View Document Text
jb g lobal.com L.L.C.
____________________________________________________
41 East 11 th Street, 11 th Fl
New York, N.Y. 10003
212-388-9873
www.jbglobal.com
January 10, 2026
Investment Advisory Brochure
This brochure provides information about the way we do business. If you have any
questions about this brochure, please contact us at (212) 388-9873 or info@jbglobal.com.
This brochure has not been approved or verified by the United States Securities and
Exchange Commission (SEC) or by any state securities authority. We are a registered
investment advisor. Registration of an investment advisor does not imply any level of skill
or training. Additional information about us is also available on the SEC’s website at
www.advisorinfo.sec.gov by entering JBGlobal.com L.L.C.
Item 2 – Material Changes
This brochure dated January 10, 2026 is a new document prepared according to the SEC’s
new requirements and rules. This brochure contains new and different information from
older documents.
This section will describe only specific material changes and provide you with a summary
of those changes. Our last update of this brochure was on January 8, 2025.
Upon request, we will also send you an up-to-date Brochure at any time, free of charge. As
required by the SEC, we will also send you our updated brochure, or material changes,
annually.
You may request our brochure by contacting James Berman at (212) 388-9873 or
jberman@jbglobal.com.
Material Changes Since Last Update :
Eitan Ventures LLC was liquidated and closed in 2025..
Item 3 -Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
ii
Item 3 –Table of Contents
iii
Item 4 – Advisory Business
1
4
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
5
6
Item 7 – Types of Clients
7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
7
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
8
I tem 11 – Code of Ethics
8
Item 12 – Brokerage Practices
11
Item 13 – Review of Accounts
13
13
Item 14 – Client Referrals and Other Compensation
14
Item 15 – Custody
15
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
15
Item 18 – Financial Information
16
16
Item 19 – Rollovers
Item 4 – Advisory Business
We provide investment advisory services (money management) to individuals, trusts and
foundations. We are 100% owned by James Berman, the Managing Member.
Investment Philosophy
We don’t believe that anyone can “time” the markets or sustainably trade based on guessing
the direction of short-term securities prices. The next short-term uptick or downtick of the
Dow is unknowable; we believe that only a charlatan would pretend otherwise. We,
therefore, apply the only approach that we believe works over time: a long-term investment
strategy rooted in the precepts of value investing. Value investing looks at securities for
what they are: the ownership stakes in businesses in the case of stocks (or the debt
obligations of companies or governments, as in the case of bonds). We try to buy such
securities at discounts to their intrinsic value, as measured by the financial statements. We
try to sell securities at times of excessive optimism, when prices are artificially high, and
then reinvest those proceeds in what we feel is underpriced. We don’t buy or sell based on
charts of stock movements, trading strategies or “hunches.” We believe those strategies are
recipes for eventual failure, no matter the practitioner. We attempt to buy what’s
undervalued and sell what’s overvalued, trying always to reallocate from the expensive to
the cheap. We do this knowing not when the tide will turn, but knowing that it often will.
Good assets return to favor eventually. We eschew market timing, trading and most hedging
strategies, deeming them false comforts, often destined to fail—ironically, just when they’re
needed most. As the saying goes, the market is designed to humiliate the maximum number
of people the maximum number of times. We approach markets with the appropriate
humility, which means ignoring “macro” calls, the next new thing, and all manner of hype
and trend. We typically buy securities or funds in sectors that are unloved, unwanted and
unfashionable—and, hence, cheap. Those looking for a trader, market timer or “seer”
should look elsewhere. Those looking for an investment advisor that makes decisions based
on a deliberative assessment of value should consider working with us.
Our company is wholly owned by James Berman. We have been managing assets since
1996, first mostly as an investment advisor registered with New York State and since July
2011 as an investment advisor registered with the Securities and Exchange Commission.
Registration of an investment advisor does not imply any level of skill or training. As of
January 10, 2026, we have $120,945,234 in assets under management. Schwab
Institutional, a division of Charles Schwab & Co., acts as an independent custodian for our
client accounts and executes trades on behalf of our clients. They also provide the bulk of
our back-office support, including creating and mailing account statements and keeping
track of tax information for separate accounts. We are a completely independent and
separate business from Schwab Institutional.
Item 5 – Fees and Compensation
GENERAL INFORMATION ON FEES:
We provide investment advisory services to individual, separate accounts. These accounts
are managed on a discretionary basis, meaning we make changes to the portfolio without
getting the client’s specific permission for each trade. We tailor these accounts by
determining the proper mix of assets (such as stocks and bonds) to individual client needs
and preferences. We require a minimum of $2,000,000 of assets to manage an account. We
may waive this minimum at our discretion..
