MOSELEY INVESTMENT MANAGEMENT, INC.

Moseley Investment Management, Inc. Disclosure Brochure 1724 Manatee Avenue West Bradenton, FL. 34205 1630 Ringling Boulevard Sarasota, FL. 34236 (941) 745-2799 www.moseleyinvestment.com 2025 This Brochure provides information about the qualifications and business practices of Moseley Investment Management, Inc. If you have any questions about the contents of this Brochure, please contact us at 941-745-2799. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC), or by any state securities authority. Moseley Investment Management, Inc. is a registered investment advisor with the Securities and Exchange Commission (SEC). Registration does not imply any specific level of skill or training. Additional information about Moseley Investment Management, Inc. and our advisory team is available via the SEC’s website at www.adviserinfo.sec.gov or on our company website at www.moseleyinvestment.com. 1  Item 2 - Material Changes The information contained in this section relates only to material changes that have occurred since the last update. We define a material change as any change that an average client would consider important to know prior to making an investment decision. The following are short summaries of the material changes that have occurred since our 2024 annual update with regards to our services or business operations. Item 4 Moseley Investment Management had entered into an agreement with Pontera Solutions, Inc. that allows Moseley Investment Management to perform investment management services to Held-Away-Accounts such as your 401K account. Please refer to Item 4b and 5b for further information. Item 9 A client complaint was filed against Moseley Investment Management Inc. which was settled through mediation. Item 15 We are considered to have custody of our firms 401K Plan because members of our firm serve as trustee to the plan, and we also act as the investment advisor to the plan. We do not have physical custody of any funds and/or securities. Consistent with the rules, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. You may request a copy or our current brochure and brochure supplements (information regarding each of our financial advisors), Form CRS, or our Privacy Policy, by contacting us at the number or email listed below. Moseley Investment Management, Inc. Main Phone: 941-745-2799 Fax Number: 941-746-1424 Web Site Address: http://www.moseleyinvestment.com E-mail Address: info@moseleyinvestment.com 2  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 7 Item 6 – Performance Based Fees 9 Item 7 – Types of Clients 9 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 9 Item 9 – Disciplinary Information 12 Item 10 – Other Financial Industry Activities and Affiliations 12 tem 11 – Code of Ethics 12 Item 12 – Brokerage Practices 12 Item 13 – Review of Accounts 15 Item 14 – Client Referrals and Other Compensation 15 Item 15 – Custody 15 Item 16 – Investment Discretion 15 Item 17 – Voting Client Securities 16 Item 18 – Financial Information 16 3  Item 4a – About Moseley Investment Management Our Firms History: Moseley Investment Management, Inc. (“MIM” “we”, “our”, “us”) is a registered investment advisor (RIA) that was founded in 1990 by Susan Moseley. The firm was established for the purpose of providing clients with comprehensive financial planning, consulting, and portfolio management. We are federally registered with the United States Security and Exchange Commission (SEC), with office locations in Bradenton and Sarasota, FL. *Registration does not imply any specific level of skill or training. Our Principals/Owners Susan Moseley, CIMA, President Ryan T. Moseley, CFA, Vice President Our Investment Committee: Our Investment Committee establishes the overall investment strategies employed by the firm and reviews the overall investments. The Investment Committee members include Susan Moseley, CIMA, Ryan Moseley, CFA, and Laurie Tinnell, CFP ®. Assets under Management: As disclosed in Moseley Investment Management’s ADV Part 1, our regulatory assets under management (RAUM) as of close of business on February 28, 2024, is approximately $409,531,096 of discretionary assets and $839,396 in non-discretionary. In addition to our RAUM, we have approximately $11,315,000.00 in assets under advisement in outside 401k plans. Item 4b- Advisory Business Moseley Investment Management is an investment advisor providing financial planning, consulting and investment advisory services to individuals, pension and profit-sharing plans, estates, and business entities. These services include review of all aspects of your current financial situation with emphasis on income planning, estate planning, insurance planning, investment planning, retirement planning and capital needs planning. To the extent other services are needed, we will assist you in those areas in which it is competent to advise. Initial Consultation: The initial step in the financial planning process involves a meeting or meetings with you for the purpose of defining the scope of the engagement. At this time, through an in-depth interview we will gather your background information about your financial circumstances, investment objectives, and risk tolerance among other things Once defined, we will enter into an Investment Advisory Agreement, disclosing the terms and the fees to be charged. As a follow up, we will also help you coordinate the implementation of any recommendations made, including referral to other practicing professionals whose services may be required. Portfolio Management Services: Portfolio Management Services include the provision of continuous advice to you or investing your account based on your particular circumstances using individual stocks, exchanged traded funds (ETFs), mutual funds, 4  bonds and/ or options. Through personal discussions in which goals and objectives based on your particular circumstances are established, we develop a strategy and create and manage a portfolio based on that strategy. During our data-gathering process, we determine your individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss