View Document Text
Brochure
Form ADV Part 2A
Item 1 - Cover Page
Westhampton Capital, LLC
CRD# 119176
2150 Country Club Road
Suite 250
Winston-Salem, North Carolina 27104
Telephone: (336) 725-5579
www.westhamptoncapital.com
January 6, 2026
This brochure provides information about the qualifications and business practices of Westhampton
Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (336)
725-5579 or brant@westhamptoncapital.com. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
authority.
Westhampton Capital, LLC 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
Westhampton Capital, LLC also is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Material Changes
, 202
This Brochure is prepared in the revised format required beginning in 2011. Registered Investment
Advisers are required to use this format to inform clients of the nature of advisory services provided,
types of clients served, fees charged, potential conflicts of interest and other information. The
Brochure requirements include providing a Summary of Material Changes (the “Summary”) reflecting
any material changes to our policies, practices, or conflicts of interest made since our last required
“annual update” filing. In the event of any material changes, such Summary is provided to all clients
within 120 days of our fiscal year-end. Our last annual update was filed on January
. Of
course, the complete Brochure is available to clients at any time upon request.
8
5
Item 3 - Table of Contents
Page
Item 1 - Cover Page ...................................................................................................................................................................... 1
Item 2 - Material Changes ........................................................................................................................................................ 1
Item 3 - Table of Contents ........................................................................................................................................................ 2
Item 4 - Advisory Business ...................................................................................................................................................... 3
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 ........................................................................................................................................ 9
Item 10 - Other Financial Industry Activities and Affiliations .............................................................................. 9
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 9
Item 12 - Brokerage Practices ............................................................................................................................................. 10
Item 13 - Review of Accounts .............................................................................................................................................. 12
Item 14 - Client Referrals and Other Compensation ............................................................................................... 12
Item 15 - Custody....................................................................................................................................................................... 13
Item 16 - Investment Discretion ........................................................................................................................................ 13
Item 17 - Voting Client Securities ...................................................................................................................................... 13
Item 18 - Financial Information ......................................................................................................................................... 14
Brochure Supplements…………………..………………………...………..………………………………………… Exhibit A
Page 2
Item 4 - Advisory Business
General Information
Westhampton Capital, LLC (“Westhampton Capital”) was formed in 1998, and provides portfolio
management services to its clients.
Brant R. Snavely is the principal owner, founder and Chief Executive Officer of Westhampton Capital.
Please see Brochure Supplements, Exhibit A, for more information on Mr. Snavely and other
individuals who formulate investment advice and have direct contact with clients or have
discretionary authority over client accounts.
As of December 31, 2025, Westhampton Capital managed $238,519,094 on a discretionary basis, and
no assets on a non-discretionary basis.
SERVICES PROVIDED
At the outset of each client relationship, Westhampton Capital spends time with the client, asking
questions, discussing the client’s investment experience and financial circumstances, and reviewing
options for the client. Based on its reviews, Westhampton Capital generally develops with each
client:
•
•
a financial outline for the client based on the client’s financial circumstances and goals, and
the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile reflects the client’s current financial picture and a look to the future goals of the
client. The Investment Plan outlines the types of investments Westhampton Capital will make or
recommend on behalf of the client to meet those goals. The Profile and the Plan are discussed
regularly with each client but are not necessarily written documents.
Portfolio Management Services
As described above, at the beginning of a client relationship, Westhampton Capital meets with the
client, gathers information, and performs research and analysis as necessary to develop the client’s
Investment Plan. The Investment Plan will be updated from time to time when requested by the
client, or when determined to be necessary or advisable by Westhampton Capital based on updates
to the client’s financial or other circumstances.
To implement the client’s Investment Plan, Westhampton Capital will manage the client’s investment
portfolio on a discretionary basis. As a discretionary investment adviser, Westhampton Capital will
have the authority to supervise and direct the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may impose certain written restrictions on Westhampton
Capital in the management of their investment portfolios, such as prohibiting the inclusion of certain
types of investments in an investment portfolio or prohibiting the sale of certain investments held in
the account at the commencement of the relationship. Each client should note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the client’s
investment portfolio. Each client should also note that his or her investment portfolio is treated
individually by considering each purchase or sale for the client’s account. For these and other
Page 3
reasons, performance of client investment portfolios within the same investment objectives, goals
and/or risk tolerance may differ and clients should not expect that the composition or performance
of their investment portfolios would necessarily be consistent with similar clients of Westhampton
Capital.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. Westhampton Capital
will provide Retirement Plan consulting services to Plans and Plan Fiduciaries as described below.
