funding or
evaluating the sufficiency of savings plan. When our services focus only on certain areas of your interest or need,
your overall situation or needs may not be fully addressed due to limitations you may have established.
Whether we have created a broad-based or modular plan, we will present you with a summary of our
recommendations customized to your situation, guide you in the implementation of some or all of them, per your
decision, as well as offer you periodic reviews thereafter (see Item 13). Our Limited Fixed Fee Engagement does
not have a written deliverable and this service concludes at the end of the meeting and does not establish an
ongoing client relationship. In all instances involving our financial planning engagements, our clients retain full
discretion over all implementation decisions and are free to accept or reject any recommendation we make.
Portfolio Management Services
You may also engage our firm to implement investment strategies that we have recommended to you. Depending
on your risk profile, goals and needs, among other considerations, your portfolio will involve the employment of
one of our investment strategies as well as either a broad range or more narrowly focused choice of investment
vehicles which are further discussed in Item 8 of this brochure, and our fee rates are noted in Item 5.
Where appropriate, we will prepare investment guidelines reflecting your objectives, time horizon, tolerance for
risk, as well as any account constraints you may have for the portfolio. These guidelines will be designed to be
specific enough to provide future guidance while allowing flexibility to work with changing market conditions. We
will account for any reasonable restrictions you may require for the management of your portfolio, such as
excluding certain types of holdings or investment strategies. We want to note that it will remain your
responsibility to promptly notify us if there is any change in your financial situation and/or investment objectives
for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment
recommendations. Our portfolio management services are conducted under a discretionary trading agreement
(defined in Item 16), and the engagement may include:
• understanding risk tolerance
• investment strategy
• investment guideline development
• asset allocation
• asset selection
• regular monitoring, and
• periodic rebalancing.
As of June 9, 2026, our firm had over $107.9 million of reportable client assets under its management on a
discretionary basis. 2
2 The term “assets under management” and rounding as defined by the SEC’s General Instructions for Part 2 of Form ADV.
Jayco Wealth Management, Inc.
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Item 5 - Fees and Compensation
Forms of payment are based on the types of services being provided, terms of service, etc., and will be stated in
your engagement agreement with the firm. Our published fees may be discounted as determined by our firm. We
strive to offer fees that are fair and reasonable in light of the experience of the firm and the services to be
rendered to our clients. Payment is made via check or draft from US financial institutions as well as through
qualified, unaffiliated PCI compliant third-party processors3 or through your custodian of record maintaining your
account; both requiring your prior authorization. We do not accept cash, money orders or similar forms of
payment for advisory engagements.
Financial Planning Services
Financial planning clients will receive an invoice each time we assess our fee. It will include the fee being charged,
any formula used to calculate our planning fee, the time period covered by the fee, and the fee calculation itself.
Hourly Fees
Limited Engagements (e.g., modular financial planning components) are accomplished via our hourly fee. The
maximum rate is $400 per hour; billed in 15-minute increments and a partial increment (e.g., 10 minutes) is
treated as a whole increment. Prior to entering into an agreement with our firm you will receive an estimate of the
overall cost based on your requirements and the time involved. Payment is due in full upon our delivery of your
plan or advice. We reserve the right to invoice the client for the time involved with their planning engagement
should there be a delay on their part beyond a month. This service does not provide a written deliverable and
concludes at the end of the meeting thereby does not establish an ongoing client relationship.
Fixed Fee
Limited Fixed Fee Engagement, a one-time extended consultation that can include any of the topics listed in Item
4 above at the client’s request. One-time fixed fee based on the complexity of client situation with a rate
between $500 to $2,000. This service does not provide a written deliverable and concludes at the end of the
meeting thereby does not establish an ongoing client relationship.
Broad-Based Financial Plan
We offer our broad-based financial planning services on a fixed fee basis. The fee ranges from $2,500 to
$12,000. The fee takes into consideration factors such as the complexity of your financial profile, the depth of
services to be provided through the engagement, assets that comprise your overall portfolio, number of individual
accounts comprising the portfolio, whether our firm will be assisting in executing transactions for your investment
account(s), time involved in the engagement, etc. Half the quoted fee is due upon the commencement of the
engagement and the remainder upon delivery of plan or advice. We reserve the right to invoice the client in
installments for the time involved with their planning engagement should there be a delay on their part beyond a
month.
Small Business Planning
We offer small business planning with a fixed fee range of $5,000 to $20,000 or a limited engagement billed hourly.
3 For an explanation of the term “PCI,” who the PCI Security Standards Council is, as well as its comprehensive standards to enhance payment
card data security, please go to https://www.pcisecuritystandards.org/security_standards/index.php
Jayco Wealth Management, Inc.
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Retainer Fee
We are typically engaged on a retainer fee basis for divorce planning engagements. The initial retainer fee is
$1,100 and time will be assessed against the retainer at the firm’s hourly rate. Retainer fees are to be paid in full at
the beginning of the engagement. For extended engagements, the firm will send an invoice monthly and will
indicate whether the retainer requires replenishment, and those fees will be due upon your receipt of our invoice.