your prior investment history, as well as family composition and background. We design portfolios based on your objectives and needs determined in the financial planning process. We communicate with you on an ongoing basis to see if your objectives, goals, and financial needs have changed. If there have been significant changes, we discuss updating their plans and their portfolios. We offer Portfolio Management Services on a discretionary or “non-discretionary basis, (see Item 16, Investment Discretion). When acting on a discretionary basis, this means we will buy and sell investments in your account as appropriate without requiring your pre-approval prior to each transaction. When acting on a non- discretionary basis, no trades will be placed without your consent, you will make the final decision on your investments. As part of our standard services, we monitor positions in your accounts on an ongoing basis and conduct account reviews at least annually. Managed Portfolios: The primary investments in our Managed Portfolios are individual securities and/or Exchange Traded Funds (ETF) that meet your objectives. For certain clients, option strategies may be suitable. We mainly sell cash secured puts and covered calls on large US companies to generate income and buy and sell securities. Once we construct an investment portfolio, we will monitor the performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial condition. For the managed portfolios, block trades will be completed and then allocated to individual accounts. For each account that we include in the block trade, we must reasonably believe that the block order is consistent with our duty to seek best execution and may benefit each client participating in the aggregated order. The average price per share of each block trade is allocated to each account that participates in the block trade. Accounts that participate in the same block trade could be charged transaction costs in accordance with their advisory contracts. If a block order cannot be executed in full at the same price or time, the securities purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation. Partial fills will be allocated in a way that does not consistently advantage or disadvantage particular client accounts and are generally filled pro-rata among participating accounts. Personal Asset Allocation: We may personalize a portfolio based on your individual needs and suitability. You may also request restrictions on an account, such as when you need to keep a minimum level of cash or do not want us to buy or sell certain specific securities or security types in the account. These accounts are opened and maintained according to the Investment Advisory Agreement which describes the discretionary authority that you grant to us. Estate and Inheritance Planning As part of our Investment Management Services, we offer Estate and Inheritance Planning. This is a benefit we offer to all clients. If you decide to elect the service, there will be a 1 – 2-hour meeting with the estate attorney to clarify you and your family desired needs and outcomes. You will receive an outline of the steps to achieve your goals. Third-Party Money Managers: We sometimes choose to enter into agreements with third-party investment advisers for the provision of asset allocation and similar advisory services. 5  When we feel it is necessary, a representative may provide personal advisory services to you in the selection of a particular third-party advisory service. Factors considered in selecting third-party advisory service may include but are not necessarily limited to: ● Each individual representative’s preference for a particular third-party advisory service. ● The client’s risk tolerance, goals, and objectives, as well as investment experience ● The amount of client assets available for investment All securities transactions will be decided upon and executed by the third-party advisory service. Our recommendation will be made after considering relevant and applicable information about your financial situation including but not limited to investment objectives, reasonable restrictions, your wants imposed on the management of your account, and assessed risk based upon your assets that constitute your net worth. Third-party Money Managers account minimums and fees are disclosed in each respective manager’s Form ADV and associated paperwork. Termination of third-party money managers are disclosed in each respective manager agreement. Wealth Management and Financial Consulting: We provide a variety of financial consulting services at an hourly rate for those who do not desire ongoing portfolio management services. Our consulting services may address general financial matters or be focused on particular issues, depending upon your needs. Topics may range from overall investment advisory questions, research and analysis, discussions pertaining to the financial impact of a life event, assistance with goals and objectives, 529 college savings plans, analysis and management of employer’s benefit plans, and various other issues as may be requested by you. Generally, such financial consulting services will involve preparing an investment plan based on your financial circumstances and recommendations may be made to help you reach your objectives and goals. When preparing an investment plan, we will consider one or more of the following elements: current position, cash flow, education funding, retirement planning, income tax planning, estate planning, risk management/insurance, and other specific financial concerns. Held Away Accounts (Pontera) We provide an additional service for accounts not directly held in our custody, but where we do have discretion, and may leverage an Order Management System to rebalancing strategies on behalf of the client. These are primarily 401(k) accounts, HSA’s and other assets we do not custody or held at our custodian Charles Schwab. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools as necessary. The Order Management System allows us to manage client accounts on a discretionary basis without having to obtain and maintain a client’s login credentials. Clients using the Order Management System will receive a link allowing them to connect their account(s) to the platform. Once a client account is connected to the Order Management System, we will monitor and rebalance or reallocate investments in that account in the same way as we do for other (non-held away) accounts, though using different tools. When clients engage Moseley Investment Management, Inc.in this capacity, they are responsible to keep the Pontera platform link active, so that we will be able to access and manage the respective account delay. If we determined that an Order Management System link has become inactive, we will use our best efforts to notify the client to resolve the issue. However, clients will remain subject to our fees described in Item 5 and outlined in the clients Investment Advisory Agreement even when we are not capable of executing trades because of an inactive link) ByAllAccounts We have the ability, through services provided by ByAllAccounts, Inc. to provide reporting services on investment assets that are not managed by us (“Excluded Assets”). We do not have trading access to these 6  assets; as such, the client or other authorized person maintains responsibility for trading of these assets. Our obligation related to Excluded Assets is limited to performance reporting and potentially, if contracted to provide investment consulting. Implementation of any recommendations that we provide to a client related to Excluded Assets is the responsibility of the client or the authorized person to the Excluded Assets and not ours. The client or authorized person is responsible for any trading errors, timing of trades, and/or any other errors related to the trading of the account. Additional Service: E-money/The Moseley Virtual Platform: We help you aggregate and organize your financial life by using The Moseley Virtual Platform (MVP). We then align your investments with your goals and review at least annually to ensure they continue to reflect your current needs and sentiments. In order to maintain a full understanding of your financial situation we gladly work with your Attorneys, Insurance and Estate Professionals, Certified Public Accountants, Third Party Administrators, Pension Plan Consultants and Trust Department Advisors Newsletters/ Videos: We will occasionally prepare general, educational, and informational newsletters and videos. Newsletters and videos are always offered on an impersonal basis and do not focus on the needs of a specific individual. Seminar / Workshops: We offer educational, informative, and motivational seminars / workshops to our clients as well as the public. Workshops are always offered on an impersonal basis and do not focus on the individual needs of the participants. Item 5: Fees and Compensation Financial Consulting Services –$350 per hour: We charge an hourly fee of $350.00 per hour for clients who request specific consultant services and do not desire ongoing investment management. The fee is negotiable based upon the complexity of your needs and the level of services rendered. If you engage us for additional ongoing investment management services, we may offset all or a portion of the fee for those services based upon the amount to be paid for the consulting services. Prior to engaging us to provide consulting services, you will be required to enter into a written Agreement with our firm. The Agreement will set forth the terms and conditions of the engagement and describe the scope of the services to be provided and the amount of our fee. We do not require prepayment of fees. After the first meeting with you, and upon completion of the agreed upon services, an invoice detailing the date, services rendered, number of hours and the total amount due will be mailed to you. Payment is due upon receipt of the invoice. Portfolio Management Stock portfolio - Annual fee ranges from .75% to 1.295% Fixed Income portfolio – Annual fee of .5% Portfolio Management fees are billed per quarter and will be charged in advance within 10 days following the beginning of the quarter for which said fees will be incurred. Fees are based on the market value of the clients assets under management on the last trading day of each prior calendar quarter. Fees are usually debited by the custodian from a client’s custodial account and remitted by the custodian to the firm. The custodian does not validate or check our fee, its calculation, or the assets on which the fee is based. Services begin on the effective 7  date on which the Agreement is signed or when the account is funded. In any partial quarter, fees will be adjusted prorate based upon the number of calendar days in the year that the Agreement became effective. The Advisor reserves the right to adjust the fee for accounts depending on the size and type of account and the services required upon 30 days’ prior written notice to the client. Management fees will be prorated for any contribution or distribution of $10,000 or more made within the previous quarter. Each month the client will receive a statement directly from the custodian showing all transactions, positions, and credits/debits in to or from the client’s account; the statement after the quarter-end will reflect the advisory fee paid by the client to us. In some cases, negotiation of fees may result in different fees being charged for similar services and may be less than our stated fee schedule. Held -Away Accounts (Pontera)/ByAllAccounts – Annual .5% to 1% The fee for any held away account will be calculated as described above but will be deducted directly from another client account held at our custodian. In the event there is not a related account to deduct the fee the client will be sent an invoice for payment. In the event of an account termination mid-quarter, the fee will be prorated, and a refund will be credited to your account. You will receive a final invoice detailing the refunded amount and the calculation used. Estate and Inheritance Planning: If you decide to elect this service, we will reduce our fee one time to cover the cost to the attorney. You