The services provided will be detailed in the consulting agreement. The appropriate Plan
Fiduciary(ies) designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i)
make the decision to retain our firm; (ii) agree to the scope of the services that we will provide; and
(iii) make the ultimate decision as to accepting any of the recommendations that we may provide. The
Plan Fiduciaries are free to seek independent advice about the appropriateness of any recommended
services for the Plan. Retirement Plan consulting services may be offered individually or as part of a
comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, Westhampton Capital will be considered a fiduciary under ERISA. For example,
Westhampton Capital will act as an ERISA § 3(21) fiduciary when providing nondiscretionary
investment advice to the Plan Fiduciaries by recommending a suite of investments as choices among
which Plan Participants may select. Also, to the extent that the Plan Fiduciaries retain Westhampton
Capital to act as an investment manager within the meaning of ERISA § 3(38), Westhampton Capital
will provide discretionary investment management services to the Plan.
With respect to any account for which Westhampton Capital meets the definition of a fiduciary under
Department Of Labor rules, Westhampton Capital acknowledges that both Westhampton Capital and
its Related Persons are acting as fiduciaries. Additional disclosure may be found elsewhere in this
Brochure or in the written agreement between Westhampton Capital and Client.
Fiduciary Consulting Services
•
Investment Selection Services
Westhampton Capital will provide Plan Fiduciaries with recommendations of investment
options consistent with ERISA section 404(c). Plan Fiduciaries retain responsibility for the
final determination of investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
Westhampton Capital provides Plan Fiduciaries and Plan Participants general,
nondiscretionary investment advice regarding asset classes and investments.
•
Investment Monitoring
Westhampton Capital will assist in monitoring the plan’s investment options by preparing
periodic investment reports that document investment performance, consistency of fund
management and conformation to the guidelines set forth in the investment policy statement
and Westhampton Capital will make recommendations to maintain or remove and replace
Page 4
investment options. The details of this aspect of service will be enumerated in the
engagement agreement between the parties.
Fiduciary Management Services
• Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), Westhampton
Capital provides continuous and ongoing supervision over the designated retirement plan
assets. Westhampton Capital will actively monitor the designated retirement plan assets and
provide ongoing management of the assets. When applicable, Westhampton Capital will have
discretionary authority to make all decisions to buy, sell or hold securities, cash or other
investments for the designated retirement plan assets in our sole discretion without first
consulting with the Plan Fiduciaries. We also have the power and authority to carry out these
decisions by giving instructions, on your behalf, to brokers and dealers and the qualified
custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services
Westhampton Capital will monitor the investment options of the Plan and add or remove
investment options for the Plan without prior consultation with the Plan Fiduciaries.
Westhampton Capital will have discretionary authority to make and implement all decisions
regarding the investment options that are available to Plan Participants.
•
Investment Management via Model Portfolios.
Westhampton Capital will provide discretionary management of Model Portfolios, among
which the participants may choose to invest as Plan options. Plan Participants will also have
the option of investing only in options that do not include Model Portfolios (i.e., the Plan
Participants may elect to invest in one or more of the mutual fund options made available in
the Plan and choose not to invest in the Model Portfolios at all).
Non-Fiduciary Services
•
Participant Education
Westhampton Capital will provide education services to Plan Participants about general
investment principles and the investment alternatives available under the Plan. Education
presentations will not consider the individual circumstances of each Plan Participant and
individual recommendations will not be provided unless a Plan Participant separately
engages Westhampton Capital for such services. Plan Participants are responsible for
implementing transactions in their own accounts.
•
Participant Enrollment
Westhampton Capital will assist with group enrollment meetings designed to increase
retirement Plan participation among employees and investment and financial understanding
by the employees.
Page 5
Item 5 - Fees and Compensation
General Fee Information
Fees paid to Westhampton Capital are exclusive of all custodial and transaction costs paid to the
client’s custodian, brokers or other third-party consultants. Please see Item 12 – Brokerage
Practices for additional information. Fees paid to Westhampton Capital are also separate and distinct
from the fees and expenses charged by mutual funds, ETFs (exchange traded funds) or other
investment pools to their shareholders (generally including a management fee and fund expenses, as
described in each fund’s prospectus or offering materials). The client should review all fees charged
by funds, brokers, Westhampton Capital and others to fully understand the total amount of fees paid
by the client for investment and financial-related services.
Portfolio Management Fees
The negotiable annual fee for portfolio management services, based on a percentage of assets under
management, is up to 1.5%.