Portfolio Management Fees
Fees for portfolio management services are assessed an annualized asset-based fee that is paid quarterly, in
arrears. The fee is calculated based on the reporting period ending value of your account (e.g., the last market
day of the quarter), and account asset values are in consonance with the statement you receive from your
custodian of record for the purpose of verifying the computation of our advisory fee. In the rare absence of a
reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g.,
unaffiliated public accounting firm), and you may choose to separately seek such an opinion at your own
expense as to the valuation of “hard-to-price” securities if necessary.
Our portfolio management fee is based on a blended tier as noted in the following table. For example, an
account with assets of $750,000 will be charged an annualized asset-based fee of 1.25% on the first
$499,999 and the remainder would be assessed the lower rate of 1.00%.
Assets Under Management
$0 - $499,999
$500,000 - $1,999,999
$2,000,000 - $9,999,999
$10,000,000-Above
Annualized Asset-Based Fee
1.25% (125 basis points)
1.00% (100 basis points)
0.80% (80 basis points)
0.60% (60 basis points)
For the benefit of discounting your asset-based fee, we may aggregate portfolio management services accounts
for the same individual or two or more accounts within the same family, or accounts where a family member has
power of attorney over another family member’s or incompetent person’s account. Should investment objectives
be substantially different for any two or more household accounts, requiring different investment approaches or
operational requirements, fee schedules may be separately applied.
Your first billing cycle will begin once your agreement is executed and assets have settled into your account held
by the custodian of record. Fees for partial quarters will be prorated based on the remaining days in the reporting
period in which the firm services the account. Fee payments will generally be assessed within the first 15 days of
each billing cycle. By signing our firm’s engagement agreement(s), as well as the selected custodian account
opening documents, you will be authorizing the withdrawal of our advisory fee and any trading charges (e.g.,
brokerage fees, etc.). The withdrawal of these fees will be accomplished by the selected custodian, not by our
firm, and the custodian will remit our fees directly to our firm. We urge you to verify the accuracy of fee
calculations in your account statement; custodians do not verify the accuracy of advisory fee assessments.
Alternatively, you may request to directly pay our advisory firm its portfolio management services fee in lieu of
having the advisory fee withdrawn from your investment account. We will send you a written invoice that includes
the fee due, the formula used to calculate the fee, the fee calculation itself, the time period covered by the fee,
the amount of assets under management on which the fee was based, and the name of the custodian maintaining
your account. Your direct payment must be received by our firm within 15 days of our invoice.
Jayco Wealth Management, Inc.
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Additional Client Fees
Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees,
qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account
holder per the custodian of record’s separate fee schedule. We will ensure you receive a copy of our custodian’s
fee schedule at the beginning of the engagement, and you will be notified of any future changes to these fees by
the custodian of record and/or third-party administrator for certain tax-qualified plans.
Fees paid by our clients to our firm for our advisory services are separate from any of these fees or other similar
charges. Advisory fees for our firm’s services are separate from any transactional charges a client may pay, as
well as those for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), or other
investments of this type.
Per annum interest at the current statutory rate in which the client resides may be assessed on fee balances due
more than 30 days, and we may refer past due accounts to collections or legal counsel for processing. We
reserve the right to suspend some or all services once an account is deemed past due.
Additional information about our fees in relationship to our brokerage practices are noted in Items 12 and 14 of
this document.
External Compensation for the Sale of Securities to Clients
We do not charge or receive a commission or mark-up on your securities transactions, nor do we receive SEC Rule
12b-1 fees (“trails”) from a recommended mutual fund company. Fees charged by issuers are detailed in
prospectuses or product descriptions and you are encouraged to read these documents before investing. You
retain the option to purchase recommended or similar investments through your own selected service provider.
Firm policy does not allow associates to accept or receive additional economic benefits, such as sales awards or
other prizes, for providing advisory services to firm clients.
Termination of Services
Either party may terminate the agreement at any time by communicating their intent to terminate in writing. If
you verbally notify our firm of the termination and, if in two business days following this notification we have not
received your notice in writing, we will make a written notice of the termination in our records and send you our
own termination notice as a substitute. We will not be responsible for investment allocation, advice, or
transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be
necessary that we inform the custodian of record that the relationship between our firm and the client has been
terminated.
Our clients have the right to terminate the engagement without fee or penalty within five business days after
entering into the agreement with our firm. Should a client terminate any financial planning service after the five-
business-day time period, the client may be assessed fees at the firm’s current hourly rate for any time incurred in
the preparation of the client’s analysis or plan. Our portfolio management services are billed in arrears; therefore,
when a client terminates their agreement after the five-business-day period, no refund is to be expected and the
client will be assessed fees on a prorated basis for services incurred from either (i) as a new client, the date of the
engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other accounts, the last
billing period to the date of the firm’s physical or constructive receipt of written termination notice.
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Any earned fees in excess of any prepaid deposit will be billed at the time of termination and will be due upon
receipt of our invoice. The return of payment to a client for our hourly services will only be completed via check
from our firm’s US-based financial institution; no credits or “transaction reversals” will be issued.
Item 6 - Performance-Based Fees and Side-By-Side Management
Our firm’s advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any
portion of managed funds, also known as performance-based fees. Our fees will also not be based on side-by-side
management, which refers to a firm simultaneously managing accounts that do pay performance-based fees (such
as a hedge fund) and those that do not.
