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Item 1 Cover Page
Westbourne Investments, Inc.
2121 Eisenhower Ave., Ste 605
Alexandria VA 22314
(800) 808-7488
pwalsh@westbourneinv.com
www.westbourneinv.com
March 29, 2026
Part 2A of Form ADV: Firm Brochure
information about
This Brochure provides
the qualifications and business practices of
Westbourne Investments, Inc. (WESTBOURNE) and Ariba Asset Management (ARIBA), a division of
Westbourne Investments, Inc. If you have any questions about the contents of this brochure, please
contact us at (800) 808-7488 or pwalsh@westbourneinv.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.
Westbourne Investments, Inc. is an investment advisory firm registered with the appropriate regulatory
authority. Registration does not imply a certain level of skill or training. Additional information about
Westbourne Investments, Inc. also is available on the SEC's website at adviserinfo.sec.gov. You can search
this site by a unique identifying number, known as a CRD number. Westbourne's CRD number is 37499.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 1 of 14
Item 2 Summary of Material Changes
Item 2 provides a summary of material changes that WESTBOURNE has made to this Brochure since the last
annual update, which occurred on March 24, 2025. For additional details, see the referenced item in the
Brochure.
•
Item 14 – Added WESTBOURNE’s referral arrangement with a non-affiliated Trustee.
Additionally, WESTBOURNE has made other changes, some of which may clarify or enhance existing
disclosures, but we do not consider these other changes to be material.
The revised Brochure will be available on the SEC’s public disclosure website (IAPD) at adviserinfo.sec.gov
or you may contact us at the number or email listed on the cover page of this Brochure to obtain a copy.
When an update is made to this Brochure, we will send a copy to you with a summary of material changes,
or a summary of material changes that includes an offer to send you a copy either by electronic means
(email) or in hard copy form.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 2 of 14
Item 3 Table of Contents
Item 1 Cover Page ......................................................................................................................................... 1
Item 2 Summary of Material Changes .......................................................................................................... 2
Item 3 Table of Contents............................................................................................................................... 3
Item 4 Advisory Business .............................................................................................................................. 4
Item 5 Fees and Compensation .................................................................................................................... 6
Item 6 Performance-Based Fees and Side-By-Side Management ................................................................ 7
Item 7 Types of Clients .................................................................................................................................. 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 7
Item 9 Disciplinary Information .................................................................................................................. 10
Item 10 Other Financial Industry Activities and Affiliations ....................................................................... 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 11
Item 12 Brokerage Practices ....................................................................................................................... 12
Item 13 Review of Accounts ....................................................................................................................... 13
Item 14 Client Referrals and Other Compensation ..................................................................................... 13
Item 15 Custody .......................................................................................................................................... 14
Item 16 Investment Discretion ................................................................................................................... 14
Item 17 Voting Client Securities .................................................................................................................. 14
Item 18 Financial Information ..................................................................................................................... 14
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 3 of 14
Item 4 Advisory Business
Firm Description & Principal Owners
Westbourne Investments, Inc. (WESTBOURNE) provides independent, customized account management
for individuals and institutions. Our firm specializes in providing highly personal management of our
client’s assets. Stock and bond portfolios are designed and managed in strict accordance with each client’s
individual investment objectives. Discretionary authority is limited by the objectives of the account, the
applicable fiduciary obligations imposed by the law and the assets contained in the account. WESTBOURNE
was founded in 1990 and was principally owned by Robert "Bob" Long and Patrick Walsh. In September
2024, Bob's interest in WESTBOURNE was transferred to his son, Robert "Rob" Long.
Types of Advisory Services
WESTBOURNE offers a number of different types of advisory services.
• Personal Financial Planning
insurance policies.