The minimum portfolio value eligible for conventional investment advisory services is generally
$250,000. Westhampton Capital may, at its discretion, make exceptions to the foregoing or negotiate
special fee arrangements where Westhampton Capital deems it appropriate under the circumstances.
Portfolio management fees are generally payable quarterly, in arrears. If management begins after
the start of a quarter, fees will be prorated accordingly. With client authorization and unless other
arrangements are made, fees are normally debited directly from client account(s).
Either Westhampton Capital or the client may terminate their Investment Advisory Agreement at any
time, subject to any written notice requirements in the agreement. In the event of termination, any
fees due to Westhampton Capital from the client will be invoiced or deducted from the client’s account
prior to termination.
Retirement Plan Services Fees
The fee for Retirement Plan Services is individually negotiated based upon the complexity of the plan,
the composition of the plan assets, the actual services provided and the client’s relationship with
Westhampton Capital. The agreed upon fee is disclosed to the client prior to any service being
provided. Retirement plan sponsors pay all fees for any individualized services provided by
Westhampton Capital to the plan participants.
Retirement plan service fees are generally payable quarterly, in arrears. If management begins after
the start of a quarter, fees will be prorated accordingly. With client authorization and unless other
arrangements are made, fees are normally debited directly from client account(s).
Either Westhampton Capital or the client may terminate their Investment Management Agreement at
any time, subject to any written notice requirements in the agreement. In the event of termination,
any fees due to Westhampton Capital from the client will be invoiced or deducted from the client’s
account prior to termination.
Other Compensation
David A. Leland, Portfolio Manager, and Paul Fulton, III, Director of Marketing, of Westhampton
Capital, are also licensed to sell insurance in North Carolina. In providing advisory services, David or
Paul may recommend the purchase of products under circumstances where they would be entitled to
Page 6
receive a commission or other compensation in the transaction. In all such circumstances, however,
the client will be notified of this payment in advance of the transaction, and under no circumstances
will the client pay both a commission to David or Paul and a management fee to Westhampton Capital
on the same pool of assets.
Item 6 - Performance-Based Fees and Side-By-Side Management
Westhampton Capital does not have any performance-based fee arrangements. “Side-by-Side
Management” refers to a situation in which the same firm manages accounts that are billed based on
a percentage of assets under management and at the same time manages other accounts for which
fees are assessed on a performance fee basis. Because Westhampton Capital has no performance-
based fee accounts, it has no side-by-side management.
Item 7 - Types of Clients
Westhampton Capital serves individuals, high net worth individuals, charitable organizations and
pension and profit-sharing plans. With some exceptions, the minimum portfolio value eligible for
conventional investment advisory services is $250,000.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies
In accordance with the Investment Plan, Westhampton Capital will allocate the account as to stocks,
bonds, and cash; distribute the equity and debt assets into industry groups; select individual stocks
and bonds; and write covered calls when deemed appropriate.
Westhampton Capital offers customized portfolio management to meet the specific financial
objectives of investors. These accounts are managed by our in-house team of portfolio managers
using a structured, quantitative approach to sector and security selection. Westhampton Capital’s
investment philosophy is based on the belief that a company’s long-term value is based on the cash
flow it ultimately generates. The Westhampton Capital investment process utilizes both quantitative
and qualitative analysis to assess a company’s ability to generate cash flow and its current valuation
relative to intrinsic value. Westhampton Capital believes the disciplined, systematic application of its
approach, as modeled below, will lead to long-term value for its clients.
Investment Management Process Model
Flow
Financial Quality
Assessment
Sector Selection
Final
Portfolio
Cash
Analysis
Quantitative statistics
related to balance sheet
quality and shareholder
Assess realistic
growth potential
and valuations
Based on the current
outlook for the business
and economic cycle weight
the Standard & Poor’s (S&P) value creation
industry sectors
Page 7
We believe that our growth at a reasonable price philosophy provides the best opportunity for
competitive long-term performance with below average risk. We seek to purchase stocks from
companies selling at a discount to our estimate of intrinsic value based on a demonstrated earnings
record, a strong balance sheet, high return on capital, consistent free cash flow generation, and a
sound and shareholder friendly management team.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity
or income needs in a portfolio, or to add a component of capital preservation. Westhampton Capital
will generally evaluate and select individual bonds or bond funds based on several factors including,
without limitation, rating, yield and duration.
