Description of Services and Fees Carpenter, Claydon Advisors, Inc. is a registered investment adviser based in Maitland, Florida. We are organized as a sub-Chapter S corporation under the laws of the State of Florida. We have been providing investment advisory services since 2007. Deborah Claydon is our sole owner. Currently, we offer the following investment advisory services, which are personalized to each individual client:
•Financial Planning and Consulting Services
•Portfolio Management Services
•Asset Allocation and Portfolio Monitoring/Review Services
•Pension Consulting Services The following paragraphs describe our services and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we," "our" and "us" refer to Carpenter, Claydon Advisors, Inc. and the words "you," "your" and "client" refer to you as either a client or prospective client of our firm. In addition, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Financial Planning Services We offer broad-based, modular, and consultative financial planning services. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we specify those long-term objectives (both financial and non-financial), we will develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm and the data derived from our financial planning software, we will review with you the financial projections, designed to help you evaluate your capacity to meet your stated financial goals and objectives. In limited circumstances, you may only require advice on a single aspect of the management of your financial resources. In these instances, we offer financial plans in a modular format and/or general consulting services that address only those specific areas of interest or concern.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You must promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Our fee for financial planning services will be based on either a fixed fee, typically ranging between $1,000 and $10,000, or an hourly fee of $300. These fees may be negotiated based on the complexity and scope of the engagement and your individual circumstances. An estimate of the total time/cost will be determined at the start of the advisory relationship. In limited circumstances, the time/cost could potentially exceed the initial estimate. In such cases, we will notify you and may request that you approve the additional fee. Typically, financial planning fees will be due upon presentation of the plan. However, other fee payment arrangements may be negotiated. For example, particularly complex 4 ©2017 National Compliance Services 800-800-3204 plans may require prepayment of a portion of the estimated fee for services. For lengthy engagements, interim payments may be requested. For hourly consulting services in which a plan is not presented, the fee will typically be payable upon completion of the consultation.
Applicable fees, fee payment arrangements, and the terms of the engagement will be clearly set forth in the client agreement executed between you and our firm prior to services being rendered. In no circumstance will we require prepayment of a fee more than six months in advance and in excess of $1,200.
Financial planning services are generally based on an annual term. On-going financial planning services, which will include meetings to review your progress towards stated goals, asset performance and re-balancing, and review of third-party advisers (if applicable), are available upon delivery of the financial plan. The financial plan is used to assist us in organizing your financial information and determining the scope of services that are most suitable for your specific financial situation and investment needs.
Upon completion of the financial plan, we will provide implementation services, as described more fully below. As requested, we may recommend other professional advisers, e.g. accountants, independent trustees/trust companies, or legal counsel, among others. However, we will not be compensated for such referrals. We may also work in conjunction with your other professional advisers. Under such arrangements, we will act as a project manager to coordinate the work of the appropriate parties in a manner consistent with your objectives.
Fees and terms for subsequent years will be negotiated on a case-by-case basis, and a new financial planning agreement will be executed between you and our firm. The annual fee will be negotiable based on the scope of the subsequent engagement. Such fees are typically payable quarterly in arrears as invoiced; however, other fee-paying arrangements maybe negotiated on as case-by-case basis for subsequent engagements.
Updates to a financial plan that would be considered extraordinary in nature would not be included under the retainer service. These updates will be provided at your request and for an additional fee. Extraordinary research or analysis may involve additional costs, which will be negotiated on an individual basis in advance of such additional services rendered.
You may terminate a financial planning agreement within five business days after the date when all parties have signed the agreement without penalty. Any pre-paid fees will be returned to you. After this five-day period, either party may terminate the agreement upon written notice to the other. If a deposit has been collected by us, a pro rata refund will be sent to you. Conversely, you may incur a pro rata charge for bona fide financial planning and/or consulting services rendered prior to such termination.
We offer a variety of services to you for the implementation of your financial plan as explained below. Portfolio Management Services We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis, and will re-balance the portfolio as required by changes in market conditions and in your financial circumstances. 5 ©2017 National Compliance Services 800-800-3204 Asset Allocation and Portfolio Monitoring/Review Services We may provide asset allocation and/or portfolio monitoring/review services on a non-discretionary basis. Such services are offered for the purposes of re-balancing your portfolio or for monitoring and/or processing client initiated transactions. These services will be provided on a non-continuous pre- determined periodic basis, such as monthly, quarterly, semi-annually, or annually. The frequency of the services provided will be agreed upon between us and will be detailed in the client agreement. Such services may include a review of your existing portfolio with asset allocation recommendations, a review/evaluation of recommendations made by other advisory professionals for suitability, management and/or monitoring of a participant's investments in a 401(k) plan, or on-going portfolio monitoring services.
