Overview
- Headquarters
- Powell, OH
- Average Client Assets
- $2.2 million
- SEC CRD Number
- 121382
Fee Structure
Primary Fee Schedule (SHUTTLEWORTH & CO ADV PART 2A AND PART 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $4,000,000 | 0.75% |
| $4,000,001 | $10,000,000 | 0.65% |
| $10,000,001 | and above | Negotiable |
Minimum Annual Fee: $1,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $39,000 | 0.78% |
| $10 million | $71,500 | 0.72% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- HNW Share of Firm Assets
- 71.89%
- Total Client Accounts
- 483
- Discretionary Accounts
- 483
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: SHUTTLEWORTH & CO ADV PART 2A AND PART 2B (2026-04-14)
View Document Text
Item 1: Cover Page
Form ADV Part 2A-Disclosure Brochure
Effective: April 2026
Shuttleworth & Company
3807 Attucks Drive,
Powell, OH 43065
614-760-7738
www.sco-advisors.com
This Brochure provides information about the qualifications and business practices of
Shuttleworth & Company (CRD#: 121382). Please contact Erin Maynard if you have any
questions about the contents of this brochure at 614-760-7738 or by email at erin@sco-
advisors.com.
Shuttleworth & Company is a registered Investment Advisor. The information in this
brochure has not been approved or verified by the SEC or by any other States’ Securities
Regulating Bodies. Registration of an Investment Advisor does not imply any specific level
of skill or training.
Additional information about Shuttleworth & Company and its advisory persons are
available on the SEC’s website at www.adviserinfo.sec.gov by searching for our firm name
or by our CRD #121382.
1
Item 2: Material Changes
The purpose of this page is to inform interested parties of any material changes SCO has made
since the last annual amendment update.
SCO has made the following material changes to our Firm Brochure since our last annual
amendment update was filed in March 2026.
We will provide ongoing disclosure information about material changes, as necessary.
• David Shuttleworth Trust is no longer an owner of SCO. See Item 4 for more information.
also
available on our website
Our disclosure brochure may be requested by contacting us at 614-760-7738 or info@sco-
advisors.com. Our brochure
at https://sco-
is
advisors.com/regulatory-disclosures.
2
Item 3: Table of Contents
Item 1 - Cover Page
Page 1
Item 2 - Material Changes
Page 2
Item 3 - Table of Contents
Page 3
Item 4 - Advisory Business
Page 4-6
Item 5 - Fees and Compensation
Page 6-8
Item 6 - Performance Based Fees and Side-by-Side Management
Page 8
Item 7 - Types of Clients
Page 8
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Page 8-11
Item 9 - Disciplinary Information
Page 11
Item 10 - Other Financial Industry Activities and Affiliations
Page 11
Item 11 - Code of Ethics, Participation in Client Transactions, Personal Trading
Page 12-13
and Qualified Plan Rollovers
Item 12 - Brokerage Practices
Page 13-15
Item 13 - Review of Accounts
Page 15
Item 14 - Client Referrals and Other Compensation
Page 16
Item 15 - Custody
Page 16
Item 16 - Investment Discretion
Page 17
Item 17 - Voting Client Securities
Page 17
Item 18 - Financial Information
Page 18
Form ADV Part 2 B: Brochure Supplement - E.M. Maynard and M.R. Freiburger
Page 19-24
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Item 4: Advisory Business
Firm Information and Advisory Service
The business activities of Shuttleworth & Company (hereafter “SCO”) consist of providing
investment advisory services. David L. Shuttleworth, founded SCO in March 1999. Erin M.
Maynard and Matthew R. Freiburger are equal owners and shareholders in the firm. Erin Maynard
is the Chief Compliance Officer as of January 1, 2025.
SCO renders continuous management of accounts and provides advice to clients as to investment
of funds based on an individual client’s needs and suitability. SCO utilizes a balanced long-term
investment strategy. Therefore, suitable clients include individuals (including trusts and estates),
pension funds, charitable organizations, and other entities with established funds that have long
time horizons. Established goals and objectives serve as guidelines that portfolio managers of
Shuttleworth & Company use for investment management decisions. Advisory services are
performed in general on a discretionary basis. No client account participates in a wrap-fee program.
SCO has under its management the following assets as of December 31, 2025:
Discretionary
$173,016,187
Non-Discretionary
$0
Retirement Plan Rollover Recommendations - When SCO provides investment advice about your
retirement plan account or individual retirement account (“IRA”) including whether to maintain
investments and/or proceeds in the retirement plan account, roll over such investment/proceeds
from the retirement plan account to an IRA or make a distribution from the retirement plan account,
we acknowledge that SCO is a “fiduciary” within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as
applicable, which are laws governing retirement accounts. The way SCO makes money creates
conflicts with your interests, so SCO operates under a special rule that requires SCO to act in your
best interest and not put our interest ahead of yours.