Risk of Loss
While Westhampton Capital seeks to diversify clients’ investment portfolios across various asset
classes consistent with their Investment Plans to reduce risk of loss, all investment portfolios are
subject to risks. Accordingly, there can be no assurance that client investment portfolios will be able
to fully meet their investment objectives and goals, or that investments will not lose money.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks. While Westhampton Capital manages client investment portfolios, based on
Westhampton Capital’s experience, research and proprietary methods, the value of client investment
portfolios will change daily based on the performance of the underlying securities in which they are
invested. Accordingly, client investment portfolios are subject to the risk that Westhampton Capital
allocates client assets to individual securities and/or asset classes that are adversely affected by
unanticipated market movements, and the risk that Westhampton Capital’s specific investment
choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above,
Westhampton Capital may invest client portfolios in mutual funds, ETFs and other investment pools
(“pooled investment funds”). Investments in pooled investment funds are generally less risky than
investing in individual securities because of their diversified portfolios; however, these investments
are still subject to risks associated with the markets in which they invest. In addition, pooled
investment funds’ success will be related to the skills of their managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions
applicable to registered investment companies under the Investment Company Act of 1940.
Equity Market Risks. Westhampton Capital will generally invest portions of client assets directly into
equity investments, primarily stocks, or into pooled investment funds that invest in the stock market.
As noted above, while pooled investments have diversified portfolios that may make them less risky
than investments in individual securities, funds that invest in stocks and other equity securities are
nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks
that stock values will decline due to daily fluctuations in the markets, and that stock values will
decline over longer periods (e.g., bear markets) due to general market declines in the stock prices for
all companies, regardless of any individual security prospects.
Fixed Income Risks. Westhampton Capital may invest portions of client assets directly into fixed
income instruments, such as bonds and notes, or may invest in pooled investment funds that invest
in bonds and notes. While investing in fixed income instruments, either directly or through pooled
investment funds, is generally less volatile than investing in stock (equity) markets, fixed income
Page 8
investments nevertheless are subject to risks. These risks include, without limitation, interest rate
risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default
by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance
to maturity).
Foreign Securities Risks. Westhampton Capital may invest portions of client assets into pooled
investment funds that are invested internationally. While foreign investments are important to the
diversification of client investment portfolios, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial
reporting or disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency risk,
which is the risk that the value of the foreign security will decrease due to changes in the relative
value of the U.S. dollar and the security’s underlying foreign currency.
Item 9 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of Westhampton Capital or the
integrity of Westhampton Capital’s management. Westhampton Capital has no disciplinary events to
report.
Item 10 - Other Financial Industry Activities and Affiliations
Neither Westhampton Capital nor its Management Person has any other financial industry activities
or affiliations to report.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
Westhampton Capital has adopted a Code of Ethics (“the Code”), the full text of which is available to
you upon request. Westhampton Capital’s Code has several goals. First, the Code is designed to assist
Westhampton Capital in complying with applicable laws and regulations governing its investment
advisory business. Under the Investment Advisers Act of 1940, Westhampton Capital owes fiduciary
duties to its clients. Pursuant to these fiduciary duties, the Code requires people associated with
Westhampton Capital (managers, officers and employees) to act with honesty, good faith and fair
dealings in working with clients. In addition, the Code prohibits such associated persons from trading
or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for Westhampton Capital’s associated
people. Under the Code’s Professional Standards, Westhampton Capital expects its associated
persons to put the interests of its clients first, ahead of personal interests. In this regard,
Westhampton Capital associated people are not to take inappropriate advantage of their positions in
relation to Westhampton Capital clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated people. From time-to-time Westhampton Capital’s associated people may
invest in the same securities recommended to clients. Under its Code, Westhampton Capital has
adopted procedures designed to reduce or eliminate conflicts of interest that this could potentially
Page 9
cause. The Code’s personal trading policies include procedures for limitations on personal securities
transactions of associated persons, reporting and review of such trading and preclearance of certain
types of personal trading activities. These policies are designed to discourage and prohibit personal
trading that would disadvantage clients. The Code also provides for disciplinary action as
appropriate for violations.
Participation or Interest in Client Transactions
Because associated people may invest in the same securities as those held in client accounts,
Westhampton Capital has established a policy requiring its associated persons to pre-clear
transactions in some types of securities with the Chief Compliance Officer. The goal of this policy is
to avoid any conflicts of interest that arise in these situations. Some types of securities, such as CDs,
treasury obligations and open-end mutual funds, are exempt from this pre-clearance requirement.
However, in the event of other identified potential trading conflicts of interest, Westhampton Capital’s
goal is to place client interests first.