We describe those services and fees in Item 6, below.
We charge fees for investment advisory services to individual, separate accounts based on
the following scale:
TOTAL ASSETS MANAGED
Up to $200,000
$200,001-$300,000
$300,001-$500,000
$500,001-$1,000,000
Over $1,000,000
ANNUAL FEE
1.50%
1.25%
1.10%
1.00%
0.95%
We debit the annual fee directly from client accounts in quarterly installments. You will get
your monthly account statement from Charles Schwab & Company showing the charge to
the account at the beginning of each calendar quarter (based upon the account value at the
end of the month before).
The client authorizes the payment of our investment advisory fee directly from their
account. The annual fee is assessed quarterly in arrears (meaning for the prior quarter’s
management) on the value of the total assets in your account(s) managed by us on the last
business day of each calendar quarter. Fees are prorated with regard to inflows and
outflows of cash and other assets. We reserve the right, however, to charge a fee, assessed
for all of the quarter, based on the total assets in your accounts managed by us on the first
day of a calendar quarter, if the client terminates the agreement during that quarter.
We do negotiate account minimums and fees in some cases. You definitely can get similar
investment advisory services at lower cost somewhere else.
Either of us can cancel the client agreement at any time, for any reason, with 30 days’
written notice. Before closing the account, we will charge any earned, unpaid fees.
The fees we charge for investment advisory services are separate and distinct from the fees
and expenses that mutual funds and exchange-traded funds (ETFs) charge their
shareholders. These fees and expenses are described in each fund's brochure (prospectus).
These fees generally include a management fee, other fund expenses, and a possible
marketing fee. If the fund also charges a sales charge, a client may pay an upfront or
back-end sales charge. We will not receive any part of these commissions, fees, and costs.
You could invest in an ETF or mutual fund directly, without our services. To understand the
total amount of fees you pay, you should review both the fees charged by the mutual funds
or ETFs, as well as our fees . It is your responsibility to verify the accuracy of the fee
calculation; the custodian will not determine whether the fee is properly calculated.
Our fees are separate from brokerage commissions, transaction fees, and other related
costs and expenses which Charles Schwab & Company charges. Custodians, brokers, and
other third parties may charge you custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes
on brokerage accounts and securities transactions. We don’t receive any part of these
commissions, fees, and costs. Please see Item 12, below, for additional information on
brokerage.
Item 6 – Performance-Based Fees
We do not charge any performance-based fees.
Item 7 – Types of Clients
We provide investment advisory services (money management) primarily to individuals
and trusts.
We provide investment advisory services to individual, separate accounts. These accounts
are managed on a discretionary basis, meaning we have authorization to make changes to
the portfolio without getting the client’s specific permission before each trade. We tailor
these accounts, by determining the proper mix of assets (such as stocks and bonds) to
individual client needs and preferences. We require a minimum of $2,000,000 of assets to
manage an account. We waive this minimum in certain cases.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
We follow a fundamental “investment” approach, meaning that we try to purchase
securities trading at lower prices than our estimate of their intrinsic value and hold them
until the price is higher than the value, often for long periods of time. We don’t use a
“trading” approach, meaning we don’t buy and sell securities rapidly in an effort to
anticipate the short-term direction of their prices. We only buy and sell securities rapidly
when doing so to harvest tax losses. We mainly analyze company and fund financial
statements in order to choose investments. Investing in securities involves a risk of loss that
you should be prepared to bear. Please note that past performance does not guarantee
future results and that global investment subjects you to significant risks, including, but not
limited to: currency risks, price risks, political risks, interest rate risks, inflation risk,
regulatory risk, tax risk, business risk, default risk, investment risks, credit risks, and
market risks. For a full description of these risks, please contact us.
Item 9 – Disciplinary Information
We are required to disclose all material facts regarding any legal or disciplinary events that
would be important for you to know before you decide to hire us. We are happy to tell you
we have nothing to report and we never have. As long as we’ve been in business, we have
never been the subject of any formal complaints nor been the subject of any disciplinary
proceedings.