Under this special rule’s provisions, SCO must act as a fiduciary to a retirement plan account or
IRA under ERISA/IRC:
• Meet a professional standard of care when making investment recommendations (e.g.,
give prudent advice).
• Never put the financial interests of SCO ahead of you when making recommendations
(e.g., give loyal advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that SCO gives advice that is in
your best interest.
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• Charge no more than is reasonable for the services of SCO; and
• Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account
to an individual retirement account managed by SCO, please know that SCO and our investment
advisor representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your account
at the retirement plan to an IRA managed by SCO. We will earn fewer investment advisory fees if
you do not roll over the funds in the retirement plan to an IRA managed by SCO.
Thus, our investment advisor representatives have an economic incentive to recommend a rollover
of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on our
economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have adopted an impartial conduct standard to manage this conflict of interest whereby our
investment advisor representatives will (i) provide investment advice to a retirement plan
participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary
status described below, (ii) not recommend investments which result in SCO receiving
unreasonable compensation related to the rollover of funds from the retirement plan to an IRA,
and (iii) fully disclose compensation received by SCO and our supervised persons and any material
conflicts of interest related to recommending the rollover of funds from the retirement plan to an
IRA and refrain from making any materially misleading statements regarding such rollover.
When providing advice to your regarding a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances then
prevailing that a prudent person acting in a like capacity and familiar with such matters would use
in the conduct of an enterprise of a like character and with like aims, based on the investment
objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the
financial or other interests of SCO or our affiliated personnel.
SCO will generally require that anyone whose functions or duties relate to providing investment
advice possess a CFA, ChFC, or CPA designation, Series licensing, and/or experience judged by
SCO’s management to be comparable to the above.
Management Services for Held Away Accounts
SCO offers an additional service directly to clients that have accounts held away from SCO where
SCO has discretion and may use a third-party platform to facilitate the management of held away
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accounts. SCO regularly reviews the available investment options in these accounts, monitors
them, rebalances, and implements our strategies in the same way we do other accounts, though
using different tools as necessary.
Item 5: Fees and Compensation
Fee Schedule
Annual fees for investment management services are calculated using a tiered billing system, based
upon the market value of the account. The fee is the sum of the results from applying the following
annual rates:
Assets Under Management
Assets Under Management
Assets Under Management
Assets Under Management
Lower Range
0
1,000,001
4,000,001
10,000,001
Rate
Upper Range
1.00%
1,000,000
0.75%
4,000,000
10,000,000
0.65%
And above Negotiable
This is a blended fee. This means that the assets in a client’s account will be billed at different
levels according to the fee schedule above. Each asset tier shall be assessed a fee percentage in
accordance with the schedule shown above. The cumulative fee percentage for the account shall
be a blended rate based on the fee percentages applied to each asset tier.
For example, if a client had an account value of $3,000,000, the following equation would be used
to calculate their quarterly fee: ($1,000,000 x 1.00%) + ($2,000,000 x 0.75%) = $10,000 + 15,000
= $25,000 annual fee / 4 quarters = $6,250 quarterly fee.
Clients are offered the choice of being billed or consenting to a direct fee withdrawal from their
account. If you choose to have the investment advisory fees deducted from your account, you must
authorize the qualified custodian(s) of your account to deduct fees from your account and pay such
fees directly to SCO. If you choose to pay the fees after receiving a statement, fees are due upon
your receipt of a billing notice sent directly to you. The billing notice will detail the assets under
management and the time period covered. Fees for our firm's services are due immediately after
receiving the billing notice.
The annual minimum fee is $1,000. This is generally charged regardless of account size but is
subject to the discretion of the management of SCO for each account and may be negotiated.
Fees are payable quarterly in arrears based upon the beginning market value of the account at each
billing period. The fee structure may differ based upon factors such as account size, cash flow,
related accounts, investment limitations, and other special requests. Additionally, SCO reserves
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the right to customize fees concurrent with specific and unique advice if the client and advisor
believe it is in the best interest of both parties.
Clients also can hire SCO to manage their held-away accounts, including Employer Sponsored
Retirement Plan accounts (401k, 403b, 457, etc.) and college savings accounts (529
plans). Management services by SCO of held away accounts are offered under a separate
management fee schedule. Currently, the annual fee for the management of college saving plans
and some legacy employer sponsored retirement plans are a flat annual fee in the range of $500-
$1,000. Most accounts held away from SCO require the use of a third-party platform to avoid
having custody of Client funds. If a third-party platform is deemed necessary by SCO when
managing the held away assets, the annual fee will be 0.50% in place of the annual flat fee of $500-
$1,000.
