This Disclosure document is being offered to you by James River Asset Management, LLC
(“JRAM” or “Firm”) about the investment advisory services we provide. It discloses
information about our services and the way those services are made available to you, the
client.
We are an investment management firm located in Midlothian, Virginia. We specialize in
investment advisory services for individuals, high net worth individuals, employee
sponsored retirement plans, charitable organizations, trusts and estates. James River
Wealth Advisors was formed and is under common control with James River Asset
Management. Our Firm became a registered investment adviser in April 1995. We are
an employee owned firm with Lucas Swygard serving as the sole Managing Member.
We are committed to helping clients build, manage, and preserve their wealth, and to
provide assistance that helps clients to achieve their stated financial goals. We will offer
an initial complimentary meeting upon our discretion; however, investment advisory
services are initiated only after you and JRAM execute an Investment Management
Agreement.
Investment Management Services
We manage advisory accounts on a discretionary and non-discretionary basis. For
discretionary accounts, once we have determined a profile and investment plan with a
client, we will execute the day to day transactions without seeking prior client consent.
Account supervision is guided by the written profile and investment plan of the client.
We may accept accounts with certain restrictions if circumstances warrant. We primarily
allocate client assets among various equities, Exchanged Traded Funds (“ETFs”), n o-load
mutual funds and debt securities in accordance with their stated investment objectives.
All of which are considered asset allocation categories for the client’s investment
strategy.
During personal discussions with clients, we determine the client’s objectives, time
horizons, risk tolerance and liquidity needs. As appropriate, we also review a client’s prior
investment history, as well as family composition and background. Clients complete a
financial fact finder and financial attitudes questionnaire. Based on client needs, we
develop a client’s personal profile and asset allocation model. We then create and
manage the client’s investments based on that policy and plan. It is the client’s obligation
to notify us immediately if circumstances have changed with respect to their goals.
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Once we have determined the types of investments to be included in your portfolio and
allocated them, we will provide ongoing investment review and management services.
This approach requires us to periodically review your portfolio.
With our discretionary relationship, we will make changes to the portfolio, as we deem
appropriate, to meet your financial objectives. We trade these portfolios based on the
combination of our market views and your objectives, using our investment process. We
tailor our advisory services to meet the needs of our clients and seek to ensure that your
portfolio is managed in a manner consistent with those needs and objectives. You will
have the ability to leave standing instructions with us to refrain from investing in
particular industries or invest in limited amounts of securities.
If a non-discretionary relationship is in place, the Firm will call the client and present the
recommendation. The Firm will not take any action on the client’s behalf until the Firm
receives client authorization.
We do have limited authority to direct the Custodian to deduct our investment advisory
fees from your accounts, but only with the appropriate written authorization from you.
Where appropriate, we provide advice about any type of legacy position held in client
portfolios. Typically, these are assets that are ineligible to be custodied at our primary
custodian. Clients will engage us to advise on certain investment products that are not
maintained at their primary custodian, such as annuity contracts and assets held in
employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
You are advised and are expected to understand that our past performance is not a
guarantee of future results. Certain market and economic risks exist that adversely affect
an account’s performance. This could result in capital losses in your account.
Disclosure Regarding Rollover Recommendations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide
investment advice to you regarding your retirement plan account or individual retirement
account, we are also fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws
governing retirement accounts. We have to act in your best interest and not put our
interest ahead of yours. At the same time, the way we make money creates some conflicts
with your interests.
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A client or prospect leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money
in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) rollover to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory
services. As a result, our Firm and its representatives may earn an asset-based fee. In
contrast, a recommendation that a client or prospective client leave their plan assets with
their previous employer or roll over the assets to a plan sponsored by a new employer
will generally result in no compensation to our Firm. Our Firm therefore has an economic
incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various
factors that our Firm will consider before recommending a rollover, including but not
limited to: (i) the investment options available in the plan versus the investment options
available in an IRA, (ii) fees and expenses in the plan versus the fees and expenses in an
IRA, (iii) the services and responsiveness of the plan’s investment professionals versus
those of our Firm, (iv) protection of assets from creditors and legal judgments, (v) required
minimum distributions and age considerations, and (vi) employer stock tax consequences,
if any. Our Firm’s Chief Compliance Officer remains available to address any questions
that a client or prospective client has regarding the oversight.
Standard financial planning services are included within our investment management
services at no additional fee.
Participant Account Management (Discretionary)
JRAM may use a third-party platform to facilitate management of held away assets such
as defined contribution plan participant accounts, with discretion. The platform allows us
to avoid being considered to have custody of Client funds since we do not have direct
access to Client log-in credentials to affect trades. We are not affiliated with the platform
in any way and receive no compensation from them for using their platform. A link will be
provided to the Client
allowing them to connect an account(s) to the platform. Once Client
account(s) is connected to the platform, Adviser will review the current account
allocations. When deemed necessary, Adviser will rebalance the account considering
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client investment goals and risk tolerance, and any change in allocations will consider
current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account
performance. Client account(s) will be reviewed at least quarterly and allocation changes
will be made as deemed necessary.
