NAYLOR & COMPANY

Item 1. COVER PAGE Firm Brochure (Part 2A of Form ADV) This is the Firm Brochure, also known as Form ADV Part 2, for Naylor & Company Investments, LLC (“Naylor & Company”), Naylor & Company Investments, LLC 735 Miner Road, Orinda, CA 94563 415-741-7280 (telephone) www.naylorinvest.com (website) CRD No. 124924 April 20, 2026 This brochure provides information about the qualifications and business practices of Naylor & Company. If you have any questions about the contents of this brochure, Chad Naylor at chad@naylorinvest.com or at the address, phone number or email address listed above. 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. Being a registered investment advisor representative does not imply any particular level of skill or training and merely denotes that we are registered to provide investment advice and portfolio management. Additional information about Naylor & Company is available on the SEC’s website at www.advisorinfo.sec.gov. . Page 1 of 20  Item 2. MATERIAL CHANGES Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Generally, Naylor & Company Investments, LLC will notify clients of material changes on an annual basis. However, where we determine that an interim notification is either meaningful or required, we will notify our clients promptly. In either case, we will notify our clients in a separate document. Since Naylor & Company’s most recent other-than-annual amendment filing on March 31, 2026, the following material changes have been disclosed: Naylor & Company has applied for registration with the U.S. Securities and Exchange Commission (“SEC”). Page 2 of 20  Item 3. TABLE OF CONTENTS Item 1. Cover Page ....................................................................................................................... 1 Item 2. Material Changes ............................................................................................................. 2 Item 3. Table of Contents ............................................................................................................. 2 Item 4. Advisory Services ............................................................................................................ 3 Item 5. Fees and Compensation ................................................................................................... 4 Item 6. Performance Based Fees and Side-By-Side Management .............................................. 4 Item 7. Types of Clients ............................................................................................................... 4 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 5 Item 9. Disciplinary Information ................................................................................................. 9 Item 10. Other Financial Industry Activities and Affiliations ....................................................... 9 Item 11. Code of Ethics, Participation or Interest In Client Transactions and Personal Trading ................................................................................. 9 Item 12. Brokerage Practices ....................................................................................................... 10 Item 13. Review of Accounts ...................................................................................................... 10 Item 14. Client Referrals and Other Compensation .................................................................... 11 Item 15. Custody ......................................................................................................................... 11 Item 16. Investment Discretion ................................................................................................... 11 Item 17. Voting Client Securities ................................................................................................ 11 Item 18. Financial Information .................................................................................................... 12 Item 19. Requirements of State-Registered Advisers.................................................................. 12 Page 3 of 20  Item 4. ADVISORY SERVICES Naylor & Company Investments, LLC , (“Naylor & Company” and/or the “Firm”) provides investment advice, financial planning and portfolio management to individuals, high net-worth individuals, families, pension and profit-sharing plans, and businesses. The Firm tailors its service to each individual client needs. Naylor & Company has been in business since 2003, and is owned by N&C Advisors, which is owned and managed by Chad Naylor, and Dmitriy Bolotnyy. N&C Advisors also has three passive investors which are long-term clients of Naylor and Company. Naylor & Company will ensure that this relationship does not create any material conflicts of interests regarding fees, trading allocation or other items, and that this relationship does not adversely affect relationships with other clients. Naylor & Company specializes in working with clients to establish investment portfolios of stocks, bonds, ETFs, mutual funds and select alternative private investments. Naylor & Company approaches investments with a fundamental analysis of each company for which it purchases stocks. Naylor & Company seeks to find companies with reasonable valuations as determined by their price to earnings ratios, but with greater growth prospects over the long-term than the average company. Naylor & Company also invests in cyclical companies, whose earnings fluctuate with the growth of the economy. Naylor & Company invests a significant portion of client accounts in the stocks of small and medium-sized companies. These stocks can be more volatile than the stocks of larger companies and there is a