When SCO is engaged for this type of management service, an Employer Sponsored Retirement
Account Supplement Investment Management and Advisory Agreement is signed by the client
which states the fee amount for this service. In certain circumstances mutual fund investments are
used. Clients invested in mutual funds pay an additional investment management fee to the mutual
fund advisor. Each investment advisory contract may be terminated by either party prior to its
stated expiration date, if any, upon 30 days written notice to the other. Any earned portion of
SCO’s fees not previously billed will be billed to the client on a prorated basis upon such early
termination.
No compensation arrangements are permissible with outside parties for the management or
employees of SCO.
As stated above, SCO offers discretionary management services for accounts held away from SCO
via a third-party platform to facilitate management of these assets. The platform allows SCO to
avoid being considered to have custody of client funds since we do not have direct access to client
log-in credentials to affect trades. We are not affiliated with the platform in any way and receive
no compensation from them for using their platform. A link will be provided to the client allowing
them to connect an account(s) to the platform to assist SCO to view and manage the account(s).
Client agrees to promptly address any requests to update its login credentials when requested by
the third-party system. Once client account(s) are connected to the platform, SCO will review the
current account allocations. When deemed necessary, SCO may rebalance the account considering
client investment goals and risk tolerance, current allocations and current economic and market
trends.
When clients utilize the third-party platform for discretionary management of their held away
accounts, SCO charges an annual fee of 0.50%, billed and payable quarterly in arrears, based on
the account value at the beginning of the quarter. SCO does not charge the client for use of the
platform. The Advisory Fee payable for any accounts on this third-party platform will be deducted
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directly from another Client account or invoiced to the Client as agreed upon by SCO and Client
in advance.
If the held away accounts at the third-party custodian are transferred to SCO, this separate
management fee will be terminated, and the assets will fall under the current management fee
schedule of SCO, as disclosed above. Client may cancel the use of the third-party platform at any
time through the third-party. The client agrees to compensate SCO through the effective
termination date or date the assets transfer to SCO’s custodian.
Item 6: Performance Based Fees and Side-by-Side Management
SCO does not offer performance-based fee arrangements (fees based on a share of capital gains or
on the substantial appreciation of client’s assets). Performance-based fees can potentially create a
conflict of interest. This arrangement can induce an advisor to take inappropriate risk in its
portfolio management to maximize returns (and its related fees) thereby potentially putting the
client’s investments at higher risk.
Item 7: Types of Clients
type of client can be
found on
SCO offers investment advisory services to individuals, high net worth individuals, pension and
profit-sharing plans, and non-profit companies domiciled in the United States. The percentage of
the Form ADV Part 1A, Section 5 at
each
https://adviserinfo.sec.gov/firm/summary/ 121382. These percentages are subject to change and
are updated at least annually by the Advisor.
Minimum Investment Amounts Required
There are no minimum investment amounts or conditions required for establishing an account
managed by SCO. However, there is a minimum annual fee of $1,000, which is subject to the
discretion of the management of SCO for each account and may be negotiated.
All clients are required to execute an investment management agreement for services to establish
a client arrangement with SCO.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Investment Strategies
SCO uses the following investment strategies when managing client assets and/or providing
investment advice:
Potential securities for investment include equities (common and preferred stocks), fixed income
securities (including corporate, municipal and U.S. government and agency bonds), mutual funds,
exchange traded funds (ETFs), annuities, derivatives (call and put options) and partnerships
(including oil & gas pipeline and real estate).
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SCO does not primarily recommend one type of security to clients. Instead, we recommend a
combination of equity, fixed income, and cash instruments that may be suitable for each client
relative to that client’s specific circumstances and needs based upon their time horizon, goals, and
risk tolerance for their target asset allocation.
SCO is interested in the best suitability and fit for a client’s portfolio. Therefore, it focuses
primarily on a balanced strategy with long-term investments while also evaluating short-term and
trading opportunities.
Methods of Analysis
SCO primarily uses the following methods of analysis in formulating investment decisions:
Fundamental analysis is a method of evaluating a security by attempting to measure its intrinsic
value by examining related economic, financial and other qualitative and quantitative factors.
Fundamental analysts attempt to study everything that can affect the security's value, including
macroeconomic factors (like the overall economy and industry conditions) and individually
specific factors (like the financial condition and management of a company). The end goal of
performing fundamental analysis is to produce a value that an investor can compare with the
security's current price in hopes of figuring out what sort of position to take with that security
(underpriced = buy, overpriced = sell or short). Fundamental analysis is considered the opposite
of technical analysis. Fundamental analysis is about using real data to evaluate a security's value.
Although most analysts use fundamental analysis to value stocks, this method of valuation can be
used for just about any type of security.