It also
This service includes a discussion and written analysis of an individual or family’s current financial
condition, including current and expected income sources from salary, social security, pensions,
or other sources; estimated monthly expenses; risk protection in place via life, disability, long-
term care, and other relevant
includes recommendations,
implementation, and monitoring of an asset allocation plan based on the investor’s financial goals,
as well as the individual’s ability, willingness and need to take risk, as determined by time horizon,
stability of earned income, need for liquidity, and the investor’s available options for liquidity
should their investment plan fail. An investor’s available options may include delaying retirement,
taking a part-time job, downsizing the current home, selling a second home, lowering
consumption, or moving to a region with a lower cost of living. The more options, the more risk
one can take.
• Diversified equity and balanced portfolio management
Managed portfolios are structured with Exchange Traded Funds (ETFs) and/or individual stocks
that represent the following investment categories:
Income-oriented equities are selected for their relatively consistent ability to produce
noticeably superior rising income streams from basic industry sectors of the economy
represented by real estate, energy production and delivery, select utilities,
entertainment, and financial services.
Core equities are comprised of 15 to 20-year-old companies, characterized by strong,
innovative managements, excellent balance sheets, demonstrated pricing power,
earnings growth consistency and predictability, proprietary markets or product ranking
one or two in their respective industry niche, and possessing a shareholder motivated
management.
Growth equities represent a category comprised of ably-managed younger versions of the
core group, with dynamic new products or services that address, rapidly expanding, new
markets and societal needs, and possess all, or most, of the financial attributes and
metrics of the older core companies.
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March 29,2026
Form ADV Part 2A Disclosure Brochure
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• ETF portfolio management
WESTBOURNE develops a strategic asset allocation plan based on the client's risk tolerance,
investment return objectives, investment time horizon, income requirements and other factors.
The target investment portfolio for the client is usually divided among equity, fixed income, and
alternative investments. The asset allocation model further identifies investment asset classes
within these broad categories, such as short and intermediate-term U.S. and global bonds, U.S.
large and small company growth and value stocks, international large company and small
company growth and value stocks, real estate investment trusts, publicly traded Master Limited
Partnerships, precious metals, and money market securities. WESTBOURNE invests in selected
common stock funds including Exchange Traded Funds (ETFs) that track these asset classes,
periodically rebalancing to the target allocation while considering the impact of taxes and
transaction costs. Investors in ETF portfolios should expect to remain fully invested in their
selected asset allocation plan at all times.
• Options
WESTBOURNE employs various strategies in line with the clients’ agreed upon strategies.
Covered Calls Strategy - Selling call options on equities long in accounts, using strike prices
above purchase prices and using time/value analysis to achieve enhanced cashflow(income).
Synthetic Longs Strategy - Selling put options, below the market price to provide the
opportunity to purchase equities at lower levels, also used in conjunction with “covered calls”
to create spreads. Also used with the purchase of long calls, to acquire participation in
positive equity appreciation.
Long Puts Strategy - To provide a measure of insurance against sudden, volatile stock value
declines.
Long Call Strategy - Buying call options.
Advanced Options Strategy - Vertical & Butterfly options spreads.
Options Strategies within the approved risk levels of option trading (zero to three) could employ
all of the above outlined strategies. All clients receive the custodian’s “option risk brochure.”
Option positions are monitored daily and chronological records are kept to evaluate future
decisions by the investment committee.
Tailored Relationships
Portfolios are managed according to the objectives and needs of the client. Client goals and objectives
are clarified in meetings and via correspondence and are used to determine the course of action for each
individual client. The needs and objectives for each client are documented in client files and our portfolio
management system electronically.
Clients may impose restrictions on investing in certain securities or types of securities. This must be done
in writing. Account restrictions and guidelines imposed by clients may affect the composition and
performance of a client’s portfolio. For these reasons, performance of the portfolio may not be identical
with other clients of Westbourne.
