Firm Description
We are both a registered investment adviser and a branch office of broker/dealer Raymond
James Financial Services, Inc. (RJFS), member FINRA/SIPC. Employees may provide advice for an
asset-based fee through the Firm or sell securities for commission through RJFS. RJFS has a
corporate affiliate, Raymond James & Associates, Inc. (RJA) member NYSE/SIPC. RJA is a dually
registered broker/dealer and investment advisor. RJFS accounts are custodied with RJA, and
RJA executes and clears transactions. RJA also facilitates various advisory programs. For further
information refer to the Raymond James & Associates Wrap Fee Program Brochure.
Principal Owners
The Firm is owned by Malcolm A. Makin, President, Chief Executive Officer and Chief
Compliance Officer. We, and our predecessors, were founded in 1975.
Types of Advisory Services
We provide discretionary and non-discretionary investment advisory services, financial planning
services, a selection of other investment management services and educational
workshops/seminars. We offer services to individuals, high net worth individuals, trusts,
estates, charitable organizations, corporations, endowments, and foundations.
Accounts Managed by your Investment Advisor Representative (IAR):
Ambassador
Ambassador is an investment advisory program which allocates your assets based upon your
financial objectives and risk tolerances. We are the advisor providing investment advisory
services and RJA administers the program providing support services for both clients and our
financial advisors. Ambassador offers clients the opportunity to (1) maintain full investment
authority and direct the individual investments made within their account(s), or (2) delegate
investment discretion to their financial advisor.
Accounts Managed by Other Asset Managers:
Freedom
Freedom is an investment program in which your assets are allocated to meet your financial
objectives and risk tolerances. Your IAR may assist you in selecting the appropriate Freedom
strategy. RJA acts as wrap-fee sponsor and manager providing portfolio management, selecting
the representative funds and monitoring their performance on a continuous basis. Your IAR
receives a portion of the asset-based fee.
Raymond James Consulting Service (RJCS)
RJCS is an investment program in which your assets are allocated to meet your financial
objectives and risk tolerances. Your IAR may assist you in selecting an appropriate program
based on your financial objectives and risk tolerance. RJA acts as wrap-fee sponsor and
manager providing portfolio management, selecting certain portfolio managers, monitoring
performance, providing other administrative services and assisting portfolio managers with
certain trading activities. Your IAR receives a portion of the asset-based fee.
Other Services:
Raymond James Trust
We utilize Raymond James Trust, N.A. which offers personal trust services, including serving as
trustee or as an agent or custodian for individual trustees. Raymond James Trust serves living
trusts, charitable remainder trusts, life insurance trusts and specialty trusts. We make
suggestions regarding asset allocation and individual investment transactions required to
implement, monitor, and adjust the trust portfolio. Raymond James Trust serves as the trustee
(or co-trustee) and has final approval on all investment suggestions.
Financial Planning
We offer financial planning services. This service reviews aspects of a client’s financial situation,
which may include cash management, risk management, insurance, education funding, goal
setting, retirement planning, estate and charitable giving planning, tax considerations, and
capital needs planning.
We meet with the client to review risk tolerance, financial goals and objectives and time
horizon. Meetings may include a review of additional financial information including sources of
income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax
returns, investments, and personal and family
obligations.
The scope of financial planning services may vary, and clients should understand that when the
scope is limited, that certain financial components may not be taken into consideration.
Wrap Fee Programs
A “wrap-fee” program is one that provides the client with advisory and brokerage execution
services for an all-inclusive fee.
We offer the Ambassador program where we manage the investment portfolio. We actively
solicit advisory clients for this program and are responsible for marketing the program.
We also participate in Freedom and RJCS, both wrap fee programs where you appoint RJA as
the subadvisor to manage your investment strategy.
In evaluating the programs, clients should consider that, depending on the wrap fee charged,
the amount of portfolio activity in the client’s account, the broker dealer's usual commission
rates and other factors, the wrap fee may be more or less than the aggregate cost of such
services if they were to be provided separately and if we were to negotiate commissions and
seek best price and execution of transactions for the client's account.
Tailored Relationships
We tailor investment advisory services to the individual needs of the client. The goals and
objectives for each client are documented in our client relationship management system.
Investment policy statements may be created that reflect the stated goals and objectives.
Our clients are allowed to impose restrictions on the investments in their account. We may
accept any reasonable limitation or restriction to discretionary authority placed on the account
by the client. All limitations and restrictions must be presented to us in writing.
Fiduciary Statement
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,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), 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. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Client Assets
As of December 31, 2023, assets under management on a fee basis were $1,055,252,906.
Assets managed on a discretionary basis were $983,198,733 and assets managed on a non-
discretionary basis were $72,054,173.