Technical analysis is a method of evaluating securities by analyzing statistics generated by market
activity, such as past prices and volume. Technical analysts do not attempt to measure a security's
intrinsic value, but instead use charts and other tools to identify patterns that can suggest future
activity. Technical analysts believe that the historical performance of stocks and markets are
indications of future performance.
Tactical investing strategies may include what is known as the Concentrated Collar – we sell
“covered calls” on concentrated equity positions to generate income for a client’s portfolio. We
use this income to purchase “protective puts” to protect from significant downside risk. The use
of covered calls and protective puts together in such a way is known as a “cashless collar”. It is
considered “cashless” because it generates its own funding without the need for additional costs
to you. This strategy greatly limits capital gains taxes because it limits risk without the need to
sell your concentrated equity position. Also, there is the potential for enhanced profitability. Our
goal is to create enough income to cover the cost of the puts, our management fee, and have
enough income left over to create additional profits for you.
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Risk of Loss
Investment in any securities or investment strategy does carry inherent risks that clients
acknowledge their understanding of, and such affirmation is included in written agreements with
SCO.
Past performance is not indicative of future results. Therefore, you should never assume that the
future performance of any specific investment or investment strategy will be profitable. Investing
in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further,
depending on the different types of investments there may be varying degrees of risk. You should
be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our firm is unable to represent,
guarantee, or even imply that our services and 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. There are certain additional risks associated with investing in securities through our
investment management program, as described below:
• Market Risk – Either the stock market as a whole, or the value of an individual
company, goes down resulting in a decrease in the value of client investments. This
is also referred to as systemic risk.
• 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.
• Fixed Income Risk. When investing in bonds, there is the risk that the issuer will
default on the bond and be unable to make payments. Further, individuals who
depend on set amounts of periodically paid income face the risk that inflation will
erode their spending power. Fixed-income investors receive set, regular interest
(coupon) payments that face the same inflation risk.
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• 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.
• ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will
bear additional expenses based on your 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. You will also incur brokerage
costs when purchasing ETFs.
• Management Risk – Your investment with our firm varies with the success and
failure of our investment strategies, research, analysis and determination of
portfolio securities. If our investment strategies do not produce the expected
returns, the value of the investment will decrease.
Item 9: Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or
disciplinary events that could be relevant to your proper evaluation of each supervised person
providing investment advice. No information is applicable to this item for any current member of
SCO. To date no disciplinary actions, past or ongoing, are applicable to SCO or any current or
former employee of SCO.
Item 10: Other Financial Industry Activities and Affiliations
SCO is not and does not have a related person that is a broker/dealer, municipal securities dealer,
government securities dealer or broker, an investment company or other pooled investment vehicle
(including a mutual fund, closed-end investment company, unit investment trust, private
investment company or "hedge fund," and offshore fund), another investment advisor or financial
planner, a futures commission merchant, commodity pool operator, or commodity trading advisor,
a banking or thrift institution, an accountant or accounting firm, a lawyer or law firm, an insurance
company or agency, a pension consultant, a real estate broker or dealer, and a sponsor or syndicator
of limited partnerships.
We are an independent investment registered advisor and only provide investment advisory
services. We are not engaged in any other business activities and offer no other services except
those described in this Disclosure Brochure.
SCO does not recommend or select other investment advisors for our clients.
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Item 11: Code of Ethics, Participation in Client Transactions, Personal Trading
and Qualified Account Rollovers
• Code of Ethics
SCO has adopted a Code of Ethics that reflects its fiduciary obligations and those of its supervised
persons. The Code of Ethics also requires compliance with federal securities laws. The Code of
Ethics covers all individuals that are classified as “supervised persons”. All employees, officers,
directors and investment advisor representatives are classified as “supervised persons” and “access
persons”. A copy of our Code of Ethics is available upon request. This Code of Ethics is based
upon the principle that all employees of SCO have a fiduciary duty to place the interest of clients
ahead of theirs and SCO’s.
• Participation or Interest in Client Transactions
Personnel of SCO may participate independently or within a block transaction of client-eligible
securities. It is the policy of SCO that all allocations of joint participation be first and foremost
evenly allocated. The Code of Ethics prohibits members of SCO or family members from
influencing a market or security transaction in conjunction with a client transaction.
• Personal Trading
SCO or supervised persons of the firm buy and sell for their personal accounts, investment products
identical to those recommended to clients. This creates a conflict of interest. It is the express
policy of SCO that all persons associated in any manner with our firm must place clients’ interests
ahead of their own when implementing personal investments. As is required by our internal
procedures manual, SCO and its supervised persons will not buy or sell securities for their personal
account(s) where their decision is derived, in whole or in part, by information obtained as a result
of employment or association with our firm unless the information is also available to the investing
public upon reasonable inquiry.
SCO is now and will continue to comply with applicable state and federal rules and regulations.
