J.L. Bainbridge was founded in 1981 and is primarily owned by Jerry L. Bainbridge-Chief Executive Officer and Fay E. Bainbridge Chief Operating Officer. Please refer to the ADV Part 1 found at www.adviser.sec.gov for additional minority owners of JL Bainbridge. J.L. Bainbridge provides investment advice to retail clients. The firm primarily invests the client portfolios using the firm’s primary investment program which is conservative growth in established domestically based companies. JLB also provides retail clients with investment management advice using the firm’s fixed income program. For further detail on the investment management process at JLB, please refer to ITEM 8 Methods of Analysis, Investment Strategies, and Risk of Loss in this Brochure. The firm provides investment management services primarily limited to Growth and Income objectives. The Growth program uses primarily stocks. However, on a limited basis when accounts are first onboarded the firm will advise on and maintain other holdings such as ETFs and Mutual funds. The Income program uses a combination of securities including Stocks, Bonds, ETF’s, Mutual Funds, CDs, and Treasuries. The company provides discretionary investment management services for individuals and high net worth individuals, pension plans and 401K’s. The firm will manage the client’s account according to its Growth and Fixed Income Programs of the firm. The firm will allow the client to impose limited restrictions on investing in certain types of securities as they indicate in writing. Furthermore, the firm will take into consideration initial assets used to fund the client’s portfolio for tax purposes. JLB also provides a covered call option selection that can be added to your strategy. If selected, we will purchase in your account call options that are issued against stocks that you own and give the buyer the right to purchase your stock at a designed price over a specific timeframe. Our strategy involves selling long-term calls options with a price that the buyer can purchase your stock above the current price. Clients may also have pledged assets and invest on a margin basis. Although these are not part of our recommended strategy, we will help manage these assets. Held Away Assets Assets in accounts with a financial institution or third party other than the primary custodian we work with. Effective June 1st, 2022, JLB provides services for primarily individual 401(k), 403b, Thrift Savings Plans and 529 accounts through the use of held away services. We also have the ability to add other custodians outside of the main custodian we work with. The service will allow us to have discretion and leverage the trade order management process, without having direct custody of your assets. We are not affiliated with the platform and receive no compensation for the use of the platform. Once the client has authorized us, we can regularly review the available investment options in these accounts, monitor them, and implement our strategies in the same way we do other accounts, using different tools, as necessary. Medicare Insurance Analytics Clients of JLB are able to utilize the services of Caribou Medicare Planning Services to gain a greater understanding of their Medicare related insurance options , Currently, Clients are not charged

for this service,. JLB and its representatives do not sell insurance products or recommend insurers. are not registered insurance agents and are not providing any insurance advice. The service is for the clients of JLB to gain knowledge through Caribou Medicare Planning Services. Any recommendation made by the analysis service shall be implemented at the discretion of the client, although there is no obligation to utilize the service or to purchase insurance from any of the providers recommended Please refer to ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS - Hedging/Option Risk Assets Under Management: As of December 31, 2023, the total amount of client’s assets under management is $963,532,809 for 798 clients on a discretionary basis. JLB shall provide financial planning services as an incremental part of the overall services to clients. JLB will not charge additional financial planning fees. We have an inherent conflict of interest whenever we provide Financial Planning services to a client and Investment Advisory services. It could be in our best interest not to recommend paying down debt that would directly reduce the Assets Under Management that we manage and charge a percentage fee for. We mitigate this conflict by providing an overall plan suitable and in the best interest of the client. Whenever we provide Financial Planning Services we shall: 1. Document the scope of work in an agreement. 2. Prepare a questionnaire to understand the client’s needs. 3. Conduct a reasonable level of due diligence when referring other professionals to the financial planning client. 4. Disclosure of any and all compensation methods we shall receive. 5. Conduct reasonable due diligence when recommending or using technologies when providing professional CFP® services to a client. 6. Periodically monitor the CFP Board’s Code of Ethics and Standard of Conduct Whenever JLB makes a recommendation for the Financial Planning client to utilize the services of a third-party as mentioned above, JLB shall:
• Have a reasonable basis for the recommendation or Engagement based on the person’s reputation, experience, and qualifications;
• Disclose to the Client, at the time of the recommendation or prior to the Engagement, any arrangement by which someone who is not the Client will compensate or provide some other material economic benefit to the CFP® professional, the CFP® Professional’s Firm, or a Related Party for the recommendation or Engagement; and
• When engaging a person to provide services for a client, exercise reasonable care to protect the Client’s interests. When selecting or using and recommending technology JLB shall document the due-diligence process which will include:
• Exercising reasonable care and judgment when selecting, using, or recommending any software, digital advice tool, or other technology while providing Professional Services to a Client.
• Having reasonable level of understanding of the assumptions and outcomes of the technology employed.
• Having reasonable basis for believing that the technology produces reliable, objective, and appropriate outcomes. The CFP® professionals of JLB will also review the complete CFP Board Code of Ethics and Standards of Conduct and the Practice Standards to ensure proper implementation within the firm.