Campbell Asset Management, LLC (Campbell Asset)was formed in 2003 by the principal of our firm James P. Campbell, III. We are a private wealth management firm offering both fee-only financial planning and investment advisory services. We create customized investment portfolios based on our client’s individual risk tolerance, taxes, income needs, and return objectives. We gather this information based on initial client meetings, and/or individual financial plans. Clients may engage our firm in comprehensive financial planning. Subsequent client communication, meetings, or life events may create the necessity to change objectives, goals and/or financial plan. Our clients may also impose restrictions on investing in certain securities and selling legacy positions if stated in writing. Legacy positions are securities that a client previously owned prior to engaging Campbell Asset as discretionary investment adviser. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report, which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax situation and projected spending for current and future years; then illustrate the impact of various investments on the client’s current income tax and future tax liability. We also consider the cash flow impact of an extended period of Long Term Care needs on the client’s estate assets to predict liquidity needs.
• INVESTMENTS: We analyze investment alternatives and their effect on the client’s portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, and liability. If specifically requested by the client, we also review home and auto coverage, but these typically fall outside the scope of our standard financial plan review.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals based upon projected retirement dates.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, projected death tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client’s current financial status, tax status, net worth components, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney and accountant. Implementation of financial plan recommendations is entirely at the client’s discretion. INVESTMENT ADVISORY Our firm provides continuous advice “on a fee only” basis to our clients regarding the investment of client funds based on the individual needs of the client. All fees and

remuneration are fully disclosed to our clients. Through personal discussions in which goals and objectives based on a client’s particular circumstances are established, we create and manage a portfolio based on those parameters. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, capacity to accept risk, and liquidity needs. As appropriate, we also review and discuss a client’s prior investment history, as well as family composition, background, and special needs. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client’s stated objectives such as growth, income and tax considerations. Clients may impose, in writing, reasonable restrictions on investing in specific securities, types of securities, or industry sectors. Once the client’s portfolio has been implemented, we monitor and reallocate based on the client’s individual needs. Our investment recommendations generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities
• Mutual funds
• Exchange traded funds
• U.S. governmental securities
• Real Estate Investment Trusts (REITs)
• Commodities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client’s stated investment objectives, tolerance for risk, liquidity and suitability. SUBADVISER SERVICES Campbell Asset may also act as a subadviser to advisers unaffiliated with Campbell Asset. These third-party advisers would outsource portfolio management services to Campbell Asset. This relationship will be memorialized in each contract between Campbell Asset and the third-party advisor. PENSION CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to individuals and trusts, estates and charitable organizations. Pension Consulting Services are comprised of three distinct services. Clients may choose to use any or all of these services. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review various mutual funds (both index and managed) to determine which investments are appropriate. The number of investments to be recommended will be determined by the plan sponsor. Monitoring of Investment Portfolios: We monitor the investment portfolios on an on-going basis. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the plan’s portfolio components and will make recommendations to the plan sponsor as market factors and the client’s needs dictate. Employee Communications: For pension, profit sharing and 401(k) plan clients wherein individual plan participants exercising control over assets in their own account (‘’self-directed plans’’), we may also provide annual educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by us and the plan sponsor under the guidelines established in ERISA Section 404©. The educational support and investment workshops will NOT provide plan participants with individualized, tailored investment advice or individualized, tailored asset allocation recommendations. As of December 2023, our firm manages assets totaling $109,174,446. Of this total, $108,327,824 is in discretionary assets and $846,622 is in non-discretionary assets.