To mitigate conflicts of interest that can occur when supervised persons manage their personal
accounts at the same time SCO manages client accounts, we have developed written supervisory
procedures that include personal investment and trading policies for our representatives,
employees and their immediate family members (collectively, supervised persons). All supervised
persons of the firm are considered access persons:
• Supervised persons cannot prefer their own interests to that of the client.
• Supervised persons cannot purchase or sell any security for their personal accounts ten
days prior to implementing transactions for client account, unless done as part of a block
trade.
12
• Supervised persons are prohibited from purchasing or selling securities of companies in
which any client is deemed an “insider”.
• Supervised persons are discouraged from conducting frequent personal trading.
• Supervised persons are generally prohibited from serving as board members of publicly
traded companies unless an exception has been granted by the Chief Compliance Officer
of SCO.
All personal trading is documented, and records are kept for five years from fiscal year end for
inspection. All trading that occurs complies with SCO’s personal trading policy (See Participation
or Interest in Client Transactions). For further inquiry, all clients are encouraged to address
questions to Erin M. Maynard.
Item 12: Brokerage Practices
We seek to recommend a custodian/broker that will hold a client’s 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 in selecting brokers which starts with our
understanding of the brokerage industry. We then weigh the following factors for all brokers being
considered: the skill and quality of optimum execution of trades, the breadth of available
investment products such as stocks, bonds, mutual funds, exchange-traded funds (ETF’s), etc. and
readily availability of competitively priced fixed-income, ETFs and mutual funds, the service and
reporting of the brokerage transactions (recording and confirmation), the overall research
information made available, the commitment to provide us with a high level of service for back-
office operations, state-of-the-art trading platform and website for clients’ viewing of account
information, and industry competitive trading commissions and transaction fees, and the
reputation, financial strength, security, and stability of the broker/custodian.
The brokerage firm used may earn a commission by executing the purchase or sale of an over the
counter (OTC) security through a related company that may also earn a fee as a market maker.
SCO recommends that clients establish brokerage accounts with Charles Schwab & Co., Inc.
(Schwab), a FINRA-registered broker-dealer, member SIPC, to maintain custody of clients’ assets
and to affect trades for their accounts. Although SCO may recommend that clients establish their
accounts at Schwab, it is the client’s decision to custody their assets with Schwab by entering into
an account agreement with Schwab. SCO does not open the account(s) for the client but will assist
the client in the account opening procedure. SCO is independently owned and operated and not
affiliated with Schwab.
Schwab provides SCO with access to its institutional trading and custody services, which are
typically not available to Schwab retail investors. These services generally are available to
independent investment advisors on an unsolicited basis. Schwab’s brokerage services include the
execution of securities transactions, custody, research, and access to institutional only mutual
13
funds and other investments that are otherwise generally available only to institutional investors
or would require a significantly higher minimum initial investment for a retail investor.
Schwab does not charge separately for custody services for SCO clients maintained in its custody
but may be compensated by account holders through trading commissions and other transaction-
related or asset-based fees for securities trades that are executed through Schwab or that settle into
Schwab accounts. Schwab also earns management fees on money market and mutual funds that
are owned and operated by Schwab that SCO may choose as investments for client accounts. SCO
does not receive any incentives or referrals from Schwab.
Schwab also provides other services intended to help SCO manage and further develop its
business, and the retention and servicing of its clients. These services include monthly webcast
series that cover current market and economic topics, annual educational conferences and events,
consulting on technology, compliance, legal, and business needs, publications and conferences on
practice management and business succession, marketing consulting and support. Schwab may
provide these services or arrange for third-party vendors to provide these services.
a) Soft Dollar Practices (Other Compensation)
The Company receives an indirect economic benefit from its broker/dealer, Schwab. See above
under Item 12, “Brokerage Services” for more detailed information on what these services and
benefits are.
b) Client Referrals
SCO does not have paid arrangements such as referrals, commissions, or discounted investment
management services with any outside entity or person (i.e., broker, colleague, etc.) in connection
with obtaining a new client for SCO.
c) Directed Brokerage
It is a policy of SCO to seek to execute portfolio transactions at prices which are advantageous to
the clients, and at commission rates which are reasonable in relation to the benefits derived by its
clients. Any client directing broker execution is advised of SCO’s policy and the potential cost of
the transaction(s).
d) Trade Aggregation
SCO will, as a common brokerage trading practice, aggregate multiple contemporaneous client
orders into blocks (“block trades”) when it is judged to be practical by the advisor. Participating
accounts typically receive an average price of any partial or whole execution of such blocks. While
this procedure in most cases creates a lower average price per trade for each client, its application
cannot be guaranteed.