Consistent with the foregoing, Westhampton Capital maintains policies regarding participation in
initial public offerings (“IPOs”) and private placements to comply with applicable laws and avoid
conflicts with client transactions.
Finally, if associated people trade with client accounts (i.e., in a bundled or aggregated trade), and the
trade is not filled in its entirety, the associated person’s shares will be removed from the block, and
the balance of shares will be allocated among client accounts in accordance with Westhampton
Capital’s written policy.
Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts,
Westhampton Capital seeks “best execution” for client trades, which is a combination of several
factors, including, without limitation, quality of execution, services provided and commission rates.
Therefore, Westhampton Capital may use or recommend the use of brokers who do not charge the
lowest available commission in the recognition of research and securities transaction services, or
quality of execution. Research services received regarding transactions may include proprietary or
third-party research (or any combination) and may be used in servicing any or all of Westhampton
Capital’s clients. Therefore, research services received may not be used for the account for which the
particular transaction was affected.
Westhampton Capital recommends that clients establish brokerage accounts with National Financial
Services, LLC (“NFS”) an affiliate of Fidelity Investments, a FINRA registered broker dealer, member
SIPC, as the qualified custodian to maintain custody of clients’ assets. Westhampton Capital may also
affect trades for client accounts at NFS, or may in some instances, consistent with Westhampton
Capital’s duty of best execution and specific agreement with each client, elect to execute trades
elsewhere. Although Westhampton Capital may recommend that clients establish accounts at NFS, it
is ultimately the client’s decision to custody assets with NFS. Westhampton Capital is independently
owned and operated and is not affiliated with NFS.
NFS provides Westhampton Capital with access to its institutional trading, custody, reporting and
related services, which are typically not available to NFS retail investors. NFS also makes available
various support services. Some of those services help Westhampton Capital manage or administer
Page 10
our clients’ accounts while others help Westhampton Capital manage and grow our business. These
services generally are available to independent investment advisors on an unsolicited basis, at no
charge to them. These services are not soft dollar arrangements but are part of the institutional
platform offered by NFS. NFS’s brokerage services include the execution of securities transactions,
custody, research, and access to mutual funds and other investments that are otherwise generally
available only to institutional investors or would require a significantly higher minimum initial
investment.
For Westhampton Capital client accounts maintained in its custody, NFS generally does not charge
separately for custody services but is compensated by account holders through commissions and
other transaction-related or asset-based fees for securities trades that are executed through NFS or
that settle into NFS accounts. NFS Advisor Services also makes available to Westhampton Capital
other products and services that benefit Westhampton Capital but may not directly benefit its clients’
accounts. Many of these products and services may be used to service all or some substantial number
of Westhampton Capital accounts, including accounts not maintained at NFS.
NFS’s products and services that assist Westhampton Capital in managing and administering clients’
accounts include software and other technology that (i) provide access to client account data (such
as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide, pricing and other market data; (iv) facilitate
payment of Westhampton Capital’s fees from its clients’ accounts; and (v) assist with back-office
functions, recordkeeping and client reporting.
NFS also offers other services intended to help Westhampton Capital manage and further develop its
business enterprise. These services may include: (i) technology, compliance, legal and business
consulting; (ii) publications and conferences on practice management and business succession; and
(iii) access to employee benefits providers, human capital consultants and insurance providers. NFS
may make available, arrange and/or pay third-party vendors for the types of services rendered to
Westhampton Capital. The Custodians may discount or waive fees it would otherwise charge for some
of these services or pay all or a part of the fees of a third-party providing these services to
Westhampton Capital. NFS may also provide other benefits such as educational events or occasional
business entertainment of Westhampton Capital personnel. In evaluating whether to recommend
that clients custody their assets at NFS, Westhampton Capital may take into account the availability
of some of the foregoing products and services and other arrangements as part of the total mix of
factors it considers and not solely on the nature, cost or quality of custody and brokerage services
provided by NFS, which may create a potential conflict of interest.
Directed Brokerage
Clients may direct Westhampton Capital to use a particular broker for custodial or transaction
services on behalf of the client’s portfolio. In directed brokerage arrangements, the client is
responsible for negotiating the commission rates and other fees to be paid to the broker. Accordingly,
a client who directs brokerage should consider whether such designation may result in certain costs
or disadvantages to the client, either because the client may pay higher commissions or obtain less
favorable execution, or the designation limits the investment options available to the client.