Financial Planning
We offer financial planning services which typically involve providing a variety of advisory
services to clients regarding the management of their financial resources based upon an
analysis of their individual needs. These services can range from broad-based financial
planning to consultative or single subject planning. If you retain our firm for financial
planning services, we will meet with you to gather information about your financial
circumstances and objectives. We may also use financial planning software to determine
your current financial position and to define and quantify your long-term goals and
objectives. Once we specify those long-term objectives (both financial and non-financial),
we will develop shorter-term, targeted objectives. Once we review and analyze the
information you provide to our firm and the data derived from our financial planning
software, we will deliver a written plan to you, designed to help you achieve your stated
financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to
you, and on the financial information you provide to us. You must promptly notify our
firm if your financial situation, goals, objectives, or needs change.
As may be applicable, we may recommend additional comprehensive financial planning
and consulting services for our clients in the special needs community, offered through
our affiliate, Eli’s Village. (See Item 10 below for more details on this affiliation).
Financial Consulting Services
We offer financial consulting services that primarily involve advising clients on specific
financial-related topics. The topics we address may include, but are not limited to, risk
assessment/management, investment planning, financial organization, or financial
decision making/negotiation.
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Employer Sponsored Retirement Plan Services
For employer-sponsored retirement plans with participant-directed investments, our
firm provides its advisory services as an investment advisor as defined under Section
3(21) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment advisor, the Plan Sponsor and JRAM share
fiduciary responsibility. The Plan Sponsor retains ultimate decision-making authority for
the investments and may accept or reject the recommendations in accordance with the
terms of a separate ERISA 3(21) Investment Advisor Agreement between JRAM and the
Plan Sponsor. JRAM provides the following services to the Plan Sponsor:
• Screen investments and make recommendations.
• Monitor the investments regularly and suggests replacement investments when
appropriate.
• Provide an annual investment report.
• Assist the Plan Sponsor in developing an Investment Policy Statement (“IPS”).
We can also be engaged to provide financial education to Plan participants. The scope of
education provided to participants will not constitute “investment advice” within the
meaning of ERISA and participant education will relate to general principles for investing
and information about the investment options currently in the Plan. We may also
participate in initial enrollment meetings and periodic workshops and enrollment
meetings for new participants.
Third Party Money Managers (TPMM)
JRAM maintains relationships with outside managers. JRAM periodically evaluates
managers and would consider their use where appropriate to meet targeted client needs.
Selected Managers are evaluated by JRAM for client use. These Managers are selected
for your investments need to meet several quantitative and qualitative criteria
established by JRAM. Among the criteria that may be considered are the Manager’s
experience, assets under management, performance record, client retention, the level of
client services provided, investment style, buy and sell disciplines, capitalization level,
and the general investment process.
You are advised and should understand that:
• A Manager’s past performance is no guarantee of future results;
• There is a certain market and/or interest rate risk which may adversely affect any
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• Manager’s objectives and strategies, and could cause a loss in a Client's
account(s); and
• Client risk parameters or comparative index selections provided to JRAM are
guidelines only and there is no guarantee that they will be met or not be
exceeded.
JRAM’s IARs shall be available to answer questions the client may have regarding their
account and act as the communication conduit between the client and the Manager.
Managers may take discretionary authority to determine the securities to be purchased
and sold for the client. Neither JRAM nor its associated persons will have any trading
authority with respect to clients’ managed account with the TPMM(s).
All accounts are managed by the selected Manager and JRAM does not have any
discretionary trading authority with respect to such accounts. Information collected by
our firm regarding Managers is believed to be reliable and accurate, but JRAM does not
necessarily independently review or verify it on all occasions. All performance reporting
will be the responsibility of the respective Manager. Such performance reports will be
provided directly to you and JRAM. JRAM does not audit or verify that these results are
calculated on a uniform or consistent basis as provided by a Manager directly to JRAM or
through the consulting service utilized by the Manager.
JRAM has entered into agreements with independent Managers. Under these
agreements, JRAM offers client’s various types of programs sponsored by these
Managers. All third-party money Managers to whom JRAM will refer clients will be
licensed as registered investment advisors by their resident state and any applicable
jurisdictions or registered investment advisors with the Securities and Exchange
Commission.
Third-party managed programs generally have account minimum requirements that will
vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts. A complete description of
the Manager’s services, fee schedules and account minimums will be disclosed in the
Manager’s Form ADV or similar Disclosure Brochure which will be provided to clients at
the time an agreement for services is executed and account is established.
Wrap Fee Program
We do not sponsor or manage a Wrap Fee Program.
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Assets
As of December 31, 2023, our firm manages a total of $149,107,917 in assets under
management. We manage $143,398,389 in discretionary assets and $5,709,528 in non-
discretionary assets.