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e) Cross Trades
A cross trade occurs when the Company affects a transaction between two advisory clients (e.g.,
having Account A purchase securities directly from Account B). Such trades are most often done
when a client asset needs liquidation for a distribution request and another client needs the asset
to rebalance the account to meet the component of the asset allocation model. In a cross-trade
transaction, in contrast to an agency cross transaction, the Company receives no compensation
other than its advisory fee.
The Company shall not affect a cross trade for advisory clients unless:
1) It has been determined that no client will be disfavored by cross-trading.
2) The trade is executed at a price determined by an independent pricing mechanism and such
pricing mechanism is documented as to each cross trade.
3) In the case of cross trades involving one or more clients whose account contains employee
benefit plan assets, no cross trades shall be executed without the pre-approval (in each
instance) of the CCO. The CCO shall not approve such cross trade until he or she has
determined that the cross trade is not a "prohibited transaction" under Section 406(b) of
ERISA, or an exemption is obtained from the Department of Labor.
Item 13: Review of Accounts
All client accounts are reviewed at least quarterly, and clients are invited to participate on the same
basis. In addition, any material changes to a client’s Investment Policy Letter, portfolio objectives,
risk tolerance, securities eligibility, or general decisions such as withdrawals may be amended at
any time by the client. Client reviews are conducted by Portfolio Managers of SCO. A review
consists of a summary of the account(s) status detailing asset categorization, income and yield,
and a year-to-date and trailing twelve-month performance report based on total return. Every client
is given a report that provides detailed investment results of the overall client portfolio as well as
individual accounts. These meetings are ongoing and are meant to provide the client with frequent
opportunity to discuss future objectives and answer current questions regarding their account(s).
Account Statements - All accounts are held by a qualified custodian. Clients receive monthly an
independent account statement of assets and transactions for every account from their custodian
either electronically or printed as selected by them. SCO issues separate quarterly investment
reports for all the accounts that they manage. Clients are urged to carefully review both monthly
account statements and quarterly investment reports and compare them. Any questions a client
may have about their account statement(s) or reports, will be timely addressed by the respective
client contacting SCO and/or the qualified custodian that prepared the account statement(s) or
reports.
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Item 14: Client Referrals and Other Compensation
SCO does not have any arrangements with any other individual or entity for client referrals. SCO
does not pay anyone for client referrals, and we do not receive any compensation for referring a
client for another type of service or product which we do not offer. Occasionally an existing client
may refer to a family member or friend, that individual does not receive any special benefit or
discounted fees for the referral of someone to the firm.
Item 15: Custody
Custody, as it applies to investment advisors, has been defined by regulators as having access or
control over client funds and/or securities. In other words, custody is not limited to physically
holding client funds and securities. If an investment advisor has the ability to access or control
client funds or securities, the investment advisor is deemed to have custody and must ensure proper
procedures are implemented.
Third Party Money Transfers - SCO has been authorized by many of its clients to disburse funds
on their behalf to a third party (see below). Therefore, SCO assists many of its clients with the
routine transfer of funds either electronically or by journal entry between qualified custodial
accounts that it manages or with client’s accounts maintained at other qualified custodians, based
upon standing letters of authority from the client that meet established guidelines.
Also, the SEC has ruled that client authorized transfers (either standing letters or individually
authorized) between client accounts that do not have identical account registrations (third party)
are deemed custody over the accounts by SCO. The SEC requires that seven conditions be met for
advisors to avoid the annual surprise examination requirement. SCO (together with its qualified
custodian) complies with the seven conditions.
Fee Debiting - SCO is deemed to have custody over the accounts of clients that have granted SCO
the authority to deduct its fees and/or expenses directly from their account(s).
For accounts in which SCO is deemed to have custody, we have established procedures to ensure
all client funds and securities are held by a qualified custodian in a separate account for each client
under that client’s name. Clients or an independent representative of the client will direct, in
writing, the establishment of all accounts and therefore are aware of the qualified custodian’s
name, address and the manner in which the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s
independent representative, at least quarterly. Clients should carefully review those statements
and are urged to compare the statements against reports received from SCO. When clients have
questions about their account statements, they should contact SCO or the qualified custodian
preparing the statement.
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Item 16: Investment Discretion
When providing asset management services, SCO maintains trading authorization over your
account(s) and can provide management services on a discretionary basis. When discretionary
authority is granted, we will have the authority to determine the type of securities, the number of
securities that can be bought or sold, the broker or dealer to be used and the commission rates paid
for your portfolio without obtaining your consent for each transaction.
Almost all of SCO’s client accounts are managed on a discretionary basis and are held in custody
by a qualified custodian. All clients must independently authorize the investment management
authority in favor of SCO with their custodian for each specific account to be managed. In addition,
all clients must execute an Investment Management Agreement (for specifying the funds that SCO
is engaged to manage and to describe the management relationship in detail), and an Investment
Policy Letter (stating the client’s risk preference and investment objectives) prior to SCO’s active
involvement with a client’s account.