Managed Assets
As of December 31, 2025, WESTBOURNE managed a total of $276,365,058. $276,365,058 managed on a
discretionary basis and $0 on a non-discretionary basis.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 5 of 14
Item 5 Fees and Compensation
WESTBOURNE’S standard, stated fee schedule is as follows; however, fees for investment advisory services
provided are negotiated on a client-by-client basis prior to services rendered and are agreed to with each
client in writing:
Annual Fee Rates
Equities
Fixed Income 0.500%
Option Trading [Negotiable]
$25,000 to $100,000 2.000%
1.650%
$100,000 to $300,000
1.400%
$301,000 to $500,000
$500,001 to $2,000,000 1.150%
0.900%
Next $3,000,000
0.775%
> $5,000,000
Generally, the investment advisory fee is payable quarterly in advance, unless otherwise negotiated in
writing. The fee will be a percentage of the market value of all assets in the advisory account on the last
trading day of the previous calendar quarter. In any partial calendar quarter, the advisory fee will be pro-
rated based on the number of days that the account was open during the quarter. Client understands
that Account assets invested in shares of mutual funds or other investment companies (“funds”) will be
included in calculating the value of the Account for purposes of computing WESTBOURNE’s fees and the
same assets will also be subject to additional advisory and other fees and expenses, as set forth in the
prospectuses of those funds, paid by the funds but ultimately borne by the investor. Advisory fees will be
deducted directly from Client’s account(s) unless negotiated otherwise with WESTBOURNE.
The investment management agreement may be canceled at any time by either party on 30 days written
notice. The agreement is automatically extended from year to year unless written notice is received to
the contrary, sent by ordinary mail, terminating the services as indicated above. In the event of such
cancellation, the fee would be prorated to the date of termination and any unused portion of fees
collected in advance for advisory services will be refunded within 30 days.
Personal Financial Planning Fees - Financial planning is billed at a fixed rate. Estimates are provided and a
deposit requested. Since the nature of the work often involves variables or circumstances unknown at
the start of the engagement, estimates are not guaranteed.
Other Fees - Custodians may charge transaction fees on purchases or sales of certain mutual funds, stocks,
bonds, and exchange-traded funds. These transaction charges are usually relatively small and are
incidental to the purchase or sale of a security. In some cases, custodians also charge monthly, quarterly
or annual custody fees. Fees for custody are disclosed to clients when this type of arrangement is
recommended. Mutual funds and exchange traded funds generally charge a management fee for their
services as investment managers. The management fee is included in the expense ratio. Mutual fund fees
also include transaction charges for the purchase or sale of securities within the fund and may charge
other fees as disclosed in the fund prospectus. These fees are in addition to the fees paid by the client to
WESTBOURNE.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 6 of 14
Past Due Accounts and Termination of Agreement - WESTBOURNE reserves the right to stop work on any
account that is more than 60 days overdue. In addition, WESTBOURNE reserves the right to terminate any
financial planning engagement where a client has willfully concealed or has refused to provide pertinent
information about financial situations when necessary and appropriate to providing proper financial
advice, per the judgment of WESTBOURNE.
Item 6 Performance-Based Fees and Side-By-Side Management
WESTBOURNE does not charge performance-based fees or engage in side-by-side management.
Performance-based fees are fees based on a share of capital gains on or capital appreciation of the assets
of a client. Side-by-side management generally refers to a situation in which the same firm manages
accounts that are billed based on a percentage of assets under management, hourly charges, fixed fees
(not including subscription fees) and at the same time manages other accounts for which fees are assessed
on a performance fee basis. Since WESTBOURNE does not charge performance-based fees, it does not
engage in side-by-side management.
Item 7 Types of Clients
WESTBOURNE provides investment management and financial planning to individuals, high net worth
individuals, pension plans/profit sharing plans and institutions. The minimum account size for portfolio
management is $100,000. Accounts not meeting this minimum may at times be accepted on a case-to-
case basis.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
WESTBOURNE’S investment strategies and advice will vary depending upon each client's specific financial
situation. As such, WESTBOURNE determines investments and allocations based upon each client’s
predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various
suitability factors. A client’s restrictions and guidelines will affect the composition of the client’s portfolio.