Item 7 - Types of Clients
While our current client base consists of individuals and high net worth individuals of all investment experience,
we are available to serve small businesses and their key personnel. We do not require minimum income, asset
levels or other similar preconditions for our financial planning or portfolio management services engagement.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Method of Analysis
When we are engaged to provide investment advice, we will first gather and consider several factors, including
your:
current financial situation and need
interim and long-term goals and objectives
level of investment knowledge
tolerance or appetite for risk, and
reasonable investment restrictions involving your portfolio.
Jayco Wealth Management, Inc. generally employs fundamental analyses. We evaluate economic factors
including interest rates, the current state of the economy, or the future growth of an industry sector. Our
research may be drawn from sources that include financial periodicals, information published by economists and
other industry professionals, as well as annual reports, prospectuses and regulatory filings.
Investment Strategy
We generally orient toward Modern Portfolio Theory; selecting securities whose price movements have
historically low correlations to create efficient portfolios that offer the highest expected return for a given level
of risk, or one with the lowest level of risk for a given expected return. This practice does not employ market
timing or stock selection methods of investing but rather a long term, buy-and-hold strategy with periodic
rebalancing of the account to maintain desired risk levels.
Investments Recommended
We will strive to create portfolios that contain investment vehicles that are diversified, tax-efficient, and low-
cost investments whenever practical. Although it is common to find a broad range of mutual funds or ETFs
within a portfolio, there may be instances where we recommend holding individual security positions (e.g.,
stocks and bonds).
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We may suggest clients’ portfolios retain appreciated stock if deemed necessarily based on economic climate,
tax issues, etc.
Risk of Loss
Our firm believes its strategies and investment recommendations are designed to produce the appropriate
potential return for the given level of risk; however, there is no guarantee that an investment objective or
planning goal will be achieved. Investing in securities involves risk of loss that clients should be prepared to bear.
We have offered examples of such risks in the following paragraphs, and we believe it is important that our
clients review and consider each of these risks prior to investing.
Company Risk
When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk
that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its
value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic
risk and can be reduced or mitigated through diversification.
Failure to Implement
As a financial planning client, you are free to accept or reject any or all of the recommendations made to you.
While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients
who choose not to take the steps recommended in their financial plan may face an increased risk that their
stated goals and objectives will not be achieved.
Financial Risk
Excessive borrowing to finance a business operation increases profitability risk because the company must meet
the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan
obligations may result in bankruptcy and/or a declining market value.
Fundamental Analysis
The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis may not
provide an accurate estimate of earnings, which may be the basis for a security’s value.
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.
Management Risk
An investment with a firm varies with the success and failure of its investment strategies, research, analysis and
determination of its portfolio. If an investment strategy were not to produce expected returns, the value of the
investment would decrease.
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Market Risk
When the stock market as a whole or an industry falls, it can cause the prices of individual stocks to fall
indiscriminately. This is also called systemic or systematic risk.
Passive Investing
A portfolio that employs a passive, efficient markets approach (e.g., Modern Portfolio Theory) has the potential
risk at times to generate lower-than-expected returns for the broader allocation than might be the case for a
more narrowly focused asset class, and the return on each type of asset may be a deviation from the average
return for the asset class. We believe this variance from the expected return is generally low under normal
market conditions when a portfolio is made up of diverse, low or non-correlated assets.
Research Data
When research and analyses are based on commercially available software, rating services, general market and
financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information
or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our
firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome
of events or actions taken or not taken, or the validity of all information researched or provided which may or
may not affect the advice on or investment management of an account.
Security-Specific Material Risks
Equity (Stock) Risk
Common stocks are susceptible to general stock market fluctuations and to volatile increases or decreases in
value as market confidence in and perceptions of their issuers change. If an investor held common stock or
common stock equivalents of any given issuer, they may be exposed to greater risk than if they held preferred
stocks and debt obligations of the issuer.
Exchange-Traded Funds
ETF risks include risks due to their underlying securities (e.g., stocks, bonds, derivatives, etc.), and can be affected
by risks such as market, currency, credit, political, interest rate, etc., that are described in adjacent paragraphs.
The liquidity of the underlying stocks in the index can affect “ETF liquidity.” Liquidity risk can result from an
insufficient number of “active participants” performing their duties as intermediaries and liquidity providers in the
ETF market. “Spread risk” may also occur, which is the difference between the bid and the ask price of a security.
Since ETF transactions are priced throughout the day and are traded on exchanges like stocks, widening spreads
may occur and have impact on certain portfolios or transactions. As with any security, if the ETF “fails,” the
investor may lose their gains and invested principal. ETFs can carry additional expenses based on their share of
operating expenses and certain brokerage fees. Indexed ETFs have the potential to be affected by “active risk;” a
deviation from its stated index.
Leveraged and/or inverse ETFs attempt to achieve multiples of the performance of an index or benchmark through
the opposite (inverse) of the performance of the tracked index or benchmark. This strategy attempts to profit
from, or hedge exposures to, downward drifting markets. There is risk involving this strategy and part of the
concern is due to leveraged and inverse exchange traded funds "reset" daily, which means they are designed to
achieve their stated objectives on a daily basis. It is due to the compounding effect of daily adjustments that ETF
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performance over longer periods of time can differ significantly from the performance (or inverse of the
performance) of an underlying index or benchmark during the same period. This effect is potentially magnified
during volatile markets. If effects contrary to the ETF strategy occur, losses may be significant; therefore,
leveraged and/or inverse ETFs will be considered for portfolios either properly hedged or for clients able to sustain
potentially higher risks. Leveraged and inverse ETFs will not be used in portfolios where a "buy-and-hold"
philosophy is important.