will sign a one-time check request made payable to the attorney and will be cut from your advisory account held with us. All clients are offered estate and inheritance planning and if you choose not to elect this service, you will not be charged any more or less than our annual portfolio management fee. Emoney Advisor: This service is included in our ongoing investment management services. There is no additional charge to the you. Newsletters/Videos: Newsletters and Videos are provided to all clients and prospective clients free of charge. Seminars / Workshops: No fees are charged for seminars / workshops offered to our clients. On occasion, we may charge a fee for seminars/workshops that we offer to the general public (non-client) to cover expenses. In this case, all fees and payment provisions will be fully disclosed prior to the seminar being presented. Third-party manager: Our fee for accounts managed by a third-party manager will never exceed a total combined fee to the client, (third-party manager fee plus our fee) of 1.295% annually. Our fee will be charged in advance within 10 days following the beginning of the quarter for which said fees will be incurred. Fees are based on the market value of the clients’ assets under management on the last trading day of each prior calendar quarter. Fees are usually debited by the custodian from a client’s custodial account and remitted by the custodian to the firm. The custodian does not validate or check our fee, its calculation, or the assets on which the fee is based. Services begin with the effective date on which this Agreement is signed or when the account is funded. In any partial quarter, fees will be adjusted prorate based upon the number of calendar days in the calendar that the Agreement was effective. The Advisor reserves the right to adjust the fee for accounts depending on the size and type of account and the services required upon 30 days’ prior written notice to the client. Management fees will be prorated for any contribution or distribution of $10,000 or more made within the previous quarter. Each month the client will receive a statement directly from the custodian showing all transactions, positions, and credits/debits into or from the client's account; the statement after the quarter-end will reflect the advisory fee 8  paid by you to us. In some cases, negotiation of fees may result in different fees being charged for similar services and may be less than our stated fee schedule. *Our fee is separate and in addition to the fee charged by the third-party manager. You may also pay transaction charges and should read the third-party managers Form ADV for disclosure of fees and expenses that would be in addition to our fee. Additional Fees and Expenses: Mutual fund investments in the programs that we offer are no-load or load at NAV. Mutual fund investments may be subject to early redemption fees, 12b-1 fees, and mutual fund management fees as well as other mutual fund expenses. These fees are in addition to our fees referenced above and are not paid to us but directly to the mutual fund company. Please review the mutual fund prospectus for full details. You may be subject to transaction fees on securities bought and sold in your Schwab account. The amount of these fees varies depending upon the type of security bought or sold, the amount of assets under management or if you receive paper or electronic confirmations and statements. There could be additional fees relating to IRA and Qualified Retirement Plan accounts that you may incur such as maintenance and termination fees. These fees described above are not paid to us but are paid directly to Schwab. You will find their fees disclosed in the custodian’s account application. Item 12 further describes the factors that we consider when selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Termination: We may terminate our Investment Advisory Agreement with you at any time by providing you with written or electronic notice. Likewise, you may terminate the advisory agreement(s) without penalty upon written or electronic notice. The effective date of termination shall be the date of the notice by the other party, and we will discontinue the management of your account. If notice is within the first five (5) business days of entering into the advisory agreement no fees will be charged. If you wish to terminate the account within the middle of a quarter, your account will be prorated, and a refund will be credited to your account. A final invoice will be sent to you to show the amount that was refunded and how it was calculated. For those who were being billed on an hourly fee basis, and you terminate prior to completion of the services you will be invoiced for time and services rendered. Item 6 – Performance-Based Fees We do not charge performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients We provide portfolio management services to individuals, high net worth individuals, pension and profit- sharing plans, corporations or other business, and charitable organizations. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis: Methods of Analysis: When analyzing investments that may be right for our clients, we use a method called Fundamental Analysis. Fundamental analysis is security analysis grounded in basic factors such as company earnings, balance sheet variables and management quality which are used to predict the future value of an investment. Information such as interest rates, GNP, inflation, and unemployment may be used to predict the direction of the economy and therefore the stock market. 