risk that the broader market may not recognize the value of these companies, especially over the short-term, which could lead to losses greater than those of the overall market. Although Naylor & Company invests in many of the same stocks for most client accounts, it also customizes client accounts to the specific needs of the individual investor. Typically, this involves varying the amount of cash and bonds in a client’s account to reduce the volatility of the overall portfolio of investments. Each client is interviewed with respect to their investment preferences and Naylor & Company will avoid investing in certain companies or industries that the client wishes to avoid. In addition to providing investment advice, Naylor and Company offer financial planning and consulting on investment-related matters in conjunction with its investment services. These financial planning and consulting services may address areas such as Investment Planning, Retirement Planning, Insurance Planning, Tax Planning, Education Planning, Portfolios Review, Asset Allocation, and Real Estate Planning. Naylor and Company charges a flat fee for financial planning and consulting services. The applicable fee will be based upon the scope and complexity of the engagement. Under certain circumstances the Firm may provide free planning services to individuals. Clients are responsible for determining whether to implement a recommendation and if they decide to do so, are responsible for implementation and ongoing monitoring of the recommended plan. Naylor and Company may act as a Sub-Advisor to other Investment Advisors by offering discretionary asset management services by making certain managed portfolios available for such other Investment Advisers to offer to their clients. The Fee and billing frequency for such services is negotiated directly between Naylor and Company and the Investment Advisor. Naylor and Company’s fees may be in addition to fees charged by their Investment Advisors or Page 4 of 20  incorporated in the fees they charge their clients. Clients that are referred to Naylor and Company are encouraged to discuss how fees are determined with their Investment Advisor and who charges them. Naylor & Company does not sponsor or participate in any WRAP fee programs. As of April 16, 2026, Naylor & Company manages $ 102,292,974 of client assets on a discretionary basis and $ 1,093,870 of client assets on a non-discretionary basis. Item 5. FEES AND COMPENSATION Naylor & Company charges fees for its services based upon a percentage of assets under management. Fees are negotiable, but do not exceed three percent (3%) of assets per year. Fees are calculated and assessed quarterly in advance of the quarter (or in some instances, monthly in advance of the month) for which services are provided. In most instances, fees are collected directly from client accounts by the brokerage company used for the client account, typically, Interactive Brokers. In some instances, Naylor & Company bills the clients directly for its fees. Clients are also responsible for brokerage commissions and mutual fund fees. If Naylor & Company is not paid within 30 days of an invoice, Naylor & Company is entitled to charge interest and/or collect from Client, any, and all of its collection expenses, including reasonable attorneys’ fees. Clients may terminate their investment advisory contracts with thirty (30) days written notice. In the event of termination, clients will receive a pro-rata refund of any prepaid fees for the remainder of the quarterly billing period. As mentioned in Item 4 above, Naylor and Company may enter into a Sub-Advisory arrangement with other Investment Advisors by offers discretionary asset management services by making certain managed portfolios available for such other Investment Advisers to offer to their clients. When entering into a Sub-Advisor arrangement with another Investment Advisor, Naylor and Company will be paid a percentage of the Investment Advisors’ fee it receives from its client(s) that elect to have a portion of their assets managed by Naylor and Company. Apart from the fees noted above from client accounts, neither Naylor & Company, nor its representatives accept any fees or compensation from any brokerage, mutual fund company or any other source Therefore, Naylor & Company has no incentive to select one investment over another apart from the client’s own interest. Clients should be aware that lower fees for comparable services may be available from other investment advisory firms, however, those firms may or may not have obtained similar past performance or use comparable approaches to selecting investments. Item 6. PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT Naylor & Company nor any of its supervised persons accept any performance fees Item 7. TYPES OF CLIENTS Naylor & Company works with individuals, high net-worth individuals, families, pension and profit-sharing plans, and businesses. Page 5 of 20  Clients must have a minimum of $100,000 to open an account with Naylor & Company. In some cases, Naylor & Company may negotiate a lower minimum account size for some special circumstances. Item 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Naylor & Company approaches investments with a fundamental and technical analysis of each company for which it purchases stocks. Naylor & Company seeks to find companies with reasonable valuations as determined by their price-to-earnings ratios, but with greater growth prospects over the long-term than the average company. From time to time, Naylor & Company also invests client accounts in the stocks of some cyclical companies, whose earnings fluctuate with the growth of the economy. Investing in stocks, ETFs, mutual