Fixed Income Risks
Various forms of fixed income instruments, such as bonds, money market or bond funds may be affected by
various forms of risk, including:
Call Risk - During periods of falling interest rates, issuers of callable bonds may call (redeem) securities with
higher coupons or interest rates before their maturity dates. The owner of the bond would then lose any
potential price appreciation above the bond’s call price and would be forced to reinvest the unanticipated
proceeds at lower interest rates, resulting in a decline in the owner’s income. Call risk is generally low for
short-term bond funds, moderate for intermediate-term bond funds, high for long-term bond funds, and high
for high-yield bonds.
Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay principal at
maturity, sometimes referred to as “default risk.” Credit risk may also occur when an issuer’s ability to make
payments of principal and interest when due is interrupted. Bondholders are creditors of an issuer and have
priority to assets before equity holders (e.g., stockholders) when receiving a payout from liquidation or
restructuring. When defaults occur due to bankruptcy, the type of bond held will determine seniority of
payment.
Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an increase in
interest rates. The longer the maturity of the bond, the more sensitive its value is to changes in interest rates.
Bond prices and interest rate changes are inversely correlated.
Prepayment Risk - The prepayment risk is the premature return of principal on a fixed-income security. When
principal is returned early on a security, future interest payments will not be paid on that part of the principal.
The owner of the security would lose any price appreciation above the principal and forced to reinvest the
unanticipated proceeds possibly at lower interest rates, resulting in a decline of dividends, income, and
returns. The risk of prepayment is most prevalent in fixed-income securities such as callable bonds and
mortgage-backed securities.
Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or principal
at a lower rate.
State Government and Municipal Securities Risk - State government and municipal securities are subject to
various risks based on factors such as economic and regulatory developments, changes or proposed changes
in the federal and state tax structure, deregulation, court rulings and other factors. Repayment of state and
municipal securities depends on the ability of the issuer or project backing such securities to generate taxes or
revenues. There is also a risk the interest on an otherwise tax-exempt municipal security may be subject to
federal income tax. Unfavorable developments in any economic sector may have far-reaching ramifications on
the overall state and municipal market.
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US Government Securities Risk - United States (US) government securities are subject to varying interest rates
and inflation risks. Not all US government securities are backed by the full faith and credit of the US
government. Certain securities issued by agencies and instrumentalities of the US government are only
insured or guaranteed by the issuing agency or instrumentality, which must rely on its own resources to repay
the debt. As a result, there is risk these entities will default on a financial obligation.
Index Investing
Certain ETFs and indexed funds have the potential to be affected by “tracking error risk” (aka. “active risk”); a
deviation from a stated benchmark.
Liquidity Risk
The inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to
a lack of buyers or sellers. While certain types of fixed income are generally liquid (i.e., bonds), there are risks
which may occur such as when an issue trading in any given period does not readily support buys and sells at an
efficient price. Conversely, when trading volume is high, there is also a risk of not being able to purchase a
particular issue at the desired price.
Money Market Funds
A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value of the fund
may fluctuate, and you could lose money (termed “breaking the buck”). Money market funds are a type of mutual
fund investing in high-quality, short-term debt securities, pay dividends that generally reflect short-term interest
rates and seek to maintain a stable NAV per share (typically $1). An investment in a money market mutual fund is
typically not insured or guaranteed by the Federal Deposit Insurance Corporation, National Credit Union
Association, or any government agency.
Mutual Funds
As with ETFs, the risk of owning an opened-ended or closed-ended mutual fund is reflected in the underlying
security(ies). Mutual funds are affected by risks such as market, interest rate, currency, credit, political, active risk,
etc., as described in adjacent paragraphs. It is important to note that even “conservative” funds, such as a money
market fund or fixed income fund, can and have lost their value below the principal amount invested. Mutual
funds typically carry additional expenses based on their share of operating expenses and trading (brokerage) fees,
which may result in the potential duplication of certain fees paid by the investor. Indexed mutual funds can also be
adversely affected by “QDI ratios” that are described in a following paragraph. There are essentially nine main
types of mutual fund shares classes, as well as sub-classes for some of these. Some mutual funds are sold through
brokerage firms and assess a commission (“load) in addition to their underlying fees earlier noted, while others are
offered through investment advisers, retirement plans and other institutions. “No load” funds are also available to
the public through brokerage firms, and they usually incur trading (brokerage) fees. If a client chooses to purchase
a mutual fund on their own through a broker/dealer, they should consider the trading fees, internal operating
costs, as well as potential commissions they pay through that executing firm. Our firm is not a broker/dealer and
(per Items 5 and 10 of this brochure) does not recommend nor is compensated by a “loaded” fund.
