General Information
Eastover Investment Advisors, LLC, was formed in 2009, when it purchased Eastover Capital
Management. Eastover Capital Management was originally formed in 1988 by Donald Toney, who
continues to serve on Eastover’s Investment Committee. Eastover Investment Advisors, LLC uses the
d/b/a of Eastover Capital Management (“Eastover”) and provides portfolio management services to
its clients.
Yancey Williams (“Will”) Mackey is the sole principal owner of Eastover. Please see
Brochure
Supplement, Exhibit A, for more information on Mr. Mackey and other individuals who formulate
investment advice and have direct contact with clients or have discretionary authority over client
accounts.
As of December 31, 2023, Eastover managed $306,818,107 client assets on a discretionary basis and
$20,913,608 client assets on a non-discretionary basis.
SERVICES PROVIDED
At the outset of each client relationship, Eastover spends time with the client, asking questions,
discussing the client’s investment experience and financial circumstances, and reviewing options for
the client. Based on its reviews, Eastover generally develops with each client:
• a financial outline for the client based on the client’s financial circumstances and goals, and
the client’s risk tolerance level (the “Financial Profile” or “Profile”); and
• the client’s investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments Eastover will make on
behalf of the client to meet those goals. The Profile and the Plan are discussed regularly with each
client but are not necessarily written documents.
Financial Planning
Eastover offers limited financial planning services to those clients in need of such service in
conjunction with Portfolio Management services. Eastover’s limited financial planning services
normally address areas such as general cash flow planning, retirement planning, and insurance
analysis. The goal of this service is to assess the financial circumstances of the client to more
effectively develop the client’s Investment Plan. Financial Planning is not offered as a stand-alone
service or for a separate fee but is typically provided in conjunction with the management of the
portfolio.
Portfolio Management
As described above, at the beginning of a client relationship, Eastover meets with the client, gathers
information, and performs research and analysis as necessary to develop the client’s Investment Plan.
The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by Eastover based on updates to the client’s financial or
other circumstances.
To implement the client’s Investment Plan, Eastover will manage the client’s investment portfolio on
a discretionary basis. As a discretionary investment adviser, Eastover
will have the authority to
supervise and direct the portfolio without prior consultation with the clien
t.1
Notwithstanding the foregoing, clients may impose certain written restrictions on Eastover in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should note, however, that restrictions
imposed by a client may adversely affect the composition and performance of the client’s investment
portfolio. Each client should also note that his or her investment portfolio is treated individually by
giving consideration to each purchase or sale for the client’s account. For these and other reasons,
performance of client investment portfolios within the same investment objectives, goals and/or risk
tolerance may differ, and clients should not expect that the composition or performance of their
investment portfolios would necessarily be consistent with similar clients of Eastover.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions.
Eastover will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular
services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies)
designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the
decision to retain our firm; (ii) agree to the scope of the services that we will provide; and
(iii) make the ultimate decision as to accepting any of the recommendations that we may provide.
The Plan Fiduciaries are free to seek independent advice about the appropriateness of any
recommended services for the Plan. Retirement Plan consulting services may be offered individually
or as part of a comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, Eastover will be considered a fiduciary under ERISA. For example, Eastover will
act as an ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan
Fiduciaries by recommending a suite of investments as choices among which Plan Participants may
select. Also, to the extent that the Plan Fiduciaries retain Eastover to act as an investment manager
within the meaning of ERISA § 3(38), Eastover will provide discretionary investment management
services to the Plan. With respect to any account for which Eastover meets the definition of a fiduciary
under Department of Labor rules, Eastover acknowledges that both Eastover and its Related Persons
are acting as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the
written agreement between Eastover and Client.
Fiduciary Management Services
• Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), Eastover
provides continuous and ongoing supervision over the designated retirement plan assets.
1 Eastover has a legacy fee-sharing arrangement with a Separate Account Manager (“Manager”) to provide
discretionary investment management services to a few of Eastover’s clients. Eastover does not select or
recommend Managers to new clients.
Eastover will actively monitor the designated retirement plan assets and provide ongoing
management of the assets. When applicable, Eastover will have discretionary authority to
make all decisions to buy, sell or hold securities, cash or other investments for the designated
retirement plan assets in our sole discretion without first consulting with the Plan
Fiduciaries. We also have the power and authority to carry out these decisions by giving
instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan
for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services
Eastover will monitor the investment options of the Plan and add or remove investment
options for the Plan without prior consultation with the Plan Fiduciaries. Eastover will have
discretionary authority to make and implement all decisions regarding the investment
options that are available to Plan Participants.
• Investment Management via Model Portfolios.
Eastover will provide discretionary management of Model Portfolios among which the
participants may choose to invest as Plan options. Plan Participants will also have the option
of investing only in options that do not include Model Portfolios (i.e., the Plan Participants
may elect to invest in one or more of the mutual fund options made available in the Plan, and
choose not to invest in the Model Portfolios at all).
Non-Fiduciary Services
• Participant Education
Eastover will provide education services to Plan Participants about general investment
principles and the investment alternatives available under the Plan. Education presentations
will not take into account the individual circumstances of each Plan Participant and individual
recommendations will not be provided unless a Plan Participant separately engages Eastover
for such services. Plan Participants are responsible for implementing transactions in their
own accounts.
• Participant Enrollment
Eastover will assist with group enrollment meetings designed to increase retirement Plan
participation among employees and investment and financial understanding by the
employees.