Elgethun Capital Management is an investment advisor registered with the United States Securities and Exchange Commission (“SEC”) and is a Corporation formed under the laws of the State of South Dakota.
• John Barker is the owner, President and Chief Compliance Officer of Elgethun Capital Management.
• Elgethun Capital Management has been registered as an investment advisor since September 2003. General Description of Primary Advisory Services The following are brief descriptions of Elgethun Capital Management’s primary services. A detailed description of Elgethun Capital Management’s services is provided in Item 5 – Fees and Compensation so that clients and prospective clients can review the description of services and description of fees in a side- by-side manner. Asset Management Services – Elgethun Capital Management provides advisory services in the form of Asset Management Services. Asset Management Services involve providing clients with continuous and on- going supervision over client accounts. This means that Elgethun Capital Management will continuously monitor a client’s account and make trades in client accounts when necessary. Advisory Services to Pooled Investment Vehicles – Elbark Capital LLC is a related person of Elgethun under common control of John Barker and provides advisory services to a pooled investment vehicle: Palisades Fund LP. Consultation Services – Elgethun Capital Management provides investment advice through consultation services for an hourly rate. ECM Investment services may be involved with any financial service/advice for a client. The hourly rate is negotiable according to the work involved with the consultation/advice. Limits Advice to Certain Types of Investments. Elgethun Capital Management provides investment advice on the following types of investments:
• No-Load (i.e. no trading fee) and Load-Waived (i.e. trading fee waived) Mutual Fund Shares
• Exchange-listed securities (i.e. stocks)
• Securities traded over-the-counter (i.e. stocks)
• Fixed income securities (i.e. bonds)
• Closed-End Funds and Exchange Traded Funds (ETFs)
• Foreign Issues and American Depository Units (ADRs)
• Warrants
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• United States government securities
• Options contracts on securities and commodities
• Interests in partnerships

investing in real estate and oil and gas interests
• Hotel interests
• Hedge funds
• Private equity
• Private loans Elgethun Capital Management does not provide advice on variable life insurance, variable annuities, or futures contracts on tangibles or intangibles. When providing asset management services, Elgethun Capital Management typically constructs each client’s account holdings using individual equities, individual corporate, government/agency, or municipal bonds and equity/bond mutual funds to build diversified portfolios. It is not Elgethun Capital Management’s typical investment strategy to attempt to time the market but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Participation in Wrap Fee Programs We do not offer services through traditional wrap-fee management programs. In wrap-fee programs, advisory services (including portfolio management or advice regarding selecting other investment advisors) and transaction services are provided for one fee. In a standard asset management program, such as the one provided by Elgethun Capital Management, advisory services are provided for a fee, but transaction services are paid separately on a per-transaction basis to the broker-dealer. Consequently, Elgethun Capital Management does not receive any transaction-related revenue. Tailor Advisory Services to Individual Needs of Clients Elgethun Capital Management’s services are always provided based on the individual needs of each client. This means, for example, that you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with each client on a one- on-one basis through interviews and questionnaires to determine the client’s investment objectives and suitability information. Client Assets Managed by Elgethun Capital Management As of December 2023, Elgethun Capital Management managed $786,613,953 of discretionary assets. ECM had an additional $396,678,395, in assets under advisement. Total assets under management and advisement: $1,183,292,348.