The arrangement that Westhampton Capital has with NFS is designed to maximize efficiency and to
be cost effective. By directing brokerage arrangements, the client acknowledges that these economies
of scale and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that a client chooses to use the brokerage
Page 11
and/or custodial services of these alternative service providers can in fact result in a certain degree
of delay in executing trades for their account(s) and otherwise adversely affect management of their
account(s).
By directing Westhampton Capital to use a specific broker or dealer, clients who are subject to ERISA
confirm and agree with Westhampton Capital that they have the authority to make the direction, that
there are no provisions in any client or plan document which are inconsistent with the direction, that
the brokerage and other goods and services provided by the broker or dealer through the brokerage
transactions are provided solely to and for the benefit of the client’s plan, plan participants and their
beneficiaries, that the amount paid for the brokerage and other services have been determined by the
client and the plan to be reasonable, that any expenses paid by the broker on behalf of the plan are
expenses that the plan would otherwise be obligated to pay, and that the specific broker or dealer is
not a party in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
Westhampton Capital typically directs trading in individual client accounts as and when trades are
appropriate based on the client’s Investment Plan, without regard to activity in other client accounts.
However, from time to time, Westhampton Capital may aggregate trades together for multiple client
accounts, most often when these accounts are being directed to sell the same securities. If such an
aggregated trade is not completely filled, Westhampton Capital will allocate shares received (in an
aggregated purchase) or sold (in an aggregated sale) across participating accounts on a pro rata or
other fair basis; provided, however, that any participating accounts that are owned by Westhampton
Capital or its officers, directors, or employees will be excluded first.
Item 13 - Review of Accounts
Managed portfolios are reviewed at least quarterly but may be reviewed more often if requested by
the client, upon receipt of information material to the management of the portfolio, or at any time
such review is deemed necessary or advisable by Westhampton Capital. These factors generally
include but are not limited to, the following: change in general client circumstances (marriage,
divorce, retirement); or economic, political or market conditions. Brant Snavely, Chief Executive
Officer and Portfolio Manager, Harry Shertzer, Chief Compliance Officer and Portfolio Manager, David
Leland, Portfolio Manager and Paul Fulton, Director of Marketing, all review accounts.
Account custodians are responsible for providing monthly or 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. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. Westhampton Capital will provide
additional written reports as needed or requested by the client.
Item 14 - Client Referrals and Other Compensation
As noted above, Westhampton Capital receives an economic benefit from NFS in the form of support
products and services it makes available to Westhampton Capital and other independent investment
advisers whose clients maintain accounts at NFS. These products and services, how they benefit our
firm, and the related conflicts of interest, are described in Item 12 - Brokerage Practices. The
availability of NFS’s products and services to Westhampton Capital is based solely on our
participation in the program, and not on the provision of any particular investment advice. Neither
NFS nor any other party is paid to refer clients to Westhampton Capital.
Page 12
Item 15 - Custody
NFS is the custodian of nearly all client accounts at Westhampton Capital. From time to time, however,
clients may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms and at least quarterly
account statements. Clients are advised to review this information carefully, and to notify
Westhampton Capital of any questions or concerns. Clients are also asked to promptly notify
Westhampton Capital if the custodian fails to provide statements on each account held.
From time to time and in accordance with Westhampton Capital’s agreement with clients,
Westhampton Capital will provide additional reports. The account balances reflected on these
reports should be compared to the balances shown on the brokerage statements to ensure accuracy.
At times there may be small differences due to the timing of dividend reporting, pending trades or
other similar issues.
Item 16 - Investment Discretion
As described above under Item 4 - Advisory Business, Westhampton Capital manages portfolios on
a discretionary basis. This means that after an Investment Plan is developed for the client’s
investment portfolio, Westhampton Capital will execute that plan without specific consent from the
client for each transaction. For discretionary accounts, the client provides Westhampton Capital with
Trading and Asset Movement Authorizations, giving Westhampton Capital the authority to carry out
various activities in the account, generally including the following: trade execution; the ability to
request checks on behalf of the client, and the withdrawal of advisory fees directly from the account.
Westhampton Capital then directs investment in the client’s portfolio using its discretionary
authority. The client may limit the terms of the authorizations to the extent consistent with the
client’s investment advisory agreement with Westhampton Capital and the requirements of the
client’s custodian. The discretionary relationship is further described in the agreement between
Westhampton Capital and the client.
Westhampton Capital has a few legacy accounts that were originally set up under a nondiscretionary
arrangement. For these accounts, the client has provided Westhampton Capital with Trading and
Asset Movement Authorizations, which allow Westhampton Capital to carry out approved actions in
However, in accordance with the investment advisory agreement between
the portfolio.
implement trading
Westhampton Capital and the client, Westhampton Capital does not
recommendations or other actions in the account unless and until the client has approved the
recommendation or action. As with discretionary accounts, clients may limit the terms of these
authorizations, subject to Westhampton Capital’s agreement with the client and the requirements of
the client’s custodian.
