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Form ADV Part II 11/30/2025
Item 1 – Cover Page
Nestlerode & Loy, Inc.
110 Regent Court, Suite 202
State College, PA 16801
814-238-6249
www.nestlerode.com
11/30/2025
This Disclosure Brochure (“Brochure”) provides information about the qualifications and
business practices of Nestlerode & Loy, Inc. If you have any questions about the contents of
this Brochure, please contact us at 814-238-6249 and/or via email to
banderson@nestlerode.com. The information in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Nestlerode & Loy, Inc. is a registered investment adviser. Registration of an Investment
Adviser does not imply any level of skill or training. The oral and written communications
of an Adviser provide you with information about which you determine to hire or retain an
Adviser.
Additional information about Nestlerode & Loy, Inc. also is available on the SEC’s website at
www.adviserinfo.sec.gov .
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Form ADV Part II 11/30/2025
Item 2 – Material Changes
On July 28, 2010, the United State Securities and Exchange Commission published
“Amendments to Form ADV” which amends the disclosure document that we provide to
clients as required by SEC Rules. This Brochure dated 11/30/2025 is a revised edition of a
new document prepared according to the SEC’s requirements and rules.
The date of our last update of our brochure was 11/30/2024. There are no material
changes included in this iteration of our ADV.
We encourage you to read the Brochure in its entirety.
In the past we have offered or delivered information about our qualifications and business
practices to clients on at least an annual basis. Pursuant to SEC Rules, we will ensure that
you receive a summary of any materials changes to this and subsequent Brochures within
120 days of the close of our business’ fiscal year which is September 30th. We may further
provide other ongoing disclosure information about material changes as necessary.
We will further provide you with a new Brochure as necessary based on changes or new
information, at any time, without charge.
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Form ADV Part II 11/30/2025
Item 3 - Table of Contents
Item 1 – Cover Page ............................................................................................................................................... i
Item 2 – Material Changes ................................................................................................................................. ii
Item 3 - Table of Contents ................................................................................................................................. iii
Item 4 – Advisory Business ............................................................................................................................... 1
Item 5 – Fees and Compensation .................................................................................................................... 1
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................... 3
Item 7 – Types of Clients .................................................................................................................................... 3
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 3
Item 9 – Disciplinary Information .................................................................................................................. 9
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 9
Item 11 – Code of Ethics ..................................................................................................................................... 9
Item 12 – Trading Practices ........................................................................................................................... 11
Item 13 – Review of Accounts ....................................................................................................................... 11
Item 14 – Client Referrals and Other Compensation ........................................................................... 12
Item 15 – Custody .............................................................................................................................................. 12
Item 16 – Investment Discretion ................................................................................................................. 12
Item 17 – Voting Client Securities ............................................................................................................... 13
Item 18 – Financial Information ................................................................................................................... 13
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Form ADV Part II 11/30/2025
Item 4 – Advisory Business
Nestlerode & Loy, Inc, formerly Nestlerode & Co., Inc. has been in business since August 1937. The
principal owner of the firm is Judy L. Loy, CEO. Nestlerode & Loy, Inc. provides continuous investment
advisory supervision, determining the amount, type, and specific investments to buy or sell and
completing the appropriate transactions in each advisory account with full investment discretion.
Within our general investment objectives, we further tailor individual accounts as required by our clients.
For example, we have clients who restrict investment in tobacco firms, firms that make or distribute
alcohol, and firms that produce weapons or weapon systems. Additionally, we tailor our investment
portfolios to meet the requirements of non-profit institutions’ policies for diversification and or
investment restrictions. We offer ESG portfolios for clients through ETF and mutual funds. Tailoring is
done on an individual portfolio basis.
As part of our Investment Advisory services, we work with clients to do an overall financial plan, which
includes but is not limited to:
Social Security Planning, MoneyGuide Pro plans, Retirement Contributions, Retirement Distribution
planning, Charitable Gifts and Debt Management.
Wrap fee programs: None
The amount of client assets managed on a discretionary basis totaled $201,174,777 as of 11/30/2025.
Nestlerode & Loy, Inc. provides discretionary investment advisory services on a fee basis as described
below and provides investment consultation (non-continuous investment advice and planning) upon
request at the rate of $250.00 per hour. Fee is billed monthly until completion of the consultation. The
minimum consultation fee is $500.00. This fee may be reduced due to individual circumstances and work
being delegated to salaried staff.