It is important that each client promptly notify WESTBOURNE with respect to any material changes to the
client’s financial circumstances, including for example, a change in current or expected income level, tax
circumstances, or employment status.
• Financial Planning
Strategies are devised and implemented on a client-by-client basis. Generally, WESTBOURNE
consults with each client to find agreement on the appropriate level of portfolio risk after
considering factors such as personal situation, including age, health, family circumstances,
income, expenses, assets, debts, liquidity needs, goals, objectives, risk tolerance, suitability and
other relevant factors. WESTBOURNE then proposes an asset allocation strategy that attempts to
maximize growth possibilities for the agreed upon level of risk and implements the strategy by
creating a multi-asset class portfolio primarily consisting of passively managed exchange-traded
funds (“ETFs”) and index funds. WESTBOURNE then monitors each client portfolio on an ongoing
basis, rebalancing as necessary to ensure risk exposures are as agreed upon from the last account
review and given the current and expected condition of the client, the markets, and the global
economy.
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March 29,2026
Form ADV Part 2A Disclosure Brochure
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Changes in the asset allocation models, which includes adding, removing or replacing securities
at the discretion of WESTBOURNE, are made based on significant changes in the economic,
financial or political climate; changes in the tax code; the management of the securities; and/or
the client’s personal circumstances, including health, employment and family status. WESTBOURNE
may replace a particular security (or securities) if it significantly diverges from its relevant index
in terms of risk or return, with a security that is more in line with the risk/return profile of the
relevant index or if there is a different security that in WESTBOURNE’s opinion, would be better
suited.
• Equity & Options Management
The Method of Analysis begins with “Top Down” understanding of all important economic
variables such as interest rates, rate of inflation, money supply growth, leading economic
indicators, government fiscal and monetary policies, regulatory policies as well as the impact such
indicators have on industries and companies. Continuous monitoring of such data provides the
basic knowledge necessary to take advantage of changes in economic trends, investor psychology
and stock market price movements. “Bottom Up” securities analysis is then employed to
determine the appropriate asset allocation and to structure an investment program which meets
the investment objective and risk profile of each client. Such analysis includes, but is not limited
to, comparative statistical analysis of financial statements, quality and track record of
management, quality and reputation of the company’s products and services, competitive
environment and long-term growth potential. Using these analytical tools along with other
pertinent knowledge, our experienced management determines and monitors the intrinsic value
of each investment compared to the prevailing price of the stock. This technique provides a
consistent framework for investing in companies at prices that afford the possibility of above
average appreciation and dividend growth.
Risk of Loss
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 WESTBOURNE. Investments
may lose value, and past performance is never a guarantee of future results.
The information contained in this Brochure did not include every potential risk associated with an
investment strategy, nor all of the risks applicable to a particular security. Risks vary by client according
to their investment objectives, guidelines, liquidity needs or risk tolerances and not every strategy or
portfolio will be exposed to each of the risks described in this Brochure. This list is not intended to be
exhaustive of all of the risks associated with investing in strategies or securities that are utilized or
recommended by WESTBOURNE. Rather, it is a general description (in alphabetical order) of the nature
and risks of the investment advisory services provided by WESTBOURNE and its advisors.
Asset Allocation: A portfolio that holds large cash positions may deviate from the stated benchmark
and could underperform as a result. Differences in the security holdings and weights of a portfolio
versus the strategy benchmark will result in disparities between a portfolio’s performance relative to
its benchmark. A portfolio may perform better or worse than a similarly managed account for various
reasons including, but not limited to, the frequency and timing of rebalancing and trading each
portfolio and the size and number of positions in each portfolio.
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Cash-Equivalents (Money Market Funds): Cash equivalents are short-term, highly-liquid investments,
such as money market funds (a type of mutual fund) and are subject to interest rate and issuer-specific
changes. Interest rate increases can cause the price of a money market security to decrease. Likewise,
a decline in the credit quality of an issuer can cause the price of a money market security to decrease.