QDI Ratios
While many ETFs and index mutual funds are known for their potential tax-efficiency and higher “qualified
dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods
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within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of
an ETF or mutual fund portfolio), may be considered “non-qualified” under certain tax code provisions. A
holding’s QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio.
Item 9 - Disciplinary Information
Neither the firm nor its management has been involved in any criminal or civil action in a domestic, foreign, or
military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would
reflect poorly upon our offering advisory business or its integrity.
Item 10 - Other Financial Industry Activities and Affiliations
Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of
interest between the firm and its clients, or that may be contrary to law. Jayco Wealth Management, Inc. will
provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of
interest involving its business relationships that might reasonably compromise its impartiality or independence.
Our advisory firm and its management are not registered nor have an application pending to register as a Financial
Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member firm or associated person of
such a firm, nor are we required to be registered with such entities. Neither our firm nor its management is or has
a material relationship with any of the following types of entities:
accounting firm
another investment adviser, to include financial planning firms, municipal advisers, sub-advisers, or third-party
investment managers; nor do we recommend/refer, select, or utilize their services
bank, credit union or thrift institution, or their separately identifiable department or division
insurance company or insurance agency/broker
lawyer or law firm
pension consultant
real estate broker, dealer, or adviser
sponsor or syndicator of limited partnerships
trust company, or
issuer of a security, to include investment company or other pooled investment vehicle (including a mutual
fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,”
and offshore fund).
While Ms. Kramer is certified public accountant (CPA), she is not associated with an accounting firm. She does
not act in the capacity of an accountant to an advisory client, nor does she serve in a role that would be defined
as having physical custody of an account (see Item 15).
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Jayco Wealth Management, Inc. holds itself to a fiduciary standard, which means the firm and its associates will
act in the utmost good faith, performing in a manner believed to be in the best interest of its clients. Our firm
believes that business methodologies, ethics rules, and adopted policies are designed to eliminate or at least
minimize material conflicts of interest and to appropriately manage any material conflicts of interest that may
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remain. You should be aware that no set of rules can possibly anticipate or relieve all material conflicts of
interest. Our firm will disclose to its advisory clients any material conflict of interest relating to the firm, its
representatives, or any of its employees which could reasonably be expected to impair the rendering of
unbiased and objective advice.
Code of Ethics Description
We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm
accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and
professionally responsible manner in all professional services and activities. Firm policies include prohibitions
against insider trading, circulation of industry rumors, and certain political contributions, among others. We
periodically review and amend our Code of Ethics to ensure that they remain current, and we require firm
personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the
firm’s Code of Ethics is made available to any client or prospective client upon request.
Associates that are CERTIFIED FINANCIAL PLANNER® Practitioners, such as Ms. Kramer, also adhere to the Certified
Financial Planner Board of Standards, Inc.’s and these standards can be found at ww.cfp.net.
Statement Regarding our Privacy Policy
We respect the privacy of all clients and prospective clients (collectively termed “customers”), both past and
present. It is recognized that you have entrusted our firm with non-public personal information and it is
important that both access persons and customers are aware of firm policy concerning what may be done with
that information.
The firm collects personal information about customers from the following sources:
• information clients provide to complete their financial plan or investment recommendation
• information clients provide in engagement agreements and other documents completed in connection with
the opening and maintenance of an account
• information customers provide verbally, and
• information received from service providers, such as custodians, about client transactions.
The firm does not disclose non-public personal information about our customers to anyone, except in the
following circumstances:
• when required to provide services our clients have requested
• when our customers have specifically authorized us to do so
• when required during the course of a firm assessment (i.e., independent audit), or
• when permitted or required by law (i.e., periodic regulatory examination).
To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to
protect the privacy of customer information. Within the firm, access to customer information is restricted to
personnel that need to know that information. All access persons and service providers understand that
everything handled in firm offices is confidential and they are instructed not to discuss customer information
with someone else that may request information about an account unless they are specifically authorized in
writing by the customer to do so. This includes, for example, providing information about a spouse’s IRA account
or to adult children about their parents’ accounts, etc.
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The firm will provide you with its privacy policy on a cyclical basis per regulatory guidelines and at any time, in
advance, if firm privacy policies are expected to change.
Firm Recommendations and Conflicts of Interest
Neither the firm nor an associate is authorized to recommend to a client, or effect a transaction for a client,
involving any security in which the firm or a “related person” (e.g., associate, an immediate family member, etc.)
has a material financial interest, such as in the capacity as a board member, underwriter or adviser to an issuer of
securities, etc.
An associate is prohibited from borrowing from or lending to a client unless the client is an approved financial
institution.
The firm remains focused on ensuring that its offerings are based upon the needs of its clients, not resultant fees
received for our services. We note that you are under no obligation to act on a recommendation from our firm
and, if you choose to do so, you are under no obligation to complete them through our firm or a service provider
whom we may recommend.
Our firm does not trade for its own account (e.g., proprietary trading). The firm’s related persons may buy or sell
securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and
this poses a conflict of interest. We mitigate this conflict by ensuring that we have policies and procedures in place
to ensure that the firm or a related person will not receive preferential treatment over a client. In an effort to
reduce or eliminate certain conflicts of interest involving personal trading (i.e., trading ahead of client
recommendation, etc.), firm policy may require that we periodically restrict or prohibit related parties’
transactions. Any exceptions must be approved by the firm, and we will maintain personal securities transaction
records as required.