Item 5 – Fees and Compensation
The specific way fees are charged by Nestlerode & Loy, Inc. is established in a client’s written agreement
with Nestlerode & Loy, Inc. The advisor will generally bill its management fees on a quarterly basis
(three-month intervals, not necessarily at the end of calendar quarters) based on the market value of
each account on the third Friday of the appropriate month.
Individuals may have multiple accounts. Each account will be charged according to its individual
investment objective (IO). Fees may be discounted at the discretion of the Advisor.
An account will consist of equities and/or a combination of equities, fixed income and publicly traded
REITs to achieve the total return expectation and risk tolerance of the client by investing in multiple asset
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classes (i.e. large, mid, small cap stocks, investment grade, high yield and foreign stocks) and various
Form ADV Part II 11/30/2025
investment styles (including but not limited to aggressive growth, growth, growth & income, aggressive
income and asset allocation.)
Annual fee schedule (post 8/2011):
Under $500,000
$500,000 - $2,000,000
$2,000,000 - $5,000,000
Over $5,000,000
1.5% of assets under management
1.0% of assets over $500,000
0.75% of assets over $2,000,000
0.60% of assets over $5,000,000
Please Note: Cash Positions: At any specific point in time, depending upon perceived or anticipated
market conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), Nestlerode & Loy, Inc. maintains cash positions for defensive purposes. All cash positions (money
markets, etc.) shall be included as part of assets under management for purposes of calculating the
advisory fee. Nestlerode & Loy, Inc.’s Chief Compliance Officer, Jody Sharer, remains available to address
any questions that a client or prospective may have regarding the above fee billing practice.
Nestlerode & Loy, Inc. has limited custody solely as a result of receiving fees directly deducted from
client’s funds or securities because Nestlerode & Loy, Inc. possesses written authorization from the client
to deduct advisory fees from an account held by a qualified custodian; sends the qualified custodian
written notice of the amount of the fee to be deducted from the client’s account and; sends the client a
written invoice itemizing the fee, including any formulae used to calculate the fee, the time period
covered by the fee and the amount of assets under management on which the fee is based.
Management fees shall not be prorated for each capital contribution and withdrawal made during the
applicable calendar quarter.
Nestlerode & Loy, Inc.’s fees are exclusive of transaction fees, and other related costs and expenses which
shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, and
other third parties such as fees charged by managers, 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. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a funds’ prospectus. Any 12b-1 paid to the firm in a managed
account is refunded to the client by RBC. First run fixed income offerings may also pay an additional
markup which is disclosed on the trade confirmation. No advisor is paid on markup or ticket charges.
Such charges, fees and commissions are exclusive of and in addition to Nestlerode & Loy, Inc.’s Advisory
fees.
RBC charges an annual fee of $65 per non-retirement account who opt for paper statements,
confirmations, etc., an annual fee of $50 per retirement account under $150,000 and a closing fee of $120
to close a retirement account. RBC also charges a postage charge on each non-mutual fund trade of $3.
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Form ADV Part II 11/30/2025
No fees are payable in advance. New clients may cancel the advisory account within five business days
without charge. Fees are negotiable in certain instances as determined by the advisor and agreed to in
writing by the advisory client. Clients may terminate their agreement with Nestlerode & Loy, Inc. with
written notice at any time. A pro-rated, closing management fee does apply if the account(s) have been
open longer than a five-business day period.
client
e.g.
transactions and determining the reasonableness of their compensation (
,
Item 12 further describes the factors that Nestlerode & Loy, Inc. considers in selecting or recommending
broker-dealers for
commissions).
Item 6 – Performance-Based Fees and Side-By-Side Management
Nestlerode & Loy, Inc. does not charge any 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
Nestlerode & Loy, Inc. provides portfolio management services to individuals, high net worth individuals,
corporate pension and profit-sharing plans, charitable institutions, foundations and endowments and
municipalities and trust programs.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Holding wealth in any form, including cash and government bonds involves the risk of potential loss of
value and or purchasing power. Anyone or any organization accumulating wealth in any form cannot
avoid the possibility of the risk of loss and should understand that there are a number of risks associated
with savings and investment. Risk cannot be totally avoided and must be managed in any investment
management operation.