An investment in a money market fund is neither insured nor guaranteed by the FDIC or any other
government agency. Although money market funds seek to preserve the value of your investment at
one dollar per share, it is possible to lose money by investing in a money market fund.
Concentration: Strategies that are concentrated in only a few securities, sectors or industries, regions
or countries or asset classes could expose a portfolio to greater risk and may cause greater portfolio
volatility.
Cybersecurity and Information Security: A portfolio is susceptible to operational and informational
security risks due to the increased use of the internet. In general, cyber incidents can result from
deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by
computer viruses or other malicious software code, gaining unauthorized access to systems,
networks, or devices through “hacking” or other means for the purpose of misappropriating assets or
sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or
breaches of third-party service providers may cause disruptions at third-party service providers and
impact business operations, potentially resulting in financial losses; the inability to transact business;
violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage;
unanticipated expenses or other compensation costs; and/or additional compliance costs. If a client
suspects fraudulent activity in an account(s), the client should immediately contact WESTBOURNE
using the information on the cover page of this Brochure and contact the qualified custodian using
the information on the custodial statement.
Equities (Stocks): Equity instruments are subject to equity market risk, which is the risk that common
stock prices will fluctuate over short or even extended periods. Equity securities generally have
greater price volatility than fixed income securities. The market price of equity securities may increase
or decrease, sometimes rapidly or unpredictably. Equity securities may decline in value due to factors
affecting markets generally, particular industries, sectors or geographic regions represented in those
markets, or individual security concerns.
Exchange Traded Funds (“ETFs”): ETFs are, by definition, portfolios of securities, and although the risk
associated with investments in ETFs may be low relative to investments in securities of individual
issuers, there are events that can trigger sharp, and sometimes adverse, price movements in ETFs that
are not related to movements of the markets in general. These events include, but are not limited to,
unanticipated dividends, changes to regular dividend amounts, announcements of rights offerings and
possible unexpected revisions to the net asset values of the ETF.
Fixed Income (Bonds or Debt): Debt securities are affected by changes in interest rates. When interest
rates rise, the value of debt securities are likely to decrease. Conversely, when interest rates fall, the
values of debt securities are likely to increase. The values of debt securities may also be affected by
changes in the credit rating or financial condition of the issuing entities.
Market: Securities markets are volatile and investing in securities involves the risk of loss that clients
should be prepared to bear. The direction of the capital markets (e.g., stock, credit, interest rate, real
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Form ADV Part 2A Disclosure Brochure
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estate, private equity, volatility, etc.) are difficult to predict and are dependent upon changes in a
number of factors, including, but not limited to, interest rates, inflation, and a host of additional
economic and political factors. There is always a risk that the capital markets as a whole will decline,
bringing down the value of individual securities regardless of their fundamental characteristics.
Market risk is also known as systematic risk or undiversifiable risk. This risk is both unpredictable and
impossible to completely eliminate.
Operational and Third-Party Risk: Portfolios are exposed to operational risk introduced through
human intervention or the failure of automated processes. Operational risks include, but are not
limited to, reconciliation errors, trading the wrong security, trading a security for an unintended
portfolio or purchasing a security that a portfolio was intended to sell, or vice versa. In addition,
natural disasters, power interruptions and other events may cause system failures. Furthermore,
reliance on third-party vendors and technology providers results in third-party risks and, despite
reasonable efforts (e.g., initial due diligence and monitoring), there is no guarantee that any or all
third-party service provider risks will be mitigated and may result in consequences such as the inability
to execute client transactions or monitor client accounts.
Options and Complex Products: Complex products, including but not limited to, master limited
partnerships (MLPs), real estate investment trusts (REITs) and options, may use advanced trading
techniques such as leverage, which lead to additional risks and costs. For example, option strategies
can involve frequent trading, increasing transaction costs. “Pass-Through” securities, such as MLPs
and REITs, do not pay corporate income taxes, but the shareholder pays taxes on dividends received
at the holder’s ordinary income tax rate. Investing in a complex product should not be compared to
investing in the underlying asset, as the features and risks may differ significantly. Investors should be
aware of any attributes related to limits on the upside or downside potential of returns, call options,
income, risk reduction strategies, early termination events, tax consequences, and market events that
impact the complex product or its underlying asset. Certain complex products carry additional risk,
including the potential for losses that may exceed the original investment amount.