funds, bonds and alternatives involves a risk of loss that clients should be prepared to bear. In addition, investing in these securities involves significant short- term fluctuations that clients should also be prepared to bear. Naylor & Company invests a significant portion of client accounts in the stocks of small and medium-sized companies. These stocks can be more volatile than the stocks of larger companies and there is a risk that the broader market may not recognize the value of these companies, especially over the short-term, which could lead to losses greater than those of the overall market. Although Naylor & Company invests in many of the same stocks for most client accounts, it also customizes client accounts to the specific needs of the individual investor. Typically, this involves varying the amount of cash and bonds in a client’s account to reduce the volatility of the account. However, Naylor & Company may invest some client accounts in more large company stocks, ETFs or mutual funds as their needs or wishes dictate. Each client is interviewed with respect to their investment preferences and Naylor & Company will avoid investing in certain companies or industries that the client wishes to avoid. METHODS OF ANALYSIS Based on the client’s needs, investment objectives and time horizon, Naylor & Company may use one of the following analyses when analyzing investment plans on behalf of its clients. • Fundamental analysis involves analyzing a company’s financial statements and health, its management and competitive advantages, and its competitors and markets. Fundamental analysis is performed on historical and present data but with the goal of making financial forecasts. There are several possible objectives: to conduct a company stock valuation and predict its probable price evolution; to make a projection on its business performance; to evaluate its management and make internal business decisions; and to calculate its credit risk. Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the issuer. • Technical analysis is a method of evaluating securities by relying on the assumption that market data, such as charts of price, volume and open interest can help predict future (usually short-term) market trends. Technical analysis assumes that market psychology influences trading in a way that enables predicting when a stock will rise or fall. The technical indicators that Naylor & Company may consider include, but are not limited to, Page 6 of 20  price, volume, momentum, relative strength, sector/group strength and moving averages. Technical analysis does not consider the underlying financial condition of a company. This presents a risk that a poorly managed or financially unsound company may underperform regardless of market movement. Analysis consists of identifying an investment area or macro-opportunity where a market dislocation has occurred and/or where an extraordinary risk/reward potential exists, identifying prospective best of breed emerging managers in the identified investment area, and analyzing quantitative measurements to determine a potential fit for Naylor & Company’s needs and expectations. INVESTMENT STRATEGIES Naylor & Company always strives to meet the individual investment objectives of each of our clients. During an interview with a new client, will seek to understand the client’s goals and time horizon while also evaluating the client’s risk tolerance through discussion and feedback. The specific methods used to meet client investment objectives will vary but, in general will construct well-diversified investment portfolios that are comprised of low expense ratio, institutional share class mutual funds, ETFs, individual stocks, fixed income, speculative strategies and other securities that are deemed to be appropriate, given the investment profile of a particular client. RISK OF LOSS The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by Naylor & Company. As a general matter, investing in securities involves a risk of loss that investors should be prepared to bear. No guarantee or representation is made that the investment strategies offered by Naylor & Company will be successful. Clients should be able to withstand the loss of their entire investment. Subject to each client’s stated investment objective, examples of such risks include, but are not limited to: a) Risks Pertaining to Certain Investment Types • Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. • Equity: investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. • Fixed Income: investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more Page 7 of 20  pronounced for longer-term securities.). Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. • Exchange Traded Funds (“ETFs”): An ETF is an investment fund traded on stock exchanges, like stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. • Real Estate Funds: (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. b) General Risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar will be worth more today than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Page 8 of 20  • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. • Leveraged Risk: Although Naylor & Company does not employ leverage in the implementation of its investment strategies, some strategies that Naylor & Company allocates client’s assets employ leverage. Leverage increases return to investors if the investment strategy earns a greater return on leveraged investments than the strategy’s cost of such leverage. However, the use of leverage exposes investors to additional levels of risk and loss that could be substantial. c) Acts of God and Geopolitical Risks The performance of an Account could be impacted by Acts of God or