Nestlerode & Loy, Inc. does not adhere to and has not adopted any singular method of portfolio
management. Indeed, it is our opinion that no singular portfolio strategy is successful in all market
environments. Eventually every portfolio management system, no matter how well grounded in historic
facts, will fail as unanticipated economic and investment circumstances arise. To this end, Nestlerode &
Loy, Inc. practices what we call the “Pay Attention” strategy to portfolio management. With sophisticated
portfolio management software that is updated daily, we watch the performance of all our clients’
portfolios and take note when this performance strays from the expected results. Watching for the
exceptions allows us to correct for errors in our notions about the future value of our clients’ holdings.
As such, attention is paid to the prices of the securities in all our accounts. This is sometimes called
technical analysis or the analysis of price movements of the securities we hold in client accounts. The
bottom line is that our investment performance is totally dependent on the price performance of the
securities held in our client accounts. To assist us with these efforts we use a portfolio management
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Form ADV Part II 11/30/2025
system called PowerAdvisor, FactSet quote and charting computer systems, CircleBlack, MarketSmith
Charting, Nitrogen as well as references from RBC’s technical analysis.
We use fundamental analysis of the economy, investment markets and individual securities using such
sources as RBC Capital Markets, Argus, Credit Suisse, Investor’s Business Daily, UBS, Wall Street Journal,
Value Line Investment Survey, Morningstar, and Barron’s.
We do not frequently trade securities as such costs are contrary to good portfolio performance.
The securities that we place in our clients’ accounts are priced daily and are generally quite liquid,
allowing us to reduce or eliminate positions quickly. We do not buy non-publicly traded securities and do
not recommend them. The ability to price securities daily and sell at any time reduces the risk of loss to
the client. We do not recommend any securities in which Nestlerode & Loy’s officers, owners or directors
have any vested controlling interest. We generally do not use margin accounts to buy securities as it
increases the risk of loss for the client. We typically buy stocks, bonds, municipal bonds, no-load mutual
funds, exchange traded funds and notes, publicly traded real estate investment trusts, government bonds
and certificates of deposit.
All securities fluctuate in price in the markets and as such may be worth more or less than was
committed to them at purchase. Cash and currencies are subject to changes in value as inflation reduces
purchasing power and currency traders make various currencies fluctuate in relation to other currencies.
In our estimation, there is no substitute to continually Paying Attention to the markets, the economy, and
the performance of our clients’ accounts to reduce the risk of an unacceptable outcome. We do not use
complicated schemes or securities to achieve our ends and seek to minimize counter party risk wherever
possible. We monitor outside mutual funds as we would individual securities.
Risk of Loss
All investing and trading activities risk the loss of capital. Although we will attempt to moderate these
risks, no assurance can be given that the investment activities of an account we advise will achieve the
investment objectives of such account or avoid losses. Direct and indirect investing in securities involves
risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or
methods of analysis can or will predict future results, successfully identify market tops or bottoms, or
insulate you from losses due to market corrections or declines. We cannot offer any guarantees or
promises that your financial goals and objectives will be met. Past performance is in no way an indication
of future performance. It is important that you understand the risks associated with investing in the types
of investments and strategies listed above.
Except as may otherwise be provided by law, we are not liable to clients for:
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•
Any loss that you may suffer by reason of any investment decision made or other action taken
Form ADV Part II 11/30/2025
or omitted by us in good faith;
•
Any loss arising from our adherence to your instructions, or the disregard of our
recommendations made to you; or
•
Any act or failure to act by a custodian or other third party to your account.
The information included in this Brochure does not include every potential risk associated with an
investment strategy, technique or type of security applicable to a particular client account. You are
encouraged to ask questions regarding risks applicable to a particular strategy or investment product
and read all product-specific risk disclosures. It is your responsibility to give us complete information
and to notify us of any changes in financial circumstances or goals.
There are certain additional risks associated when investing in securities; including, but not
limited to:
•
Market Risk: Either the stock market as a whole, or the value of an individual company or
fund, goes down resulting in a decrease in the value of client investments. This is also referred to as
systemic risk.
•
Legal and Regulatory Risks: The regulation of the U.S. and non-U.S. securities and futures
markets has undergone substantial change in recent years and such change may continue. In particular,
in light of the recent market turmoil there have been numerous proposals, including bills that have been
introduced in the U.S. Congress, for substantial revisions to the regulation of financial institutions
generally. Further, the practice of short selling has been the subject of numerous temporary restrictions,
and similar restrictions may be promulgated at any time. Such restrictions may adversely affect the
returns of Underlying Investment Funds that utilize short selling. The effect of such regulatory change on
the accounts and/or the underlying investment funds, while impossible to predict, could be substantial
and adverse.