Security Selection: The risk of choosing a security that underperforms the market for unanticipated
reasons. There can be no assurance that clients will ever come to realize the value of some of these
investments, and that the investment will ever increase in value. During this time, the client may have
funds locked up in an underperforming investment, which presents an opportunity cost for other
investments.
Item 9 Disciplinary Information
On July 26, 2021, the United States Securities and Exchange Commission (“Commission”) accepted
WESTBOURNE’S Offer of Settlement (“Offer”) in connection with WESTBOURNE’S failure to file with the
Commission and to deliver to retail investor clients WESTBOURNE’S Form CRS. Pursuant to the Offer,
WESTBOURNE was required to file its initial Form CRS with the Commission as Part 3 of its Form ADV and to
begin delivering its Form CRS to prospective and new retail investor clients, as applicable, by June 30,
2020. WESTBOURNE was further required to deliver its Form CRS to existing retail investor clients by July
30, 2020. Westbourne filed Form CRS with the Commission on and posted Form CRS to its website on
February 24, 2021, and delivered Form CRS to its existing retail investor clients between March 5, 2021
and March 30, 2021. As a result of this conduct, the Commission found that WESTBOURNE violated Advisers
Act Section 204 and Rules 204-1 and 204-5 thereunder. Without admitting or denying the findings,
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Form ADV Part 2A Disclosure Brochure
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WESTBOURNE entered into the Offer whereby WESTBOURNE was ordered to cease and desist from
committing or causing any violations and any future violations of Advisers Act Section 204 and Rules 204-
1 and 204-5 and censured and the SEC imposed a civil money penalty in the amount of $25,000, which
WESTBOURNE paid in full.
Notwithstanding the foregoing, WESTBOURNE is not aware of any other legal or disciplinary events that are
material to a client’s or prospective client’s evaluation of WESTBOURNE’S advisory business or the integrity
of WESTBOURNE’S management persons.
Item 10 Other Financial Industry Activities and Affiliations
Neither WESTBOURNE nor any of our management persons are registered or have an application pending
to register as a broker-dealer, or a registered representative of a broker-dealer, futures commission
merchant, commodity pool operator, commodity trading advisor or as an associated person of the
foregoing entities.
Neither WESTBOURNE nor its management person has any relationship or arrangement that is material to
our advisory business or to our clients that WESTBOURNE or any of our management persons have with any
related person.
Certain of WESTBOURNE’S supervised persons, in their individual capacities, are licensed insurance agents
and recommend the purchase of certain insurance-related products on a commission basis through non-
affiliated insurance agencies. As a result, these individuals have an incentive to recommend products or
services that create the greatest compensation for the individual. Clients should review their financial
professional’s Form ADV Part 2B Brochure Supplement to determine whether the client’s financial
professional is engaged insurance activities that may create a conflict of interest. If the client did not
receive the financial professional’s Form ADV Part 2B Brochure Supplement, the client may contact the
WESTBOURNE using the information on the cover page of this Brochure. Clients are not under any obligation
to purchase or sell any commission products or any other services offered by WESTBOURNE’S financial
professionals (in their individual capacities).
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
WESTBOURNE has adopted a code of ethics setting forth policies and procedures, including the imposition
of restrictions on itself and employees, to the extent reasonably necessary to prevent certain violations
of applicable law. This Code of Ethics and Conduct is intended to set forth those policies and procedures
and to state the WESTBOURNE’s broader policies regarding its duty of loyalty to clients. A copy of
WESTBOURNE’S code of ethics is available upon request by contacting WESTBOURNE, using the information
on the cover page of this Brochure.