If you grant trading authorization on a non-discretionary basis, we must contact you before
implementing changes in your account. Therefore, you will be contacted and required to accept
or reject our investment recommendations including:
• The security being recommended, the number of shares or units and whether to buy or sell.
Once the above factors are agreed upon, SCO is responsible for making decisions regarding the
timing of buying or selling an investment and the price at which the investment is bought or sold.
If your accounts are managed on a non-discretionary basis, you need to know that if SCO is not
able to reach you or you are slow to respond to our request, it can have an adverse impact on the
timing of trade implementations and SCO may not achieve the optimal trading price.
You will have the ability to place reasonable restrictions on the types of investments that may be
purchased in your account. You may also place reasonable limitations on the discretionary power
granted to SCO so long as the limitations are specifically set forth or included as an attachment to
the client agreement.
Item 17: Voting Client Securities
SCO retains a policy of deferring all securities voting to clients. No proxy voting arrangements
exist in favor of SCO management or its employees. SCO will help answer general questions about
proxies and aid clients in the appropriate method to vote, i.e., voting online at proxy website or by
mail. The client retains the sole responsibility for proxy decisions and voting.
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Item 18: Financial Information
SCO does not engage in prepayment of services and all billing is processed in arrears. Also, SCO
is a solvent, on-going concern with no items of disclosure regarding financial situations that may
jeopardize custodian-held client funds in any way. Therefore, the submission of a current annual
balance sheet is not applicable under securities law requirements.
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Part ADV Part 2B: Brochure Supplement
Shuttleworth & Company
Erin M. Maynard, ChFC, CLU
3807 Attucks Drive
Powell, OH 43065
614-760-7738
www.sco-advisors.com
April 2026
This brochure supplement provides information about Erin M. Maynard (CRD#: 3124545)
that supplements the Shuttleworth & Company brochure. Please contact Erin M. Maynard
at 614-760-7738 or by email at erin@sco-advisors.com if you have questions about the
contents of this supplement.
Additional information about Erin M. Maynard is available on the SEC’s website at
www.adviserinfo.sec.gov.
19
Portfolio Manager Educational Background and Business Experience
Item 2: Educational Background and Business Experience
Erin M. Maynard, born in 1973 received a BS in Financial Management from The Ohio State
University (1996), and has maintained a career in the financial services industry from 1994 through
present. She worked as a financial advisor with Western Credit Union from 1994-1998 while
attending college. In a desire to pursue a career in financial planning and investment management,
Erin worked at Banc One Securities from 1998-1999 where she became licensed in securities and
worked as a sales representative. She worked as a Retirement Planning Specialist from 1999-2007
with Nationwide Retirement Services while attaining the Series 65 Investment Adviser
Representative (IAR) license where her focus was on retirement planning for individuals. She was
an IAR with FSC Securities from 2007-2009 providing investment management, and retirement
planning for individuals and families. From 2009-2011 she was an IAR with Valic Financial
Advisers, which focused on the education and retirement planning for university faculty and staff.
Erin has been with Shuttleworth & Company (SCO) since 2011 initially working part-time as a
Portfolio Assistant. As of December 2021, Erin is a shareholder and part owner of SCO. As of
January 2018, Erin has been serving clients as an Investment Advisor Representative and Portfolio
Manager meeting their investment and financial planning needs. Erin is the Chief Compliance
Officer since January 1, 2025. Erin has earned the Chartered Financial Consultant-ChFC (2002)
and Chartered Life Underwriter-CLU (2005) designations from The American College.
Professional Designations
The ChFC is a financial designation offered through The American College, which includes a
curriculum of eight College-level courses focused on practical application and real-life case
studies. Topics include: the financial planning process; strategies for risk, income and retirement
planning, investment, estate and gift, personal financial planning, and specialized planning needs.
Annual continuing education, which includes an ethics course is required to keep the designation
in good standing. The designation is awarded by the American College, a non-profit educator
founded in 1927 with a focus on educating leading financial advisors.
The CLU is also offered through the American College and is centered on the complexities of life
insurance for both individuals and small businesses. The focus on the designation centers around
providing guidance to clients on types and amounts of life insurance, annuity advisement, Risk
Management associated with human capital, liabilities, property, and financial wealth. Guiding
clients through decisions on estate planning, including advising on wills and trust arrangements,
and providing guidance in specialized areas of your choice, with options including financial
planning, income taxation, planning for retirement needs, investments, and working with people
with disabilities and/or families caring for loved ones with special needs. Annual continuing
education is required which includes a course on ethics to maintain in good standing and to use
the designation.
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Item 3: Disciplinary Information
To date no criminal disciplinary information is applicable for Erin M. Maynard.