•
Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year,
because purchasing power is eroding at the rate of inflation. The Firm’s portfolios face inflation risk,
which results from the variation in the value of cash flows from a financial instrument due to inflation, as
measured in terms of purchasing power.
•
Market or Interest Rate Risk: The price of most fixed income securities move in the opposite
direction of the change in interest rates. For example, as interest rates rise, the prices of fixed income
securities fall. If the Firm holds a fixed income security to maturity, the change in its price before maturity
may have little impact on the Firm portfolios’ performance. However, if the Firm determines to sell the
fixed income security before the maturity date, an increase in interest rates could result in a loss.
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•
Market Volatility: The profitability of the portfolios substantially depends upon the Firm correctly
Form ADV Part II 11/30/2025
assessing the future price movements of stocks, bonds, options on stocks, and other securities and the
movements of interest rates. The Firm cannot guarantee that it will be successful in accurately predicting
price and interest rate movements.
•
Material Non-Public Information:
By reason of their responsibilities in connection with other
activities of the Firm and/or its principals or employees, certain principals or employees of the Firm
and/or its affiliates may acquire confidential or material non-public information or be restricted from
initiating transactions in certain securities. The Firm will not be free to act upon any such information.
Due to these restrictions, the Firm may not be able to initiate a transaction that it otherwise might have
initiated and may not be able to sell an investment that it otherwise might have sold.
•
Accuracy of Public Information: The Firm selects investments, in part, on the basis of information
and data filed by issuers with various government regulators or made directly available to the Firm by
the issuers or through sources other than the issuers. Although the Firm evaluates all such information
and data and sometimes seeks independent corroboration when it is considered appropriate and
reasonably available, the Firm is not in a position to confirm the completeness, genuineness, or accuracy
of such information and data. In some cases, complete and accurate information is not available.
:
Trading Limitations
For all securities, instruments and/or assets listed on an exchange, including options
listed on a public exchange, the exchange generally has the right to suspend or limit trading under certain
circumstances. Such suspensions or limits could render certain strategies difficult to complete or
continue and subject the account to loss. Also, such a suspension could render it impossible for the Firm
to liquidate positions and thereby expose the Client account to potential losses.
•
Recommendation of Particular Types of Securities:
In some cases, the Firm recommends mutual
funds. There are several risks involved with these funds. These funds have portfolio managers that trade
the fund’s investments in agreement with the fund’s objective and in line with the fund prospectus. While
these investments generally provide diversification there are some risks involved, especially if the fund is
concentrated in a particular sector of the market, uses leverage, or concentrates in a certain type of
security (i.e., foreign equities). The returns on mutual funds can be reduced by the costs of managing the
funds and the shares rise and fall in value according to the supply and demand. Open end funds may have
a diluted effect on other investors’ interest due to the structure of the fund while closed end funds have
limited shares which rise and fall in value according to supply and demand in the market. In addition,
closed end funds are priced daily and as a result they may trade differently than the daily net asset value
(NAV).
•
Firm’s Investment Activities: The Firm’s investment activities involve a significant degree of risk.
The performance of any investment is subject to numerous factors which are neither within the control of
nor predictable by the Firm. Such factors include a wide range of economic, political, competitive and
other conditions (including acts of terrorism and war) that may affect investments in general or specific
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industries or companies. The markets may be volatile, which may adversely affect the ability of the Firm
Form ADV Part II 11/30/2025
to realize profits on behalf of its clients. As a result of the nature of the Firm’s investing activities, it is
possible that the Firm’s results may fluctuate substantially from period to period.
•
Equity (Stock) Market Risk: Common stocks are susceptible to general stock market
fluctuations and to volatile increases and decreases in value as market confidence in and perceptions of
their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you
would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the
issuer.
•
Company Risk: When investing in stock positions, there is always a certain level of company
or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk
and can be reduced through appropriate diversification. There is the risk that the company will perform
poorly or have its value reduced based on factors specific to the company or its industry. For example, if a
company’s employees go on strike or the company receives unfavorable media attention for its actions,
the value of the company may be reduced.
•
Risks Associated with Fixed Income: When investing in fixed income instruments such as
bonds or notes, the issuer may default on the bond and be unable to make payments. Further, interest
rates may increase, and the principal value of your investment may decrease. Individuals who depend on
set amounts of periodically paid income face the risk that inflation will erode their spending power.