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March 29,2026
Form ADV Part 2A Disclosure Brochure
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Participation or Interest in Client Transactions
Generally, neither WESTBOURNE nor any related person of WESTBOURNE recommends to clients, or buys
or sells for client accounts, securities in which WESTBOURNE or where any related person of WESTBOURNE
has a material financial interest. For example, WESTBOURNE does not act as (1) a principal when buying
securities from (or selling securities to) clients; (2) general partner in a partnership that clients are solicited
to investment; or (3) an investment adviser to an investment company (i.e., mutual fund) that is
recommend to clients.
Personal Trading
Associated persons of WESTBOURNE may invest in securities which they recommend, buy or sell for clients.
All officers and employees of WESTBOURNE buy and sell such stocks on a “last-in, last-out” basis, so that
they trade at the same time, or later, then clients to avoid any conflicts.
Item 12 Brokerage Practices
Best Execution and Benefits of Custodial Selection
WESTBOURNE recommends Charles Schwab & Co., Inc. (“Schwab”) to clients for custody and brokerage
services. As part of WESTBOURNE’S overall relationship, WESTBOURNE receives research and other benefits
from Schwab. Such research and other benefits include, but are not limited to, investment-related
research, pricing information and market data, software and other technology that provide access to
client account data, compliance and/or practice management-related publications, discounted or gratis
consulting services, discounted and/ or gratis attendance at conferences, meetings, and other educational
and/or social events, marketing support, computer hardware and/ or software and/or other products
used by WESTBOURNE in furtherance of its investment advisory business operations. Other benefits include,
facilitating payment of our fees from client accounts, assisting with back-office and support functions,
recordkeeping and client reporting, and institutional trading and custody services, which are typically not
available to retail investors. However, clients should be aware that the fees charged by a particular
custodian (or broker/dealer) for a particular transaction or set of transactions may be greater than the
amounts another custodian (or broker/dealer) who did not provide research services or products might
charge.
Many of these services are used to service all of WESTBOURNE’S client accounts, including accounts not
maintained at Schwab that provide or pay for the research or other benefit(s). Therefore, WESTBOURNE
has an incentive to recommend Schwab based on the overall relationship. WESTBOURNE is obligated to
seek best execution for all trades; however, in seeking best execution, the determinative factor is not the
lowest possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a services. While WESTBOURNE reviews the accuracy, timeliness and
execution of trades processed through Schwab, WESTBOURNE cannot guarantee that a client will receive
the most favorable execution of their trades, which in turn may cost clients more money. Periodically,
WESTBOURNE reviews the custodial services provided by other qualified custodians. WESTBOURNE selected
Schwab due, in part, to accessibility, electronic trading, efficient and professional service, technical
support, and timely reporting to clients.
Research and Other Soft Dollar Benefits
WESTBOURNE does not receive research or other products or services from other broker-dealers or third
parties in connection with client securities transactions (“soft dollar benefits”).
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Brokerage for Client Referrals
WESTBOURNE does not recommend broker-dealers based on client referrals.
Directed Brokerage
For our investment advisory services, client transactions are executed through Schwab or the qualified
custodian and, for held-away assets, through the designated custodian, administrator, or product
provider. WESTBOURNE may be unable to achieve the most favorable execution of client transactions and
clients may pay higher transaction costs or receive less favorable prices. WESTBOURNE does not generally
allow client-directed brokerage accounts.
Aggregate Orders
IN CERTAIN CIRCUMSTANCES, WESTBOURNE advisors elects to transact aggregated or “bunched” orders when
more than two clients (at a particular custodian) require a purchase or sale of the same equity security
(i.e., stocks and ETFs) at the same time. All clients’ accounts participating in the aggregated order shall
receive an average share price. If an aggregated purchase or sale order for such a security is executed over
multiple days, WESTBOURNE applies the average price achieved each day. In some instances, a non-
aggregated order might provide a better price to clients. In addition, trades for tax-overlay accounts may
be processed separately from other advisory accounts. Therefore, same-day or multi-day trade timing
differences can occur between the processing, submission and the execution of securities transactions,
resulting in execution price differences between accounts and clients.