A client or prospective client leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii)
roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). If our firm recommends that a client roll over their
retirement plan assets into an account to be managed by Jayco Wealth Management, Inc. such a
recommendation may create a potential conflict of interest if our firm would earn new (or increase its current)
compensation as a result of the rollover. We mitigate this potential conflict by analyzing the former employer’s
plan comparing to the client’s options taking multiple factors into account and making a recommendation in the
best interest of the client. No client is under any obligation to roll over retirement plan assets to an account
managed by Jayco Wealth Management, Inc.
Item 12 - Brokerage Practices
Our clients’ accounts must be separately maintained by a qualified, unaffiliated custodian. A broker/dealer,
futures commission merchant, national bank, or trust company that is frequently reviewed for its capabilities to
serve in that capacity by their respective industry regulatory authority. Our firm is not a custodian or
broker/dealer, there is not an affiliate that is a custodian or broker/dealer, nor does a custodian or
broker/dealer supervise our firm, its activities, or our associates. We do not receive referrals from a custodian or
broker/dealer, nor would client referrals be a factor in our recommendation of a custodian or broker/dealer.
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We have entered into an agreement with Charles Schwab & Co., Inc. (“Schwab”) to serve as custodian of record
for our clients. Schwab is a FINRA and SIPC member,4 as well as an SEC-registered broker/dealer. While we
recommend that our clients use Schwab as custodian, they must decide whether to do so and open their account
by entering into an account agreement directly with Schwab. We do not technically open an account for a client,
but we will assist them in doing so.
We seek to engage a custodian who will hold client assets and execute transactions on terms that are overall
advantageous when compared to other available providers and their services. Our firm considers a wide range of
factors, including, among others, these:
combination of transaction execution services along with asset custody services (generally without a separate
fee for custody)
capability to execute, clear and settle trades (buy and sell securities for an account)
capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill
payment, etc.)
breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.)
availability of investment research and tools that assist us in making investment decisions
quality of services
competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and
willingness to negotiate them
reputation, financial strength, and stability of the provider
their prior service to us and our other clients, and
availability of other products and services that benefit us, as discussed below.
When an account is maintained at Schwab, the client is typically not charged separately for custody services and
Schwab are compensated by charging a commission or other fees on trades that Schwab executes or that settle
into a Schwab custodied account. They provide our firm and our clients with access to its institutional brokerage --
trading, custody, reporting, and related services - many of which are not typically available to Schwab “retail
customers.”
Schwab makes available various support services. Some of those services help us manage or administer our
clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally
available to us on an unsolicited basis (we don’t have to request them). Schwab’s institutional brokerage services
include access to a broad range of investment products, execution of securities transactions, and custody of client
assets. The investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services
generally benefit our clients. Schwab makes available to our advisory firm other products and services that benefit
us but may not directly benefit each client’s account. These products and services assist us in managing and
administering our clients’ accounts. They include investment research, both Schwab’s own and that of third
parties. We may use this research to service all or some substantial number of our clients’ accounts, including
accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software
and other technology that:
4 Our firm is not, nor required to be, a Securities Investor Protection Corporation (SIPC) member. See http://www.sipc.org for details.
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provides access to client account data (such as duplicate trade confirmations and account statements)
facilitates trade execution and allocates aggregated trade orders for multiple client accounts
provides pricing and other market data
facilitate payment of our fees from our clients’ accounts, and
assists with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business enterprise, such
as:
educational conferences and events
technology, compliance, legal, and business consulting
publications and conferences on practice management and business succession, and
access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, they may arrange for third-party vendors to
provide the services to us. Schwab may discount or waive its fees for some of these services or pay all or a part of
a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment for
our personnel. Some of the noted tools and services made available by Schwab may benefit our advisory firm but
may not directly benefit a client account. While our firm does not think these services are considered "brokerage
or research services" (aka. “soft dollars”) under Section 28(e) of the Securities Exchange Act of 1934, certain
jurisdictions where we serve client accounts believe they fall under this definition. The availability of these services
benefits our firm because we do not have to produce or purchase them as long as clients maintain assets in
accounts at our recommended custodian. There is a conflict of interest since our firm has an incentive to select or
recommend a custodian based on our firm’s interest in receiving these benefits rather than the client’s interests in
receiving favorable trade execution.
It is important to mention that the benefit received by our firm through participation in any custodian’s program
does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a
custodian is primarily supported by the scope, quality, and cost of services provided as a whole, not just those
services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the
custodian we may select. Our firm conducts periodic assessments of any recommended service provider which
generally involves a review of the range and quality of services, reasonableness of fees, among other items, in
comparison to industry peers.
Best Execution
“Best execution” means the most favorable terms for a transaction based on all relevant factors, including those
listed in the earlier paragraphs. We recognize our obligation in seeking best execution for our clients; however, it
is our belief that the determinative factor is not always the lowest possible cost but whether the selected
custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range
of services provided. Our firm will seek services involving competitive rates, but it may not necessarily correlate
with the lowest possible rate for each transaction. We have determined having our investment management
clients’ accounts trades completed through our recommended custodian is consistent with our obligation to seek
best execution of client trades. A review is regularly conducted regarding our recommendation of a custodian to
clients and considering our duty to seek best execution.