Item 17 - Voting Client Securities
As a policy and in accordance with Westhampton Capital’s client agreement, Westhampton Capital
does not vote proxies related to securities held in client accounts. The custodian of the account will
normally provide proxy materials directly to the client. Clients may contact Westhampton Capital
with questions relating to proxy procedures and proposals; however, Westhampton Capital generally
does not research proxy proposals.
Page 13
Item 18 - Financial Information
Westhampton Capital does not require nor solicit prepayment of more than $1,200 in fees per client,
six months or more in advance, and therefore has no disclosure required for this item.
Page 14
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Brant R. Snavely, III
CRD#1179688
of
Westhampton Capital, LLC
2150 Country Club Road
Suite 250
Winston-Salem, North Carolina 27104
Telephone: (336)725-5579
www.westhamptoncapital.com
January 6, 2026
This brochure supplement provides information about Brant Snavely, and supplements the
Westhampton Capital, LLC (“Westhampton Capital”) brochure. You should have received a copy of
that brochure. Please contact us at (336)725-5579 if you have not received Westhampton Capital’s
brochure, or if you have any questions about the contents of this supplement.
Additional information about Brant is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Born 1959
Educational Background:
Wake Forest University: MBA, Finance, 1988
University of North Carolina: BS, 1982
Business Background and Affiliations:
Exhibit A-1
Westhampton Capital: Manager and Chief Executive Officer, 9/98-present
Item 3 – Disciplinary Information
Advisers are required to disclose any materials facts regarding certain legal or disciplinary events
That would be material to your evaluation of an advisers; however, Brant has no such disciplinary
information to report.
Item 4 - Other Business Activities
Brant is not engaged in any other business activities.
Item 5 - Additional Compensation
Brant has no other income or compensation to disclose.
Item 6 – Supervision
Brant R. Snavely, III is the Chief Executive Officer and majority owner of Westhampton Capital, LLC.
Harry R. Shertzer, Jr., is the Chief Compliance Officer of Westhampton Capital, LLC. Both are Portfolio
Managers and serve on the investment committee.
Overall investment decisions are made as a team by the investment committee, and portfolio activity
based on these decisions will be carried out by these individuals, assisted by other staff members of
the firm.
As Chief Compliance Officer, Harry is responsible for providing compliance supervisory oversight to
the staff. He also participates as a team member in the investment and trading processes and may be
contacted at (336) 725-5579.
Exhibit A-2
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Harry R. Shertzer, Jr.
CRD#1251803
of
Westhampton Capital, LLC
2150 Country Club Road
Suite 250
Winston-Salem, North Carolina 27104
Telephone: (336)725-5579
www.westhamptoncapital.com
January 6, 2026
This brochure supplement provides information about Harry Shertzer, and supplements the
Westhampton Capital, LLC (“Westhampton Capital”) brochure. You should have received a copy of
that brochure. Please contact us at (336)725-5579 if you have not received Westhampton Capital’s
brochure, or if you have any questions about the contents of this supplement.
Additional information about Harry is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Born 1947
Educational Background:
College of William and Mary, Mason School of Business: MBA, 1970
American University: BS, 1969
Business Background and Affiliations:
Westhampton Capital: Chief Compliance Officer & Portfolio Manager, 2/10-present
Exhibit A-3
Item 3 – Disciplinary Information
Advisers are required to disclose any materials facts regarding certain legal or disciplinary events
that would be material to your evaluation of an advisers; however, Harry has no such disciplinary
information to report.
Item 4 - Other Business Activities
Harry is not engaged in any other business activities.
Item 5 - Additional Compensation
Harry has no other income or compensation to disclose.
Item 6 – Supervision
Brant R. Snavely, III is the Chief Executive Officer and majority owner of Westhampton Capital, LLC.
Harry R. Shertzer, Jr., is the Chief Compliance Officer of Westhampton Capital, LLC. Both are Portfolio
Managers and serve on the investment committee.
Overall investment decisions are made as a team by the investment committee, and portfolio activity
based on these decisions will be carried out by these individuals, assisted by other staff members of
the firm.
As Chief Compliance Officer, Harry is responsible for providing compliance supervisory oversight to
the staff. He also participates as a team member in the investment and trading processes and may be
contacted at (336) 725-5579.