•
ETF and Mutual Fund Risk: When investing in an Exchange-Traded Fund (ETF) or mutual
fund, a client will bear additional expenses based on the client’s pro rata share of the ETF’s or mutual
fund’s operating expenses, including the potential duplication of management fees. The risk of owning an
ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund
holds. Clients may incur brokerage costs when purchasing or selling ETFs.
•
Options Risk: Options on securities may be subject to greater fluctuations in value than an
investment in the underlying securities. Purchasing and writing put and call options are highly
specialized activities and entail greater than ordinary investment risks. We do not buy, sell or hold
options.
•
Liquidity Risk: Certain assets may not be readily converted into cash or may have a very
limited market in which they trade. Thus, you may experience the risk that your investment or assets
within your investment may not be able to be liquidated quickly, thus extending the period of time by
which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable
pricing when exiting (i.e., not being able to quickly get out of an investment before the price drops
significantly) a particular investment and therefore, can have a negative impact on investment returns.
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•
Management Risk: Your investments will vary with the success and failure of our investment
Form ADV Part II 11/30/2025
strategies, research, analysis and determination of portfolio securities. If you implement our financial
planning recommendations and our investment strategies do not produce the expected results, you may
not achieve your objectives.
•
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 bonds.
•
Call Risk: Bonds that are callable carry an additional risk because they may be called prior to
maturity depending on current interest rates thereby increasing the likelihood that reinvestment risk
may be realized.
•
Credit Risk: The price of a bond depends on the issuer’s credit rating, or perceived ability to
pay its debt obligations. Consequently, increases in an issuer’s credit risk may negatively impact the value
of a bond investment.
•
Speculation Risk: The securities markets are populated by traders whose primary interest is
in making short-term profits by speculating whether the price of a security will go up or go down. The
speculative actions of these traders may increase market volatility that could drive down the prices of
securities.
•
Geopolitical Risk: The risk an investment's returns could suffer as a result of political changes
or instability in a country. Instability affecting investment returns could stem from a change in
government, legislative bodies, other foreign policy makers or military control.
•
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.
•
Foreign Market Risk: The securities markets of many foreign countries, including emerging
countries, have substantially less trading volume than the securities markets of the United States, and
securities of some foreign companies are less liquid and more volatile than securities of comparable
United States companies. As a result, foreign securities markets may be subject to greater influence by
adverse events generally affecting the market, by large investors’ trading significant blocks of securities,
or by large dispositions of securities, than as it is in the United States. The limited liquidity of some
foreign markets may affect our ability to acquire or dispose of securities at a price and at a time it believes
is advisable. Further, many foreign governments are less stable than that of the United States. There can
be no assurance that any significant, sustained instability would not increase the risks of investing in the
securities markets of certain countries.
•
Counterparty and Broker Credit Risk: Certain assets will be exposed to the credit risk of the
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counterparties when engaging in exchange-traded or off-exchange transactions. There may be a risk of
Form ADV Part II 11/30/2025
loss of assets on deposit with or in the custody of a broker in the event of the broker’s bankruptcy, the
bankruptcy of any clearing broker through which the broker executes and clears transactions, or the
bankruptcy of an exchange clearinghouse.
•
Leverage Risk: Nestlerode and Loy, Inc. does not employ leverage in the implementation of its
investment strategies. However, some Mutual Funds, ETFs and CEFs employ leverage. Leverage increases
returns to investors if the investment strategy earns a greater return on leveraged investments than the
strategy’s cost of such leverage. Although it is not Nestlerode and Loy, Inc.’s strategy to incur margin,
Nestlerode and Loy, Inc. will do so when directed by a client; however, the use of leverage exposes
investors to additional levels of risk and loss that could be substantial.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of Nestlerode & Loy, Inc. or the integrity of
Nestlerode & Loy, Inc.’s management. Nestlerode & Loy, Inc. has no disciplinary events or outstanding
legal items for the firm or its associates.
Item 10 – Other Financial Industry Activities and Affiliations
Judy Lynne Loy is a Registered Investment Advisor and is the Chief Executive Officer/President and
actively manages portfolios. She currently spends twenty percent of her time managing the company and
eighty percent of her time managing portfolios and working with clients. Judy Loy holds a PA Insurance
license for Variable Annuities & Life Insurance through Nestlerode & Loy, Inc. to assist her clients. The
receipt of additional compensation creates a conflict of interest because it provides an incentive to
recommend investment products based on the compensation tied to those products. Investment advisor
representatives of the firm always endeavor to act in your best interest and to only recommend
investments that are suitable for you. We have policies and procedures in place to monitor all client
transactions.