Item 4: Other Business Activities and Affiliations
Erin M. Maynard is not involved in any other business activities nor has other business affiliations.
Item 5: Additional Compensation
Erin M. Maynard does not receive any additional compensation. The Management of SCO does
not participate in or condone additional compensation arrangements that extend, but are not limited
to, the following: client referrals and sales compensation for non-client contacts.
Item 6: Supervision and Succession
Erin M. Maynard is the Chief Compliance Officer, Partner and Owner at SCO. Erin is supervised
by the other member of our Management Team, Matthew R. Freiburger – Partner, Wealth
Manager. Erin has a succession agreement with Matthew R. Freiburger. Either of them can be
reached at 614-760-7738.
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Part ADV Part 2B: Brochure Supplement
Shuttleworth & Company
Matthew R. Freiburger, CFA, CPA
3807 Attucks Drive
Powell, OH 43065
614-760-7738
www.sco-advisors.com
April 2026
This brochure supplement provides information about Matthew R. Freiburger (CRD#:
5207204) that supplements the Shuttleworth & Company brochure. Please contact Erin
Maynard at 614-760-7738 or by email at erin@sco-advisors.com if you have questions about
the contents of this supplement.
Additional information about Matthew R. Freiburger is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Portfolio Manager Educational Background and Business Experience
Item 2: Educational Background and Business Experience
Matthew R. Freiburger, born in 1980, received a BS in Business Management and Accounting
with a Minor in Finance from Purdue University in 2002. He worked from 2002-2006 as a public
accountant for Crowe (formerly Crowe Chizek & Co.) rotating between the South Bend, Indiana
and Columbus, Ohio offices. Matthew was employed for a short time in 2006 at JPMorgan Chase
where he served as an Internal Auditor.
With a passion for finance, Matthew moved on to be employed at Steele Investment Counsel, Ltd.
from 2006-2019. Matthew quickly attained the Series 65 Investment Adviser Representative (IAR)
license and Certified Public Accountant (CPA) license in 2007. He then successfully completed
all three levels of the Chartered Financial Analyst (CFA) examinations in three consecutive years
and obtained the CFA Charter in 2010.
Once completed, Matthew worked for several years as a Portfolio Manager focusing on the
individual needs of families and small business owners. Matthew started January 2020 with
Shuttleworth & Company where he is primarily a Portfolio Manager, serving to provide clients
with asset management and financial guidance to reach their long-term financial goals. As of
December 2021, Matthew is a shareholder and part owner of SCO.
Professional Designations
CFA Institute is a global, not-for-profit organization comprising the world’s largest association of
investment professionals. With over 100,000 members, the CFA Institute is dedicated to
developing and promoting the highest educational, ethical, and professional standards in the
investment industry. The CFA Program is a graduate-level self-study program that is organized
into three levels, each culminating in a six-hour exam. Completing the Program takes most
candidates between three and five years. To earn a CFA Charter, one must have four years of
qualified investment work experience, become a member of CFA Institute, pledge to adhere to the
CFA Institute Code of Ethics and Standards of Professional Conduct on an annual basis, apply for
membership to a local CFA member society, and complete the CFA Program. More information
about the CFA Institute and the CFA designation can be found at www.cfainstitute.org.
The Uniform CPA Examination protects the public interest by helping to ensure that only qualified
individuals become licensed as U.S. Certified Public Accountants (CPAs). Individuals seeking to
qualify as CPAs are required to pass the CPA Examination which currently consists of four
sections that represent a total of 14 hours of testing. In the state of Ohio, one must successfully
complete
the CPA examination, successfully complete a professional standards and
responsibilities course that emphasizes the Ohio accountancy law and Board rules and have
experience performing one or more services related to public accounting. Generally, a minimum
of one year of experience is required if a candidate has a bachelor's degree and 150 semester hours
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of college credit prior to sitting for the CPA examination. More information about the CPA
program can be found at www.aicpa.org and www.acc.ohio.gov.
Item 3: Disciplinary Information
To date no criminal disciplinary information is applicable for Matthew R. Freiburger.
Item 4: Other Business Activities and Affiliations
Matthew R. Freiburger is not involved in any other business activities nor has other business
affiliations.
Item 5: Additional Compensation
Matthew R. Freiburger does not receive any additional compensation. The Management of SCO
does not participate in or condone additional compensation arrangements that extend, but are not
limited to, the following: client referrals and sales compensation for non-client contacts.
Item 6: Supervision and Succession
Matthew R. Freiburger is a Partner and Owner at SCO. Matt is supervised by the other member of
our Management Team, Erin M. Maynard – CCO, Partner, Wealth Manager. Matt has a succession
agreement with Erin M. Maynard. Either of them can be reached at 614-760-7738.
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