Each client is responsible for individual account transaction costs.
Item 13 Review of Accounts
All advisory clients’ positions are monitored daily and advisory accounts are periodically reviewed by the
advisors of WESTBOURNE. This review process focuses on the portfolio's construction relative to the client's
goals, objectives, and guidelines, individual security holdings, and capital gain/loss considerations for
taxable accounts.
Account custodians are responsible for providing quarterly account statements which reflect the positions
(and current pricing) in each account as well as transactions in each account, including fees paid from an
account. Clients are urged to compare any report provided by WESTBOURNE with the confirmations and
statements directly received from the qualified custodian.
Item 14 Client Referrals and Other Compensation
WESTBOURNE has entered into a referral arrangement with a non-affiliated Trustee (“Promoter”) whereby
the Promoter agreed to recommend WESTBOURNE’s advisory services to potential clients. In exchange for
this service, WESTBOURNE pays the Promoter referral fees. Such referral fees shall be paid solely from
WESTBOURNE’s advisory fees and shall not result in any additional charge to the client greater than the fees
or costs WESTBOURNE charges its advisory clients who were not introduced by the Promoter and have
similar portfolios under management with WESTBOURNE. When a client is introduced to WESTBOURNE by an
unaffiliated Promoter, the Promoter shall disclose the nature of the Promoter’s relationship, and shall
provide each prospective client with a copy of WESTBOURNE’s written brochure as required, together with
a copy of a separate written disclosure statement from the Promoter to the client disclosing the terms of
the arrangement between WESTBOURNE and the Promoter, including the compensation to be received
by the Promoter from WESTBOURNE.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 13 of 14
Item 15 Custody
Upon written authorization from WESTBOURNE, the custodian will directly debit client account(s) for the
payment of WESTBOURNE’S advisory fees. This ability to deduct WESTBOURNE’S advisory fees from client
accounts causes WESTBOURNE to exercise limited custody over client funds or securities. WESTBOURNE does
not have physical custody of any clients’ funds and/or securities. Client funds and securities will be held
with a bank, broker-dealer, or other qualified custodian. Clients will receive account statements from the
qualified custodian(s) holding the client’s assets at least quarterly. These account statements will indicate
the amount of WESTBOURNE’S advisory fees deducted from the account(s) each billing period. Note: The
qualified custodians do not verify the accuracy of WESTBOURNE’S advisory fee calculation and clients do
not receive an invoice from WESTBOURNE showing calculation of its advisory fees. Clients with any
questions should contact the client’s advisor or WESTBOURNE using the information on the front of this
Brochure.
Item 16 Investment Discretion
As described above under Item 4 - Advisory Business, WESTBOURNE accepts discretionary authority to
manage securities accounts on behalf of clients. WESTBOURNE has the authority to determine, without
obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to
be bought or sold. Clients must sign a limited power of attorney before WESTBOURNE is given discretionary
authority.
Item 17 Voting Client Securities
WESTBOURNE does not vote client securities. Generally, clients will receive proxy materials or other
solicitations directly from the applicable custodian or issuer’s proxy agent and should direct any questions
as instructed in the specific proxy matter. WESTBOURNE does not provide legal advice or represent or
facilitate class action claims or participate in other similar legal proceedings on behalf of clients.
Item 18 Financial Information
WESTBOURNE does not have any financial impairment that will preclude the firm from meeting contractual
commitments to clients. A balance sheet is not required to be provided because WESTBOURNE does not
serve as a custodian for client funds or securities and does not require prepayment of fees of more than
$1,200 per client, six months or more in advance. WESTBOURNE has not been the subject of a bankruptcy
petition at any time.
Westbourne Investments, Inc.
March 29,2026
Form ADV Part 2A Disclosure Brochure
Page 14 of 14