Nicole Luckie is an Associate Advisor. She will apprentice under Judy Loy for the next year before she
will be eligible to take the required examinations required for a Registered Investment Advisor. Nicole
holds a PA insurance license for Variable Annuities & Life Insurance through Nestlerode & Loy. Inc. to
assist her clients. The receipt of additional compensation creates a conflict of interest because it provides
an incentive to recommend investment products based on the compensation tied to those products. We
have policies and procedures in place to monitor all client transactions.
Item 11 – Code of Ethics
Nestlerode & Loy, Inc. has adopted a Code of Ethics for all supervised persons of the firm describing its
high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions
relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of
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rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and
Form ADV Part II 11/30/2025
business entertainment items, and personal securities trading procedures, among other things. All
supervised persons at Nestlerode & Loy, Inc. must acknowledge the terms of the Code of Ethics annually,
or as amended.
Nestlerode & Loy, Inc. anticipates that, in appropriate circumstances, consistent with clients’ investment
objectives, it will cause accounts over which Nestlerode & Loy, Inc. has management authority to effect,
and will recommend to investment advisory clients or prospective clients, the purchase or sale of
securities in which the firm, its affiliates and/or clients, directly or indirectly, have a position of interest.
Nestlerode & Loy, Inc.’s employees and persons associated with the corporation are required to follow
Nestlerode & Loy, Inc.’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers,
directors and employees of Nestlerode & Loy, Inc. and its affiliates may trade for their own accounts in
securities which are recommended to and/or purchased for the firm’s clients. The Code of Ethics is
designed to assure that the personal securities transactions, activities, and interests of the employees of
Nestlerode & Loy, Inc. 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 Nestlerode
& Loy, Inc.’s clients. In addition, the Code requires pre-clearance of many transactions and restricts
trading near client trading activity. 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 continually
monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between Nestlerode &
Loy, Inc., and its clients.
Related persons to the applicant invest for their own account and benefit. Related persons do not enter
into direct transactions in securities with investment advisory clients, although related persons may buy
or sell the same securities in which the investment advisory clients also have an interest. Related persons
may not make any transactions in any securities that would in any way compromise the advisory client in
which the related person has an interest other than that as a non-controlling minority shareholder.
Nestlerode & Loy, Inc. maintains full records on all related person transactions and reviews the same
periodically for insider trading and conflicts of interest.
Certain affiliated accounts who are managed may trade in the same securities with client accounts on an
aggregated basis when consistent with Nestlerode & Loy, Inc.'s obligation of best execution. In such
circumstances, the affiliated and client accounts will share commission costs equally and receive
securities at a total average price. Nestlerode & Loy, Inc. will retain records of the trade order (specifying
each participating account) and its allocation, which will be completed prior to the entry of the
aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled
orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.
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Form ADV Part II 11/30/2025
Nestlerode & Loy, Inc.’s clients or prospective clients may request a copy of the firm's Code of Ethics by
contacting Jody Sharer, Chief Compliance Officer at jsharer@nestlerode.com or 814-238-6249.
It is Nestlerode & Loy, Inc.’s policy that the firm will not affect any principal or agency cross securities
transactions for client accounts in equity securities. Nestlerode & Loy, Inc. will also not cross trades
between client accounts. Principal transactions are generally defined as transactions where an adviser,
acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any
security to any advisory client. A principal transaction may also be deemed to have occurred if a security
is crossed 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 adviser in relation to a transaction in
which the investment adviser, or any person controlled by or under common control with the investment
adviser, 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 adviser is dually registered as a broker-dealer
or has an affiliated broker-dealer.
Item 12 – Trading Practices
Nestlerode & Loy, Inc. suggests, but does not require, that the clients retain Nestlerode & Loy, Inc. as the
broker for the client account. If Nestlerode & Loy, Inc. is the broker, then the firm has the authority to
determine the trading costs paid by clients for securities transactions. Trading costs charged advisory
clients are generally higher than those charged by traditional brokerage firms. This is due to costs from
RBC, the manual entry of trades, manual rebalancing and the relatively small size of the local
advisory/brokerage firm. Mutual fund transactions are done at no cost and non-mutual funds are charged
$19.95 per transaction.