9  Investment Strategies: Subject to suitability requirements, we generally advise the long-term purchase of stocks, exchange traded funds, bonds, and mutual funds to our clients. Investment strategies may be any one or all the following: Long term purchases: Definition – The purchase of securities held at least a year. Short term purchases: Definition – The selling of securities within one year of purchase. Methods of Analysis Risks Fundamental Analysis – When using Fundamental Analysis, we generally rely on, among other things, company earnings, balance sheet variables and management quality which are used to predict the future value of an investment. Data we review is generally considered reliable, but we cannot guarantee, nor have we verified its accuracy. In addition, the data that we review is sometimes subjective in nature and open to interpretation. Even if our data and interpretation of the data is correct, there may be other factors that determine the value of securities other than those considered in Fundamental Analysis. Investment Strategy Risk Long-term purchases – Using a long-term purchase strategy generally assumes the Financial Markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall Financial Markets advance. Purchasing investments long-term may create an opportunity cost - “locking-up” assets that may be better utilized in the short-term in other investments. Short-term purchases – Using a short-term purchase strategy generally assumes that we can predict how Financial Markets will perform in the short-term which may be very difficult. There are many factors that can affect Financial Market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of time. Security Type Risk: Stocks – Investing in stocks involves the assumption of risk including: ● Financial Risk: which is the risk that the companies we recommend may perform poorly which will affect the price of your investment. ● Market Risk: which is the risk that the Stock Market will decline, decreasing the value of the securities the client may hold in their account. ● Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock. ● Political and Governmental Risk: which is the risk that the value of the client’s investments may change with the introduction of new laws or regulations. ETF –Exchange Traded Funds –Investing in ETF’s involves the assumption of risk including: ● Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. ● Market Risk: which is the risk that the Stock Market will decline, decreasing the value of the securities ● contained within the funds. Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the stock. Bonds – Investing in bonds involves the assumption of risk including: ● Interest Rate Risk: which is the risk that the value of the bond investments will fall if interest rates rise. 10  ● Call Risk: which is the risk that your bond investment will be called or purchased back from you when conditions are favorable to the bond issuer and unfavorable to you. ● Default Risk: which is the risk that the bond issuer may be unable to pay you the contractual interest or principal on the bond in a timely manner or at all. ● Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the bond. Mutual Funds – Investing in mutual funds involves the assumption of risk including: ● Manager Risk: which is the risk that an actively managed mutual fund’s investment advisor will fail to execute the fund’s stated investment strategy. ● Market Risk: which is the risk that the Stock Market will decline, decreasing the value of the securities contained within the mutual funds. ● Industry Risk: which is the risk that a group of stocks in a single industry will decline in price due to adverse developments in that industry, decreasing the value of mutual funds that are significantly invested in that industry. ● Inflation Risk: which is the risk that the rate of price increases in the economy deteriorates the returns associated with the mutual fund. Options – Investing in options involves the following risk: ● Selling cash secured puts…the risk is that during the option expiration time the market price drops below strike price, and we buy stock above the market price. ● Selling covered calls…the risk is the market price moves quickly upward during option expiration and we sell stock below market price. ● Put credit spreads: risk is the market price falls below put spread strike prices and we lose the amount of capital put at risk. Private Equity/Credit Funds: - Investing in Private Funds involves the following risk: ● Illiquidity: Investments are typically locked up for an extended period and can be challenging to sell quickly ● Market volatility: Investment can be affected by economic downturns and other external factors that may impact the value of the investments. ● Lack of transparency: Private equity funds often have limited disclosure requirements which can make it difficult for investors to fully understand the underlying investments. ● Regulatory changes affecting fund performance. ● Private equity investments rely on the fund manager's skill in selecting and managing investments, which could vary and impact overall returns. ● Fees: Funds could charge management fees and performance fees, which can erode investor returns over time. Associated Risks: When pursuing our long-term purchases strategy, we are assuming the Financial Markets will go up in the long- term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall Financial Markets advance. In addition, purchasing investments long-term may create an opportunity cost - “locking-up” assets that may be better utilized in the short-term in other investments. 11  Listed above are some of the primary risks associated with the way we recommend investments to our clients, please do not hesitate to contact us to discuss these risks and others in more detail. In instances where we recommend that a third-party manage the client’s assets, please refer to the third-party’s ADV and associated disclosure documents for details on their investment strategies, methods of analysis and associated risks. Investing in securities involves risk of loss that you should be prepared to bear. Item 9 – Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would-be material to your evaluation of us or the integrity of our management. Moseley Investment Management, Inc. resolved a customer-initiated arbitration on January 15, 2025, that alleged sales practice violations related to the customers’ existing concentrated position within their investment accounts. Item 10 – Other Financial Industry Activities and Affiliations We do not have any outside relationship or activities that is material to our advisory business to report. Item 11 – Code of Ethics We have adopted a Code of Ethics (the “Code”) to address securities-related conduct. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes our policies and procedures developed to protect your interests in relation to the following topics: ● The duty at all times to place your interests first; ● The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the Code and to avoid any actual or potential conflict of interest or any abuse of an employee’s position of trust and responsibility; ● The fiduciary principle that information concerning the identity of your security holdings and financial circumstances are confidential; and ● The principle that independence in the investment decision-making process is paramount. We will provide a copy of our Code of Ethics upon request. We may recommend securities to you or buy or sell securities for your account at or about the same time we may buy or sell the same securities in our own account. As such, there may be instances where our interests may appear to be placed ahead of yours. To mitigate this conflict, our firm policy prohibits us from receiving a better price on our order, if you and us invest in the same security on the same side of the market on the same day. Item 12 – Brokerage Practices Charles Schwab, Inc. (Schwab), a registered broker-dealer, member SIPC. We are independently owned and operated and are not affiliated with Charles Schwab. The custodian/brokers we use We do not maintain custody of your assets that we manage or which we advise, although we may be deemed to have custody if you have given us authority to withdraw assets from your account or if we have written permission from you to send funds from a single registration account to your joint account (see Item 15 – Custody, below). Your assets must be maintained in an account at a “qualified custodian.” Generally, a broker- dealer or bank. We use the brokerage and custodial services of Charles Schwab as the qualified custodian. 12  Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them based on written discretionary authority granted by you in our Advisory Agreement. While we require that you use Schwab as custodian/broker, you will decide whether to do so and enter into an account agreement. Conflicts of interest associated with this arrangement are described below as well as in item 14. Please consider these conflicts of interest when selecting your custodian. How we select custodians/brokers We seek to select a custodian that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: . . . . . . . . . . . . . . . • Timeliness of execution
 • Timeliness and accuracy of trade confirmations • Research services provided • Ability to provide investment ideas • Capability to facilitate transfers and payments to and from accounts (wires, check request ect.) • Prior service to us and our clients • Execution facilitation services provided • Record keeping services provided • Custody services provided
 • Frequency and correction of trading errors
 • Ability to access a variety of market venues
 • Expertise as it relates to specific securities
 • Financial condition • Business reputation 
 • Quality of services 
 Your brokerage and custody costs Your accounts that Schwab maintains are not charged a separate custody service fee but may be charged transaction fees on trades that are executed or that settle into their Schwab account. Certain trades (for example many mutual funds and ETFs) may not incur transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like ours. They provide us and our clients with access to its institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to their retail customers. They also make 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 on an unsolicited basis and at no charge to us. Services that benefit the client 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. Services that may not directly benefit the client 13  Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. These services include investment research, software and other technology that: ● Provide access to client account data (such as duplicate trade confirmations and account statements) ● Facilitate trade execution and allocate aggregated trade orders for multiple client accounts ● Provide pricing and other market data ● Facilitate payment of our fees from our clients’ accounts ● Assist with back-office functions, recordkeeping, and client reporting Services that benefit only us. Other services that are offered to us to help us to manage and further develop our business enterprise include: ● Educational conferences and events ● Consulting on technology, compliance, legal, and business needs ● Publications and conferences on practice management and business succession ● Access to employee benefits providers, human capital consultants, and insurance providers ● Marketing consulting and support Schwab may provide some of these services themselves. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. They may also provide us with other benefits, such as occasional business entertainment of our personnel. Our interest in Schwab’s services. The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. (These services are not contingent upon us committing any specific amount of business to them. In trading commissions or assets in custody.) We may have an incentive for us to request that you maintain your account with Schwab, based on our interest in receiving their services that benefit our business rather than based on your interest in receiving the best value in custody services. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality, and price of their services (see “How we select brokers/custodians”) and not Schwab services that benefit only us. It may be that Schwab may charge a higher or lower fee than another broker charges for a particular type of service, such as transaction fees. You may utilize the broker/dealer of your choice and have no obligation to purchase or sell securities through Schwab, however, if you do not use Schwab, we will reserve the right to accept the account. Aggregation The aggregation or blocking of client transactions allows an adviser to execute transactions in a timelier, equitable, and efficient manner and seeks to reduce overall commission charges to you. Our firm’s policy is to aggregate client transactions where possible and when advantageous to clients. In these instances, clients participating in any aggregated transactions will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. Allocation We do not allocate trades in such a way that the Adviser's own (or affiliated) account(s) or selected clients receive more favorable treatment than the Adviser's other client accounts. Allocation procedures should be fair and equitable to all client types with no group being favored or disfavored over any other group. When doing block trading, trade will be entered on the system then allocation using the trade allocation tool on the trading platform. 14  Item 13 - Review of Accounts Our portfolio management team regularly reviews your accounts to assess consistency with the relevant investment strategy and applicable account restrictions. While all securities within the accounts are continually monitored, there are various reconciliations performed that occur daily, monthly and/or quarterly depending on the type of account. Accounts are reviewed in the context of your stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as your individual circumstances, or the market, political or economic environment. You will be contacted at least annually for a client meeting to discuss performance and your financial status. If a meeting is not possible, a report is mailed. Performance is measured against appropriate market indexes. You will receive confirmations and at least a quarterly statement from Schwab. Item 14-Client Referrals and Other Compensation We receive an economic benefit from Schwab in the form of the support products and services they make available to us and other independent investment advisors whose clients maintain their accounts at Schwab. We benefit from the products and services provided because the cost of these services would otherwise be borne directly by us, and this creates a conflict. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item 12-Brokerage Practices). We incentivize employees to develop new business. Any incentives paid to employees will have no impact on the management fee of the investment advisory clients. Moseley Investment Management, Inc. intends to comply with Rule 206(4)-3, (the “Cash Solicitation Rule”), under the Investment Advisers Act of 1940, as amended. Any such solicitation fees will be fully disclosed and in compliance with this Rule. Item 15- Custody Under security regulations, we are considered to have custody when you authorize us to instruct Schwab to deduct our advisory fees directly from your account or we have written permission from you to send funds to a third party such as from a single registration account to your joint account or trust. We are also considered to have custody of our 401K Plan assets because members of our firm serve as trustee to the plan, and we also act as the investment advisor to the plan. We do not have physical custody of any funds and/or securities. Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab at least quarterly. They will be sent to the email or postal mailing address that you provided to Schwab. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from the account(s) each billing period. You should carefully review account statements for accuracy. If you have a question regarding the account statement or if you did not receive a statement from the custodian, please contact us at 941-745-2799. Item 16 – Investment Discretion Generally, we accept both discretionary and non-discretionary accounts. We may request that we be given discretionary authority so that we may provide discretionary asset management services for your accounts. However, you may deny such authority and request that we manage your account on a non-discretionary basis. When you agree to give us discretionary authority, we can place trades in your account prior to each trade without obtaining your permission. Our discretionary authority includes the ability to do the following without contacting you: ● Determine the security to buy or sell: and/or ● Determine the amount of the security to buy or sell 15  In all cases this discretion is to be used in a manner consistent with the stated investment objectives for your account. We will also observe the policies, limitations, or restrictions which you may have given us to follow. Your consent is typically granted and evidenced in the advisory agreement that you sign with us. Item 17 – Voting Client Securities We do not have the authority to vote proxies solicited by, or with respect to, the issuers of securities held in your account. Typically, proxy materials will be forwarded to the you by our custodian. We will forward proxy materials that we may receive directly to you at the address we have on file. Please contact us at any time with questions regarding proxy solicitations. Class Action Lawsuits We utilize the services of a third party, Chicago Clearing Corporation (CCC), to file class action lawsuits on your behalf. When CCC provides these services to clients, they will keep a percentage of the award as payment for their services. You will receive a letter from us disclosing CCC’s fee arrangement and an opportunity to not participate. Any questions regarding CCC’s services or fees should be directed to us by calling 941-745-2799. If at any time the client wishes to not participate in this service, they have the option to opt out by providing our firm written notification. Item 18 – Financial Information We are required in this Item to provide certain financial information or disclosures about our financial condition. We are well capitalized in full compliance with applicable regulations and do not foresee conditions that may impair our ability to meet contractual and fiduciary commitments to our clients and have not been the subject of a bankruptcy proceeding. 16