Campion Asset Management, LLC ("Campion")is a privately held Virginia Limited Liability Corporation that was founded in May 2005 by Terence E. Burns, CFA®, who is the sole owner of Campion.
The firm is the culmination of his investment management experience over the last 20 years and his vision to create an investment advisory business that takes pride in its independence and objectivity and whose sole interest is the financial health of the clients it serves. These beliefs are reflected in the firm's Core Values: INDEPENDENCE♦ INTEGRITY♦ INNOVATION® Campion Asset Management has no parent company, affiliated companies, or joint ventures with any firm. Campion Asset Management offers investment management services on a discretionary and non- discretionary basis to individual and institutional clients in accordance with an investment management framework that involves the following elements:  Investment Policy Statement. Campion Asset Management develops an Investment Policy Statement at the outset of every client relationship. This document serves to guide all investment actions taken on behalf of a client and establish appropriate benchmarks for evaluating performance. This document provides a detailed description of a client's investment objectives, risk tolerance, liquidity requirements, investment horizon, tax situation, and any unique needs and circumstances.  Strategic Asset Allocation. Campion Asset Management believes that Strategic Asset Allocation explains much of the variability or fluctuation in a portfolio's returns. So, the way your portfolio is allocated predominantly explains the level of risk in your overall portfolio. Therefore, as an investment adviser, it is our job to develop a Strategic Asset Allocation that positions a client's portfolio to achieve his/her stated objective(s) in accordance with Investment Policy. Each client's agreed upon Strategic Asset Allocation indicates the target allocation to each suitable and appropriate asset class as well as an acceptable range beyond which the portfolio will be rebalanced.  Macroeconomic Analysis. Campion Asset Management analyzes the economy's current state relative to the overall business cycle in order to distinguish between short- and long-term trends within asset classes, sectors, and individual securities and develop tactical opportunities to enhance portfolio returns.  Portfolio Construction. Campion Asset Management constructs a well- diversified portfolio in accordance with each client's Investment Policy by carefully analyzing the optimal way to implement the recommended Strategic Asset Allocation. Our portfolio construction process incorporates the following considerations:
•Addresses a client's unique needs and circumstances that may influence how a portfolio should be invested.
•Evaluates the long-term benefits of complementing active portfolio management with passive investing.
•Determines the best mix of value versus growth-oriented investments. 4
•Implements the asset allocation using active management and exchange-traded funds (ETFs).
•Establishes limits on portfolio turnover to reduce costs and enhance returns.
•Portfolio Monitoring and Rebalancing. Campion Asset Management believes that ongoing monitoring and rebalancing of portfolios is a critical element of a sound investment management framework. Both of these steps are an integral part of enhancing portfolio returns and controlling portfolio risk. Disciplined rebalancing reinforces the strategy of reducing exposure to outperforming asset classes and increasing exposure to underperforming asset classes. Therefore, client portfolios are monitored on an ongoing basis and reviewed in detail on at least a quarterly basis. Client portfolios are rebalanced to the agreed upon Strategic Asset Allocation in accordance with the rebalancing threshold outlined by investment Policy. The rebalancing threshold is expressed as an acceptable percentage range (for example, plus or minus 5-10 percent) around the agreed upon asset allocation. Once the asset allocation moves outside the indicated range, the client portfolio is rebalanced back to the agreed upon asset allocation.
 Performance Measurement and Evaluation. Campion Asset Management believes that measuring and evaluating investment performance provides an ideal opportunity to compare the relative success of a client's investment strategy with stated objectives and relevant benchmarks. Performance attribution indicates how significantly asset class, sector, individual security, currency, and country exposure contribute to fluctuations in a portfolio's market value. Comprehensive analysis of a client's total portfolio provides all relevant information used to evaluate the achievement of a client's investment objectives and make informed decisions. Campion Asset Management calculates investment performance in accordance with industry standards and provides a fair, accurate, and complete picture of results. Campion Asset Management provides a quarterly report that includes net-of-fee investment performance for the latest quarter, year-to-date, one-year, three-year, and five-year rolling periods, and since inception using the modified Dietz methodology (time-weighted returns with geometric linking).