other unforeseen including, but not limited to, natural disasters, public health emergencies (including any outbreak or threat of COVID-19, SARS, H1N1/09 flu, avian flu, other coronavirus, Ebola, or other existing or new pandemic or epidemic diseases), terrorism, social and political discord, geopolitical events, national and international political circumstances, and other unforeseen and/or uncontrollable events with widespread impact. These disruptions may affect the level and volatility of security prices and liquidity of any investments. There is risk that unexpected volatility or lack of liquidity will impair an investment’s profitability or result in it suffering losses. Economics and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region will adversely impact markets or securities industry participants in other countries or regions. The extent of the impact of any such disruption on Naylor & Company , clients, Accounts, and any underlying portfolio disruption, the extent of any related travel advisories and restrictions implemented, the impact of such disruption on overall supply and demand, goods and services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption to important global, regional and local supply chains and economic markets, all of which are highly uncertain and cannot be predicted. A disruption may materially and adversely impact the value and performance of any investment, ultimately resulting in significant losses to the Account. In addition, there is a risk that a disruption will significantly impact, or companies. d) Reliance on Technology; Cybersecurity Risk; Back-up Measures Naylor & Company’s operation is dependent on various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities, could be severely compromised by system or component failure, telecommunications failure, power loss, a software-related “system crash”, unauthorized system access or use (such as “hacking”), computer viruses and similar programs, fire or water damages, human errors in using and accessing relevant systems, or various other events or circumstances. It is not possible to provide comprehensive and foolproof protection against all such events, and no assurance can Page 9 of 20  be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunications systems or operations could have a material adverse effect on clients, including by preventing Naylor & Company or its affiliates from trading, modifying, liquidating, and/or monitoring its clients’ investments. In addition, clients should be aware of the risk of attempted cyber-attacks, including denial-of-service attacks, and harm to technology infrastructure and data from misappropriation of corruption. Due to Naylor & Company ’s interconnectivity with third-party vendors, central agents, exchanges, clearing houses, and other financial institutions, Naylor & Company could be adversely impacted if any of them is subject to a cyber-attack or other information security event. Although Naylor & Company takes protective measures and endeavors to modify its operations as circumstances warrant, computer systems, software, and networks may be vulnerable to unauthorized access, issues, computer viruses or other malicious code, and other events that could have a security impact. Naylor & Company has certain backup measures in place for such disruptions, but no assurance can be given that these plans will be realized, or that Naylor & Company’s would be able to resume operations following a business disruption. While this information provides a synopsis of the events that may affect a client’s investments, this list is not exhaustive each client shall understand that there are inherent risks associated with investing and depending on the risk occurrence, a client may suffer a loss of all or part of its’ principal investment. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client should be prepared to bear. Item 9. DISCIPLINARY INFORMATION There has been no disciplinary action ever taken against Naylor & Company or any of its representatives. Item 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Naylor and Company is not a registered broker-dealer, futures commission merchant, commodity pool operator or commodity trading advisor and does not have an application pending to register in any of those capacities. The Firm does not have an application pending to register, as a futures commission merchant, commodity pool operator, or commodity trading advisor. Naylor & Company has no affiliations with other investment advisors, brokers or other investment entities. The Firm does not receive, directly or indirectly, compensation from investment advisors that it recommends or selects for its clients. Item 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Naylor and Company has adopted a Code of Ethics (the “Code”). The Code provides that each employee should place the interests of Naylor and Company’s clients ahead of their own. Each Page 10 of 20  employee is required to conduct all personal securities transactions in a manner that is consistent with the Code and to avoid any actual or potential conflict of interest. No employee may misuse information about client accounts, abuse his or her position of trust and responsibility or take inappropriate advantage of his or her position. The Firm has a policy concerning trading by personnel of the Firm and its employees, the receipt of and giving of gifts, political contribution, and outside business activities, which the Firm believes is reasonably designed to minimize potential conflicts of interest between the Firm and its’ Clients. A copy of the Code is available free upon request to any client or prospective client. Employees of Naylor & Company, will, from time to