The London Company of Virginia, LLC (“London Company”) is an independently owned SEC-
registered investment advisor. The firm was originally founded in 1994 and is headquartered in
Richmond, Virginia. It was established by Stephen M. Goddard, CFA and is focused on managing
primarily domestic equities with a conservative, long term orientation. Mr. Goddard is the majority
owner of the firm and serves as Founder, Chairman and Chief Investment Officer. The London
Company is organized as a Delaware limited liability company, formed in 2012, in a corporate
reorganization in connection with a minority (non-controlling) equity investment made in the firm
by LPC London, LP, an affiliate of Lincoln Peak Capital. Lincoln Peak Capital is a private investment
firm that specializes in partnering with investment management firms to help preserve their
independence and facilitate equity transitions within a firm to key next generation management
members.
The London Company provides discretionary portfolio management services to individuals and
institutional investors through separate, sub-advisory, and wrap fee programs, as well as non-
discretionary services, via certain model portfolios (UMA). We offer multiple equity investment
strategies, which are discussed in Item 8 of this brochure. Our clients choose one of our investment
strategies to meet their needs. Upon request, we will often work with clients to accommodate client-
specific restrictions on any of our investment strategies.
Separately Managed Accounts
Separately managed accounts are individually managed and maintained for tax-exempt and taxable
clients on a fully discretionary basis. The account portfolios are comprised primarily of domestic
equities with a core/value emphasis and long-term orientation.
Sub-Advisory Accounts
London Company has sub-advisory relationships with other investment firms. We provide
discretionary investment advice on a separate account basis to clients of these outside
intermediaries. We strive to manage these accounts in the same manner as our direct accounts. The
terms and conditions of these arrangements may vary and contact between London Company and
such clients will typically take place through the relevant intermediary. Clients who obtain our
services on a sub-advisory basis are able to impose restrictions on the management of their accounts.
We also act as a sub-advisor to several registered mutual funds. As such, we provide professional
investment advisory services on a discretionary basis for several equity mutual funds. Investments
for the mutual funds are managed in accordance with each fund’s investment objective, strategies,
and restrictions. They are not tailored to the individualized needs of any particular investor in the
fund.
Investment Manager Services
London Company serves as investment manager to multiple Collective
Investment Trusts (“CITs”),
sponsored by a trust company. We serve as the investment manager, pursuant to an investment
management agreement, and receive a fee for managing the investment portfolio. The CIT has not
been registered under federal or state securities laws, and is subject to an exemption provided by
Rule 3(c)(11) of the Investment Company Act of 1940. The CIT is only available for investment by
qualified retirement plans and is not for sale to the general public.
Wrap Fee Program Accounts
London Company serves as a sub-advisor in several “wrap fee” programs, in which clients establish
an account in an investment program offered by another investment advisor (wrap program
sponsor). As such, London Company may sub-advise a portion, or all, of an account. Client accounts
in wrap fee programs are typically assessed, by the wrap program sponsor, a bundled or blanket fee
for transactions and investment advisory service fees (wrap fee). London Company receives a
portion of the wrap fee from the sponsor, as a sub-advisor to these programs. In these relationships
we do not typically have direct contact with the underlying client, as we do with our direct accounts,
although we manage these accounts to the same model as our non-wrap accounts.
Model-Based Programs
Pursuant to an agreement, certain Unified Managed Account (UMA) and/or Model Program Sponsors
(“Sponsor”) receive London Company’s model securities portfolio for a particular investment style
and, based on that model, the Sponsor or its designated representative (“Overlay Manager”) exercises
investment discretion and executes each investor’s portfolio transactions predicated on the
Sponsor’s or Overlay Manager’s own investment judgment. These Programs are referred to as
Model-Based Programs. London Company typically provides its model portfolio (also known as
impersonal investment advice) to the Sponsor or Overlay Manager, who subsequently, provides
investment advice to its clients, based on their individual needs. When changes are made to a model
by London Company, the Sponsor or Overlay Manager is responsible for implementing any
modifications in their client accounts that are invested in the specific strategy. The Sponsor/Overlay
Manager may or may not elect to execute all the purchase and/or sale transactions suggested by
submissions of revisions in the model portfolio.
London Company does not have any contact with the underlying client of these programs. London
Company does not enter trades, receive trade reports, or have access to any client reporting related
to these accounts. It is the responsibility of the Sponsor to determine whether our model is suitable
for their clients.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, London Company had a total of $15.6 billion in assets under management,
all of which were discretionary assets.