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While our firm has access to a broad range of securities through our preferred custodian, it is a finite number. In
addition, not all investment managers, share classes, etc., are represented at each custodian. Due to these normal
and customary limitations, not all portfolio holdings will be readily available, the least expensive, best performing,
etc. It is an unrealistic expectation for an investor to maintain a premise otherwise.
Directed Brokerage
Not all investment advisers require their clients to direct brokerage, nor do we think our operational relationship
with our custodian is defined as “directed brokerage” per common industry practices. While our internal policy
and operational relationship with our custodian necessitates client accounts custodied with them to have trades
executed per their order routing requirements, we do not direct our custodian as to which executing broker
should be selected for our clients’ trades, whether that is an affiliate of our custodian or another executing broker
of our custodian’s choice. As a result of our preferred custodian’s own trade execution policies, however, a client
may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net
prices on transactions than might otherwise be the case. Since we routinely recommend a particular custodian to
our clients, and that custodian may choose to use the execution services of its broker affiliate for some or all
account transactions, there is an inherent conflict of interest involving our recommendation since our advisory
firm receives various products or services earlier described. Note that we are not compensated for trade
routing/order flow, nor are we paid commissions on such trades. Our firm does not receive interest on an
account’s cash balance.
Client accounts maintained by our preferred custodian under our account master are unable to direct brokerage.
As a result, they may pay higher commissions or other transaction costs, potentially experience greater spreads, or
receive less favorable net prices on transactions for their account than would otherwise be the case if they had the
opportunity to direct brokerage.
For accounts maintained at a custodian of the client’s choice (e.g., held away accounts), the client may choose to
request that a particular broker is used to execute some or all account transactions. Under these circumstances
the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving
their account with that broker, and whether the selected broker is affiliated with their custodian of record or not.
We will not be obligated to seek better execution services or prices from these other executing brokers, and we
will be unable to aggregate transactions for execution via our custodian with other orders for accounts managed
by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially experience
greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the
case.
Aggregating Securities Transactions
Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately
the same time. This may also be termed “blocked” or “batched” orders. Aggregated orders are executed in an
attempt to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple
client accounts should there be differences in prices, brokerage commissions or other transactional costs that
might otherwise be unobtainable through separately placed orders. Our firm may, but is not obligated to,
aggregate orders and we do not receive additional compensation or remuneration because of aggregated
transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the
extent that the firm determines to aggregate client orders for the purchase or sale of securities, including
securities in which a related person may invest, the firm will generally do so in accordance with the parameters set
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forth in SEC No-Action Letter, SMC Capital, Inc. A copy of the referenced No Action Letter will be provided upon
request. Note that when trade aggregation is not allowed or infeasible and necessitates individual transactions
(e.g., withdrawal or liquidation requests, odd-lot trades, etc.), an account may potentially be assessed higher costs
or less favorable prices than those where aggregation has occurred.
Item 13 - Review of Accounts
Schedule for Periodic Review of Client Accounts
Financial Planning Services
Periodic reviews are recommended if you are receiving our financial planning services, and we believe they
should occur at least on an annual basis if practical. Reviews will be conducted by your assigned investment
adviser representative and may involve analysis and possible revision of your previous financial plan or
investment allocation. A copy of revised plans or asset allocation reports will be provided to you upon request.
Portfolio Management Services
Portfolios are reviewed on a frequent basis by Ms. Kramer. Client reviews are completed by your investment
adviser representative, and we recommend that they occur on at least an annual basis; preferably more
frequently if feasible. A copy of a revised investment guideline or asset allocation reports will be provided to the
client upon request.
Review of Client Accounts on Non-Periodic Basis
Financial Planning Services
You should contact our firm for additional reviews when you anticipate or have experienced changes in your
financial situation (i.e., changes in employment, an inheritance, the birth of a new child, etc.), or if you prefer to
modify investment account requirements. Non-periodic reviews are generally conducted by your investment
adviser representative. A copy of revised plans or asset allocation reports will be provided to the client upon
request.
Portfolio Management Services
Additional reviews by firm supervisory personnel may be triggered by news or research related to a specific
holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic
climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or
when an increase in a current position is under consideration. Account cash levels above or below what we deem
appropriate for the investment environment, given the client's stated tolerance for risk and investment
objectives, may also trigger a review.
Content of Client Provided Reports and Frequency
Whether you have opened and maintained an investment account on your own or with our assistance, you will
receive account statements sent directly from mutual fund companies, transfer agents, custodians, or brokerage
companies where your investments are held. We urge you to carefully review these account statements for
accuracy and clarity, and to ask questions when something is not clear. ur firm may provide portfolio
“snapshots” if we are engaged to provide periodic asset allocation or investment advice. We do not provide
ongoing performance reporting under our financial planning engagements.
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Portfolio management services accounts may receive written performance reports from our firm that have been
generated from our custodian’s data systems. Clients are urged to carefully review and compare account
statements that they have received directly from their custodian of record with any performance report they
may receive from our firm.