Clients are free to select another broker dealer of their choice. Investment Management maintains a fee
schedule that is lower than many brokers and higher than others for the same or similar services.
Nestlerode & Loy, Inc. as an investment advisor does not suggest or recommend other brokers to
investment advisory clients.
Nestlerode & Loy, Inc. does not engage in what is called soft money purchasing of investment research by
directing brokerage transaction fees on managed accounts to brokerage firms providing investment
research. Research deemed worthy is bought outright for cash from the issuing firm.
Item 13 – Review of Accounts
Accounts are reviewed quarterly with written reports provided to all investment management clients.
Each client receives a monthly brokerage statement, if qualifying activity occurs in the account, from the
broker maintaining custody of the account, typically our clearing firm, RBC CS, detailing all transactions
within the account and a market valuation calculation of the account. Each client receives a quarterly
brokerage statement regardless of activity in the account. Quarterly written reports from the IA include a
complete summary of each account called a "portfolio status report", graphs depicting the performance of
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Form ADV Part II 11/30/2025
the account over time and fees charged to each account. Judy L. Loy and Nicole Luckie are the reviewers
for advisory accounts.
Nestlerode & Loy, Inc. provides each investment advisory client with a written report as of the end of
each calendar quarter. Reports are usually distributed within 40 days of the end of the quarter. Clients
have the option to receive the reports via email. These reports include a "portfolio status report" created
through the PowerAdvisor Software System, which includes the history of each investment (purchase
date, total cost, number of shares, and the name of the investment), the current market valuation (market
price per unit, value of the holding and a calculation showing the gain or loss from the purchase cost), the
percentage each holding is of the entire portfolio and the estimated annual income generated by each
investment. Totals are provided for each appropriate column. In addition, graphs depicting the market
value of the account over time and the relative performance of the account versus a money market fund
and the stock market (as measured by Value Line Geometric Stock Index and the Standard & Poor’s 500
stock average) are provided. In addition, a letter or newsletter, written and edited by Judy L. Loy and
Brian L. Anderson and thoroughly reviewed by Jody Sharer, CCO, is usually provided.
Item 14 – Client Referrals and Other Compensation
Nestlerode & Loy, Inc. does not compensate anyone for providing investment advice nor compensates
any person for client referrals, except for nominal gifts to clients to thank them for referring new clients.
Item 15 – Custody
Clients should receive at least quarterly statements from RBC Clearing & Custody, who is the qualified
custodian that holds and maintains client’s investment assets. Nestlerode & Loy, Inc. urges you to
carefully review such statements and compare such official custodial records to the account statements
that we may provide to you. Our statements may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
Item 16 – Investment Discretion
Nestlerode & Loy, Inc. receives discretionary authority from the client at the outset of an advisory
relationship to select the identity and amount of securities to be bought or sold. In all cases, however,
such discretion is to be exercised in a manner consistent with the stated investment objectives for the
particular client account.
When selecting securities and determining amounts, Nestlerode & Loy, Inc. observes the investment
policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and
restrictions must be provided to the firm in writing.
Judy L. Loy has the authority to effect transactions in investment management accounts with respect to
the securities and the amount of the securities being transacted. These transactions are guided by the
investment objectives of the client and the type of account (IO) the client has with the advisor. The
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advisor is restricted to marketable securities that are generally traded and priced each day the market is
Form ADV Part II 11/30/2025
open. Advisors may not buy options, puts, calls, limited partnerships, commodities, futures, and the like.
Advisors are limited generally to purchasing stocks, bonds (government, corporate and municipal),
mutual funds, exchange traded REITs, foreign stocks, bonds, exchange traded funds and notes and
publicly traded master limited partnerships (MLPs).
Item 17 – Voting Client Securities
As a matter of firm policy and practice, Nestlerode & Loy, Inc. does not have any authority to and does not
vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting
proxies for any and all securities maintained in client portfolios. Nestlerode & Loy, Inc. may provide
advice to clients regarding the clients’ voting of proxies.
Item 18 – Financial Information
Registered investment advisers are required in this Item to provide you with certain financial
information or disclosures about Nestlerode & Loy, Inc.’s financial condition. Nestlerode & Loy, Inc. has
no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients
and has not been the subject of a bankruptcy proceeding.
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