Item 10 – Other Financial Industry Activities and Affiliations
In addition to serving as our Managing Member, James Berman teaches Corporate Finance
at NYU SPS as an adjunct professor. He also writes for Forbes.com and other publications on
financial topics. James Berman also participates in other media, such as TV interviews and
webcasts. James Berman publishes eBooks on investing, such as Lessons from the Lemonade
Stand: A Common Sense Primer on Investing . This short introduction to investing attempts to
teach the principles of sound investing by describing everything in the context of a
lemonade stand. This eBook is available for sale through Amazon’s Kindle store, the Apple
iBookstore, Barnes and Noble’s Nook store, and several other eBookstores. The book listing
in the Kindle store can be found at this link:
http://www.amazon.com/Lessons-Lemonade-Stand-Investing-ebook/dp/B00AJRM868/re
f=sr_1_3?ie=UTF8&qid=1355148223&sr=8-3&keywords=lessons+from+the+lemonade+sta
nd
Item 11 – Code of Ethics
JBGLOBAL.com LLC (“JBGLOBAL”) provides investment advisory services to separate
accounts We will always try to serve the client fairly, professionally, and ethically. In order
to ensure such ethical dealings, the following Code of Ethics outlines the basic firm rules
that protect clients.
GENERAL COMPLIANCE PROCEDURES :
A) James Berman is designated as the Chief Compliance Officer for JBGLOBAL.
B) All compliance procedures will be reviewed at least annually for adequacy.
C) All client assets that we directly advise are held at the institutional division of
Charles Schwab & Company, a qualified custodian. All proper procedures and
safeguards shall be taken to make sure that assets remain safeguarded there.
D) We will keep all required records in paper or electronic form. If maintained in
electronic form, records will be able to be printed out in paper form.
E) All valuation of client holdings is performed by Charles Schwab & Co (or their
third-party vendors), based on publicly quoted market prices.
F) All clients are sent annual notice that they are entitled to a copy of our entire ADV
form at any time upon receipt of written request—as required by SEC regulations.
All clients are emailed our Brochure A & B annually.
ADDITIONAL GENERAL COMPLIANCE PROCEDURES :
Client Investment Goals and Risk Tolerance : All clients are instructed to complete a
Confidential Client Questionnaire to document and assess their investment goals, time
horizon and risk tolerance. James Berman then personally reviews this questionnaire with
each client to make sure security investment risks are explained and understood, and to
verify suitability of client security purchases. In cases where a client does not fill out the
Questionnaire completely, James Berman conducts an interview to learn about the Client’s
personal needs and objectives.
Client Phone Calls : When appropriate, material client phone calls are documented
electronically in the Client Notes Folder.
Client Funds/Securities : Clients receive confirmation from Charles Schwab & Co on their
monthly statements when new funds/securities are deposited in their account.
JBGLOBAL has a prohibition on insider trading, a prohibition on rumor mongering,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and
business entertainment items, and personal securities trading procedures.
JBGLOBAL anticipates that in appropriate circumstances – and consistent with clients’
investment objectives – it will purchase or sell in accounts over which JBGLOBAL has
management authority, and will recommend to investment advisory clients (or prospective
clients) securities in which JBGLOBAL, its affiliates and/or clients, directly or indirectly,
have a position of interest. JBGLOBAL’s employees and persons associated with JBGLOBAL
are required to follow JBGLOBAL’s Code of Ethics. Subject to satisfying this policy and
applicable laws, officers, directors and employees of JBGLOBAL and its affiliates may trade
for their own accounts in securities which are recommended to and/or purchased for
JBGLOBAL’s clients. The Code of Ethics is designed to assure that the personal securities
transactions, activities and interests of the employees of JBGLOBAL will not interfere with
(i) making decisions in the best interest of advisory clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts.
Under the Code certain classes of securities have been designated as exempt transactions,
based upon a determination that these would materially not interfere with the best interest
of JBGLOBAL’s clients. Nonetheless, because the Code of Ethics in some circumstances
would permit employees to invest in the same securities as clients, there is a possibility that
employees might benefit from market activity by a client in a security held by an employee.
Employee trading is monitored under the Code of Ethics, and to reasonably prevent
conflicts of interest between JBGLOBAL and its clients.
Certain affiliated accounts may trade in the same securities with client accounts on an
aggregated basis when consistent with JBGLOBAL's obligation of best execution.
JBGLOBAL’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting James Berman.