Exhibit A-4
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
David A. Leland
CRD#1922266
of
Westhampton Capital, LLC
2150 Country Club Road
Suite 250
Winston-Salem, North Carolina 27104
Telephone: (336)725-5579
www.westhamptoncapital.com
January 6, 2026
This brochure supplement provides information about David Leland, and supplements the
Westhampton Capital, LLC (“Westhampton Capital”) brochure. You should have received a copy of
that brochure. Please contact us at (336)725-5579 if you have not received Westhampton Capital’s
brochure, or if you have any questions about the contents of this supplement.
Additional information about David is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Born 1959
Educational Background:
Wake Forest University School of Law: 1984
Exhibit A-5
Wake Forest University: BA, Economics, 1981
Business Background and Affiliations:
Westhampton Capital: Portfolio Manager, 10/07-present
Item 3 – Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, David has no such disciplinary
information to report.
Item 4 - Other Business Activities
David Leland, Investment Adviser Representative of Westhampton Capital, is also licensed to sell
insurance in North Carolina. In providing advisory services, David may recommend the purchase of
products under circumstances where he would be entitled to receive a commission or other
compensation in the transaction. In all such circumstances, however, the client will be notified of this
payment in advance of the transaction, and under no circumstances will the client pay both a
commission to David and a management fee to Westhampton Capital on the same pool of assets.
Item 5 - Additional Compensation
Other than as stated above, David is not engaged in any other investment-related business or
occupation and does not earn compensation for the sale of any other products or services.
Item 6 – Supervision
Brant R. Snavely, III is the Chief Executive Officer and majority owner of Westhampton Capital, LLC.
Harry R. Shertzer, Jr., is the Chief Compliance Officer of Westhampton Capital, LLC. Both are Portfolio
Managers and serve on the investment committee.
Overall investment decisions are made as a team by the investment committee, and portfolio activity
based on these decisions will be carried out by these individuals, assisted by other staff members of
the firm.
As Chief Compliance Officer, Harry is responsible for providing compliance supervisory oversight to
the staff. He also participates as a team member in the investment and trading processes and may be
contacted at (336) 725-5579.
Exhibit A-6
Paul Fulton, III
CRD#2216544
of
Westhampton Capital, LLC
2150 Country Club Road
Suite 250
Winston-Salem, North Carolina 27104
Telephone: (336)725-5579
www.westhamptoncapital.com
January 6, 2026
This brochure supplement provides information about Paul Fulton, and supplements the
Westhampton Capital, LLC (“Westhampton Capital”) brochure. You should have received a copy of
that brochure. Please contact us at (336)725-5579 if you have not received Westhampton Capital’s
brochure, or if you have any questions about the contents of this supplement.
Additional information about Paul is available on the SEC’s website at www.AdviserInfo.sec.gov.
Item 2 - Educational Background and Business Experience
Born 1962
Educational Background:
Wofford College: BA, 1985
Business Background and Affiliations:
Westhampton Capital: Investment Adviser Representative, 11/2012–present
Deutsche Bank Securities, Inc.: Client Advisor, 10/2006-10/2012
Exhibit A-7
Item 3 Disciplinary information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events that
would be material to your evaluation of an adviser; however, Paul has no such disciplinary
information to report.
Item 4 - Other Business Activities
Paul Fulton, Investment Adviser Representative of Westhampton Capital, is also licensed to sell
insurance in North Carolina. In providing advisory services, Paul may recommend the purchase of
products under circumstances where he would be entitled to receive commission or other
compensation in the transaction. In all such circumstances, however, the client will be notified of this
payment in advance of the transaction, and under no circumstances will the client pay both a
commission to Paul and a management fee to Westhampton Capital on the same pool of assets.
Item 5 - Additional Compensation
Other than as stated above, Paul is not engaged in any other investment-related business or
occupation and does not earn compensation for the sale of any other products or services.
Item 6 – Supervision
Brant R. Snavely, III is the Chief Executive Officer and majority owner of Westhampton Capital, LLC.
Harry R. Shertzer, Jr., is the Chief Compliance Officer of Westhampton Capital, LLC. Both are Portfolio
Managers and serve on the investment committee.
Overall investment decisions are made as a team by the investment committee, and portfolio activity
based on these decisions will be carried out by these individuals, assisted by other staff members of
the firm.
As Chief Compliance Officer, Harry is responsible for providing compliance supervisory oversight to
the staff. He also participates as a team member in the investment and trading processes and may be
contacted at (336) 725-5579.
Exhibit A-8