Item 14 - Client Referrals and Other Compensation
Beyond what had been previously disclosed in Item 12, Jayco Wealth Management, Inc. does not receive
economic benefit from an external source we may recommend to you. We do not engage in solicitation
activities involving unregistered persons. If we receive or offer an introduction to a client, we do not pay or earn
referral fee, nor are there established quid pro quo arrangements. Each client retains the option to accept or
deny such referral or subsequent services.
Item 15 – Custody
Our firm does not take physical custody of a client account. Our clients’ accounts must be maintained by an
unaffiliated, qualified custodian. Accounts are not to be maintained by our firm or any associate of our firm. In
keeping with this policy involving our clients’ accounts, our firm:
restricts the firm or an associate from having general power of attorney over a client account
restricts the firm or an associate from serving as trustee over a client account (unless it is an immediate family
member)
does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm
prohibits the firm or an associate from having the client’s bank or investment account access information (i.e.,
passwords and user identification)
will not collect advance fees of $1,200 or more for services that are to be performed six months or more into
the future, and
prohibits associates from having authority to directly withdraw securities or cash assets from a client account.
Although we may be deemed to have limited (aka. constructive or indirect) custody of an account since we
may request the withdrawal of advisory fees from an investment account, we will do so only on the following
terms:
our firm will possess written authorization from the client to deduct advisory fees from an account held by
their custodian of record
we will send the client’s qualified, unaffiliated custodian a notice of the amount of the fee to be deducted
from the client’s account, and
the client must be able to receive an account statement directly from the account custodian.
does not allow standing letters of authority (SLOAs) unless the:
client provides written instruction to their qualified custodian that includes the client’s signature, the third
party’s name, and either the third party’s address or the third party’s account number at a custodian to
which the transfer should be directed
client authorizes the firm in writing on their qualified custodian’s form any power to direct transfers to the
third party either on a specified schedule or from time to time
client’s qualified custodian performs appropriate verification of the client’s instructions, such as a signature
review or other method to verify the client’s authorization and provides a transfer of funds notice to the
client promptly after each transfer
Jayco Wealth Management, Inc.
Form ADV Part 2A – 07/15/2026
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client can terminate or change the instruction to the client’s qualified custodian
firm has no authority or ability to designate or change the identity of the third party, the address, or any
other information about the third party contained in the client’s instruction
third party is not a related party to our firm and is located at a different address as the firm
client’s qualified custodian sends the client a written initial notice confirming the instruction, and
client is annually provided notice reconfirming their instructions.
The client’s custodian of record will provide account transaction confirmations and account statements, which
include debits and credits, as well as our firm’s advisory fee for that period. Statements are provided on at least a
quarterly basis or as transactions occur within an account. We urge all our clients to inform us if they are not
receiving their trade confirmations or account statements from their custodian. Our firm will not create a separate
account statement for a client nor serve as the sole recipient of a client account statement.
Item 16 - Investment Discretion
As noted in Item 4, we will allow for reasonable restrictions involving the management of your portfolio
management account. It remains your responsibility to notify us if there is any change in your situation and/or
investment objective so that we may reevaluate previous investment recommendations or portfolio holdings.
We provide our portfolio management services on a discretionary basis. Via limited power of attorney signed by
the client, discretionary authority allows our firm to determine the securities to be bought or sold for your account
and the amount of securities to be bought or sold for the account without requiring your ongoing prior
authorization for each transaction in order to meet stated investment objectives. This authority will be granted by
you through the execution of both our engagement agreement and the selected custodian’s account documents.
Note that the custodian will specifically limit our firm’s authority within your account to the placement of trade
orders and the request for the deduction of our advisory fees.
Item 17 - Voting Client Securities
You may periodically receive proxies or other similar solicitations sent directly from your selected custodian or
transfer agent. Should we receive a duplicate copy, note that we do not forward these or any correspondence
relating to the voting of your securities, class action litigation, or other corporate actions.
Our firm does not vote proxies on your behalf, nor do we offer guidance on how to vote proxies. We will not
offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities
litigation or other litigation or proceeding relating to securities held at any time in a client account, including,
without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate,
initiate, supervise or monitor class action or other litigation involving client assets. We will answer limited
questions with respect to what a proxy voting request or other corporate matter may be and how to reach the
issuer or their legal representative.
You will maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of
securities that are beneficially owned by you shall be voted, as well as making all other elections relative to
mergers, acquisitions, tender offers or other legal matters or events pertaining to your holdings. You should
consider contacting the issuer or your legal counsel involving specific questions you may have with respect to a
particular proxy solicitation or corporate action.
Jayco Wealth Management, Inc.
Form ADV Part 2A – 07/15/2026
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Item 18 - Financial Information
Our advisory firm will not take physical custody of client assets, nor do we have the type of account authority to
have such control. Fee withdrawals must be done through a qualified, unaffiliated intermediary (e.g., custodian
of record), and per prior written agreement with the client.
Engagements with our firm do not require that we collect fees from you of $1,200 or more for our advisory
services that we have agreed to perform six months or more into the future.
Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in
which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust.
The firm and its management do not have a financial condition likely to impair its ability to meet commitments
to clients, nor has the firm and its management been the subject of a bankruptcy petition.
Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not
required nor included in this brochure.
Jayco Wealth Management, Inc.
Form ADV Part 2A – 07/15/2026
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