Actual investment returns are evaluated using asset-class benchmarks that have the following characteristics: measurable, appropriate, reflective of investment style, investable, specified in advance, and unambiguous.
This dynamic process does not end here, and it is for this reason that periodic meetings with the client are so important. Quarterly or semiannual meetings are obviously a time to focus attention on the value added by disciplined rebalancing and risk management, but they also present an ideal time to inquire whether a client's needs or circumstances have changed, document changes in Investment Policy, and adjust the overall asset allocation as necessary.
Investment management relationships are provided on either a discretionary or non-discretionary basis through separate investments in equities, fixed income securities, exchange traded funds, publicly traded master limited partnerships, mutual funds, cash-equivalents, real estate investment trusts and other instruments.
Under a discretionary investment management relationship,

a client grants Campion Asset Management investment discretion and authorization to invest, sell, and reinvest proceeds in the client's account without obtaining the client's prior confirmation of any proposed investment action.
5 Under a non-discretionary investment management relationship, Campion Asset Management is authorized to invest, sell, and reinvest proceeds in a client's account, only after obtaining a client's approval of any proposed investment recommendation.
It is worth noting that regardless of the type of investment management relationship, Campion Asset Management acts in a fiduciary capacity at all times when dealing with all clients.
Campion Asset Management also provides investment consulting services on matters such as allocation of assets among different classes, portfolio diversification, managing portfolio risk, retirement cash flow projections, and other general economic and financial topics.
Campion Asset Management does not assume custody of client assets; therefore, all managed accounts are maintained with an independent custodian for custody and safekeeping.
Investment advisory services are tailored to the individual needs of clients based on their investment objectives, risk tolerance, liquidity requirements, investment time horizon, tax situation, and any unique needs and circumstances.
Campion Asset Management manages client accounts in accordance with the investment mandates of each client relationship as outlined in the investment policy statement and subject to the guidelines and/or restrictions that have been provided by the client. Below are the guidelines that are followed when managing a client's portfolio:  Client investment objectives are identified by assessing the client's risk tolerance based upon their age, sources of income, current wealth, education, human capital, need for cash flows, investment goals, and emotional tolerance for volatility. Information provided by the client to develop an Investment Policy Statement is collected during client meetings, interviews, and/or questionnaires.  In order to tailor investment management services and develop effective investment advice for each client's unique needs and circumstances, Campion Asset Management strives to gain a clear understanding, if applicable, of each client's personal tax and cash flow needs, estate plans, retirement plans, and educational funding needs. Doing so requires Campion Asset Management to collect detailed personal financial information and often involves the preparation of financial analyses and personal financial statements that reflect a client's net worth, cash flow and income tax liabilities.  Before implementing an investment strategy and specific investment recommendations and actions, Campion Asset Management reviews the Investment Policy Statement and confirms the agreed upon investment strategy and asset allocation.  Careful consideration is given to implementing a client's investment strategy and asset allocation using the optimal mix of investments. Capital market conditions and client circumstances are monitored. Portfolio adjustments are made as appropriate to reflect significant changes in client needs and circumstances as well as overall market conditions. In some circumstances, clients may impose restrictions on investing in certain securities or types of securities. Such restrictions are documented in a client's Investment Policy Statement. 6 Common restrictions may include the following:  Setting minimum credit rating criteria for individual bonds.  Setting maximum maturity or duration criteria for individual bonds.  Prohibition from investments in tobacco, defense, and other morally objectionable businesses.  Prohibition from investing in certain illiquid asset classes such as alternative investments, hedge funds, and private equity.  Prohibition from investing in derivative instruments such as options and futures contracts.  Prohibition from using leverage or short selling.  Prohibition from investing in securities of competitors when the client is considered a company insider or a particular industry when the client works for a government regulatory agency. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Campion Asset Management does not participate in any wrap fee program.
As of December 31, 2023, Campion Asset Management managed combined assets of approximately $189 million between discretionary and non-discretionary accounts as follows: Type of Management Relationship Amount ($ millions) Discretionary Basis $151 Non-Discretionary Basis$38 Total Assets under Management $189 7