time, acquire securities for their own or family accounts, The employees of Naylor & Company may give advice or act with respect to their own accounts that may differ in timing or action from the advice given to the client or action taken with respect to the client’s account. Furthermore, Naylor & Company advisors may not acquire for a client’s account a position in a security obtained for their own or family accounts or the accounts of other clients, if in the sole and absolute discretion of Naylor & Company, it is not for any reason practical or desirable to acquire a position in the security for client’s account. When the same securities are purchased or sold for a client’s account and for the accounts of Naylor & Company’s advisors, they will make every reasonable effort to achieve a substantially similar price for those securities. These issues are disclosed to clients here in this Form ADV, Part 2A and in Naylor & Company’s standard investment advisory contract. Item 12. BROKERAGE PRACTICES Pursuant to the terms of its investment advisory contract, Naylor & Company exercises discretion for client accounts with respect to the securities bought and sold, amount of securities bought and sold, prices paid or obtained for securities, brokers used, and commissions rates paid. The primary factor in the recommendation of brokerage firms is the cost of brokerage commissions and fees. Other factors include minimum account balances, timely execution of trades, accuracy and timeliness of account reports, and client wishes. Naylor & Company does not receive any research or soft dollar benefits from the brokerage used for client trades. In addition, Naylor & Company does not receive any client referrals from the brokerage used for client trades. Item 13. REVIEW OF ACCOUNTS Chad Naylor, Naylor & Company’s chief executive officer, is responsible for reviewing all client accounts. Accounts are reviewed at least monthly to determine appropriate security selection. In addition, accounts are reviewed whenever an appropriate security at an appropriate price becomes available for the account and sufficient funds are available for the purchase of the account, and whenever the client informs Naylor & Company of any changes in the client’s financial objectives or resources. Page 11 of 20  Item 14. CLIENT REFERRALS AND OTHER COMPENSATION Naylor & Company, or any of its advisor receive any compensation from client referrals or any compensation other than the direct client fees noted above in Item 5, Fees and Compensation. As mentioned above, if Naylor & Company acts as a Sub-Advisor to other Investment Advisors, the Investment Advisor will be Naylor and Company a fee for the Sub-Advisory services it provides to the Investment Advisor’s clients. Item 15. CUSTODY Naylor & Company does not have custody of client funds. Instead, the custody of client funds is at independent brokers, such as Interactive Brokers. The brokers send out quarterly statements or send email notifications about the availability of statements online. Naylor & Company sends (via email) quarterly invoices to clients. Clients should review statements and invoices to ensure accuracy. Clients provide written authorization permitting Naylor & Company to collect fees in this manner. Naylor & Company will send copies of its invoices to the independent broker/custodian at the same time they are sent to the client. The independent broker/custodian will send quarterly statements to clients showing all disbursements, including the amount of any fees paid to Naylor & Company Item 16. INVESTMENT DISCRETION Pursuant to the terms of its investment advisory contract, Naylor & Company exercises discretion for client accounts with respect to the securities bought and sold, amount of securities bought and sold, prices paid or obtained for securities. Clients may discuss with Naylor & Company any limitations they would like to place on this discretion. Certain assets in client portfolios, including alternative investments, ETFs, fixed income and commodities, are non-discretionary assets. As such, the clients have specifically chosen these investments. Naylor & Company or its advisors will not trade non-discretionary assets without discussing these trades in advance with the clients. Naylor & Company will then document the clients’ investment choices for non-discretionary assets in the Clients’ Questionnaires. If the client decides to change their investment choice for a non-discretionary asset, Naylor & Company will document the change in the Client Questionnaire. As part of the periodic review of client accounts, the Chief Executive Officer will confirm that existing non-discretionary assets are in line with client instructions. If any assets are out of line with instructions, the CEO will direct employees to trade client accounts to bring the non- discretionary assets in line with client instructions. Item 17. VOTING CLIENT SECURITIES Naylor & Company does not vote client securities. From time to time, you may receive solicitations for proxies from various companies, typically forwarded to you from Interactive Brokers, and you may, if you choose, submit your votes on various corporate matters as Page 12 of 20  instructed in the proxy materials. Feel free to contact Chad Naylor or Dmitriy Bolotnyy if you have any questions about these proxy materials. Item 18. FINANCIAL INFORMATION Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure. Neither Naylor and Company nor its management has filed a bankruptcy petition at any time in the past ten years. Item 19. REQUIREMENTS OF STATE-REGISTERED ADVISERS We are registered with the United States Securities and Exchange Commission and therefore this section is not applicable. Page 13 of 20