Portfolio Management and Asset Allocation Fees Our fee for portfolio management services is based on a percentage of the assets in your account and is set forth in the following annual fee schedule: Annual Fee Schedule Assets Under Management Annual

FeeFee @ TopBlended Rate @ Top $0 - $500,000* 1.00%$5,0001.000% On the Next $500,001 - $1,000,000 0.75%$8,7500.875% On the Next $1,000,001 - $2,000,000 0.50%$13,7500.688% On the Next $2,000,001 - $5,000,000 0.30%$22,7500.455% On the Next $5,000,001 - $10,000,000 0.20%$33,7500.328% On the Next $10,000,001 - $20,000,000 0.10%$42,7500.214% Our annual portfolio management fee is billed and payable, quarterly in arrears, based on the balance at end of billing period. If the portfolio management agreement is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. The fee is negotiable based on the complexity of the client's individual circumstances and the scope of the engagement, including the number of services selected. Such terms and fees will be detailed in the written advisory agreement.
Typically, we require a minimum account size of $500,000. However, at our discretion we may waive or reduce these minimums. Additionally, at our discretion we may allow related accounts (i.e. accounts for spouses, minor children, etc.) to be aggregated for purposes of meeting the previously stated minimums or for determining the supervisory or management fee.
We will invoice you directly for the payment of fees or payment of fees will be made by the qualified custodian holding your funds and securities provided you give written authorization permitting the fees to be paid directly from your account(s). We will not have access to your funds for payment of fees 6 ©2017 National Compliance Services 800-800-3204 without your consent in writing. Further, the qualified custodian agrees to deliver a monthly or quarterly account statement directly to you showing all disbursements from the account. You are encouraged to review their account statements for accuracy. We will receive a duplicate copy of or will have electronic access to statements delivered to you.
Termination of Portfolio Management and Asset Allocation Fees If the disclosure brochure - Part II of the Form ADV - is not delivered to you, at least 48 hours prior to entering into an agreement for services, you may terminate the agreement for services within five business days of execution without penalty. If you have received, the disclosure documents 48 hours in advance, or if the five-day grace period has expired, either party may terminate the agreement upon 30 days written notice to the other. The fee will be pro-rated for the quarter in which the cancellation notice was given. As fees are payable in arrears, refunds are not applicable.
Pension Consulting Services We will provide pension consulting and/or investment management services to employee benefit plans, the plan sponsors and fiduciaries (collectively, the "client") based upon the needs of the plan as communicated by the client or, if requested, as determined by us. In general, we will provide fiduciary and non-fiduciary services which may include an existing plan review, formation of the investment policy statement, recommendation or selection of investment options for the plan, asset allocation advice, investment performance monitoring, ongoing consulting, and/or communication and education services where we will assist the client in providing meaningful information regarding the retirement plan to its participants. The specific services to be performed will be detailed in the services agreement with the client. Additionally, we may assist the client in setting up a relationship with a third party administrator and processing enrollment forms. However, we will not be the "plan administrator" as defined in ERISA and shall not have discretion over the administration of the plan or the plan assets. Services involving plan participants will be limited to educational and general, impersonal advice. The scope of these services, the fees, and the terms of the agreement for these services will be negotiated on a case-by-case basis with each client. We may be compensated based on a percentage of the assets in the plan, a fixed fee, an hourly fee, or a combination of fee arrangements based on the complexity of the plan and the agreement with the client. In any case, we will not have access to client funds for payment of fees without written consent by the client. The terms regarding payment of fees, termination, and refund will clearly set forth in the agreement executed between the client and us.
These accounts are regulated under the Employee Retirement Income Securities Act ("ERISA"). We will provide consulting services to the client as described above. If we are providing consulting services limited to recommendations of investment options and selection of investment managers or other service providers, the client must make the ultimate decision as to our recommendations. The client is free to seek independent advice about the appropriateness of any recommended services for the plan.
Plan participants who wish to engage us for individualized planning or management services regarding non-plan assets and the associated fees may do so by executing a separate agreement with us.
If the disclosure brochure - Part II of the Form ADV - is not delivered to the client, at least 48 hours prior to entering into the pension consulting agreement, the client may terminate the agreement for services within five business days of execution without penalty. If the client received the disclosure documents 48 hours in advance, or if the five-day grace period has expired, either party may terminate the pension consulting agreement upon written notice to the other. The plan will incur a pro rata charge for bona fide pension consulting services rendered prior to such termination. If applicable, any pre- paid, unearned fees will be promptly refunded to the client. 7 ©2017 National Compliance Services 800-800-3204 Types of Investments We primarily recommend mutual funds and exchange traded funds (ETFs). However, we offer advice on equity securities, corporate debt securities, certificates of deposit, municipal securities, other investment company securities, and US Government securities. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
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 may 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.
Assets Under Management As of December 31, 2023, we manage $275,849,316 in client assets on a non-discretionary basis and $3,786,272 in client assets on a discretionary basis.