JBGLOBAL’s policy is that we will not execute any principal or agency cross securities
transactions for client accounts. JBGLOBAL will also not cross trades between client
accounts, meaning we will not sell securities from one account to another. Principal
transactions are trades where an advisor, acting as principal for its own account (or the
account of an affiliated broker-dealer), buys from or sells any security to a client. A
principal transaction may also be a trade where a security is sold between an affiliated
hedge fund and another client account. An agency cross transaction is defined as a
transaction where a person acts as an investment advisor in relation to a transaction in
which the investment advisor (or any person controlled by or under common control with
the investment advisor) acts as broker for both the advisory client and for another person
on the other side of the transaction. Agency cross transactions may arise where an advisor
is dually registered as a broker-dealer or has an affiliated broker-dealer. JBGlobal is not
registered as a broker-dealer and does not have an affiliated broker-dealer.
For the full Code of Ethics and complete compliance procedures, please request the
JBGLOBAL Compliance Manual, which is available upon request.
Item 12 – Brokerage Practices
When you hire us as your advisor, we will require you to give us one-time written
authorization to choose which securities (and the amounts of those securities) to buy and
sell without getting your permission first. This is called “discretionary authority.”
Any limits on this discretionary authority must be included in this written authorization.
You may change these limits as needed. You must send these changes to us in writing.
We require you to use Charles Schwab & Company as broker and custodian for your assets.
You consent to this choice in the contract you sign. In our opinion, Charles Schwab &
Company charges reasonable discount brokerage commission rates and transaction fees.
Charles Schwab executes many (but not all) mutual fund and ETF trades at no transaction
fee. After thorough review, we believe these rates are a fair and competitive value. If we
purchase a mutual fund with a transaction fee, we first make sure that there is not a similar
or suitable no-transaction fee fund that could be purchased instead. On occasion,
no-transaction fee funds have higher overall expense ratios. In those cases, we will usually
choose the transaction fee share class in return for the greater savings over time by owning
a lower expense ratio fund. Transaction fees, which are typically of relatively small dollar
amounts, should not be confused with “loads” which are substantial commissions paid on
fund purchases. We do not purchase funds that actually require clients to pay loads. We do
sometimes purchase “load” funds, but only where the load has been waived.
We believe that Charles Schwab & Company provides best execution of all trades placed in
client accounts. To evaluate best execution, we periodically review reports created by Rules
11Ac1-5 and 11Ac1-6. We periodically review best execution data for Charles Schwab &
Company (including performance in price improvement, orders executed at or better than
National Best Bid or Offer (NBBO), speed and how the order is executed in relation to the
NBBO at the time the order is placed) and how their performance compares to industry
averages for speed, price and liquidity in trade execution. Consolidating the bulk of our
trades at one broker runs the risk that we may miss the opportunity to reduce costs or
improve execution by putting trades through multiple brokers. However, we believe that
Schwab's statistics are generally better than the industry average. We also believe that the
cost savings and convenience of having one consolidated brokerage platform--with the
wide selection of no-load mutual funds available through Schwab's platform--make Schwab
the best choice for all of our client trades at the current time.
Given our requirement that clients use Charles Schwab & Company, our ability to achieve
best execution may be partly or completely limited because we may not get trade
executions of the nature, quality, speed or price that we might otherwise get if we were
using another broker. We are not able to negotiate commission rates with Schwab or affect
the price or quality of their execution services. Given the reasonable nature of Schwab's
commission rates and the quality of Schwab's execution, however, we believe our use of
Schwab is in our clients’ best interests.
Our trade error policy is that we pay for any trade errors if the trade error would cost the
client any material amount of money.
We may buy or sell securities identical to those purchased for customers for their
personal accounts. We may execute trades on a non-aggregated or aggregated basis.
Non-aggregation could conceivably lead one client to get worse execution pricing or
timing than another client on any given security. It may also lead to variability and
dispersion of performance and returns across different client accounts. On the other hand,
aggregation could conceivably lead to worse execution pricing on large block trades that
represent a significant percentage of the daily volume of a particular security.
Aggregation can also take more time to execute if the number of accounts involved is
relatively small, thus leading to a delay which could miss an opportunistic price. We
balance these various risks on a case-by-case basis.
“Soft dollars" refer to payments or services advisors receive from a broker in exchange for
directing clients to that broker at inflated commission costs. We do not have any “soft
dollar” arrangements. We do not believe “soft dollars” are in the best interest of clients.
Although Charles Schwab & Company provides access to both proprietary and third-party
research on its website free of charge as a service to all advisors that use its platform, we
don’t believe we pay commission rates that are higher in exchange for such research. Given
the cost of our average trades, we don’t believe we substantially pay more for trades, or
more than we would anywhere else, if we did not receive such access to research. We do not
receive any payment from Schwab or any other broker. In any case, research provided by
Schwab is used to the benefit of all clients. We do not receive any payment (or in-kind
services) for rent, salary, travel, or overhead from Schwab, any other broker, or from any
third party other than from advisory clients and from subscribers or buyers of our
publications.
Item 13 – Review of Accounts
James Berman, the Managing Member of JBGlobal.com L.L.C.L, conducts the investment
review for all accounts. James Berman reviews the allocation and securities in client
accounts regularly and makes adjustments on a periodic basis. Changes in valuation,
economic, political or market circumstances may lead to adjustments in a client account.
Changes in security prices (relative to intrinsic value) or changes in the client’s individual
circumstances are most likely to cause us to make adjustments in client accounts.
Charles Schwab & Company sends monthly statements to individual account clients. These
statements show balances, all transactions and account activity. Additionally, James Berman
sends a Quarterly Letter with market commentary to individual account clients.
Item 14 – Client Referrals and Other Compensation
We don’t receive any commissions, compensation or economic benefit from non-clients in
exchange for providing investment advisory services to clients.
We do not pay anyone for client referrals.
Item 15 – Custody
Charles Schwab & Company holds all separate client advisory assets in separate accounts.
You will receive monthly statements from Schwab. We urge you to carefully review these
statements and compare these official custodial records to the account statements or
reports that we may send you. Our statements may vary from Schwab’s custodial
statements based on accounting procedures, reporting dates, or valuation methods of
certain securities.
SEC registered advisors are deemed to have custody based solely on their ability to deduct
advisory fees directly from client accounts. We debit fees directly from client accounts and,
therefore, are deemed to have “custody” on this basis under SEC rules. For separate
accounts, the debits of our fees are reflected on the account statements you receive from
Schwab. We are also deemed to have custody in situations where standing transfer
instructions authorize a transfer from any Schwab account to another account of a
third-party. In such cases, all seven of the SEC’s conditions from their Custody No-Action
Letter have been met and, therefore, no surprise exam is required.
Item 16 – Investment Discretion
When you hire us as your advisor, we will require you to give us one-time written
authorization to choose which securities (and the amounts of those securities) to buy and
sell without getting your permission first. This is called “discretionary authority.” We will
carry out our discretionary authority in line with your investment preferences, risk
tolerance, time horizon and personal needs.
Any limits on this discretionary authority must be included in this written authorization.
You may change these limits as needed. You must send these changes to us in writing.
Item 17 – Voting Client Securities
We don’t receive proxies or have the authority to vote proxies for clients. We allow them to
receive and vote proxies themselves.
Item 18 – Financial Information
We are required to provide you with certain financial information or disclosures about our
financial condition that would affect our ability to operate. We have no financial
commitment that impairs our ability to meet contractual and fiduciary commitments to
clients, and we have not been the subject of any bankruptcy proceeding.
Item 19- Rollovers, Particularly of Retirement-Plan Assets to Individual Retirement
Accounts
In 2021, the so-called “fiduciary rule” adopted by the United States Department of Labor
Under the fiduciary rule, we and our personnel may be considered
became effective.
fiduciaries under the Employee Retirement Income Security Act of 1974 (“ ERISA ”) and the
Internal Revenue Code of 1986.
Beginning February 1, 2022, investment advisors that
provide fiduciary advice in connection with making an individual retirement account (an
“ IRA ”) or other retirement account rollover recommendations must comply with prohibited
transaction exemption PTE 2020-02.
We charge a level investment-management fee, a fee based on assets under management,
that does not vary on the basis of the investment advice provided. Consequently, we are not
engaging in a prohibited transaction.
In addition to other investment advisory services
provided, we may receive a level investment-management fee from one or more clients in
connection with providing advice to roll the assets from (1) a retirement plan into an IRA,
(2) a retirement plan to another retirement plan, or (3) an IRA to another IRA. Under any
of these scenarios, when providing fiduciary investment advice in the context of a rollover
recommendation, we must comply with PTE 2020-02.
Pursuant to PTE 2020-02, each client to whom we provide investment advice with respect
to his retirement plan or IRA will review and sign a confirmation that we have disclosed the
advantages and disadvantages of staying in the existing retirement plan as opposed to
transferring the assets to us for management or, if permitted and eligible, to a retirement
plan of a new employer.
In the confirmation, the client will specify the reasons why a
recommendation to transfer assets from one retirement plan or IRA to another retirement
plan or IRA is in his best interests.