Firm Description and Types of Advisory Services JNB Advisors, LLC is an investment adviser.
We were founded in 2019 as the result of a merger between Bender Lane Advisory,
LLC and Hugh Johnson Advisors, LLC. Bender Lane Advisory and Hugh Johnson
Advisors are divisions of JNB Advisors, LLC.
We provide a diverse range of financial services to our clients including, but not limited
to individuals, high net worth individuals and families, charitable organizations,
corporations, and retirement plans.
Principal Owners
We are owned by Daniel J. Rutnik, Hugh Johnson, Daniel P. Nolan, Joseph N. Vet, Jr.,
Susan M. Reese, Christopher M. Denisulk, Charles Brown and Robert T. Hennes.
Types of Advisory Services Investment Advisory Services
We provide investment advisory services, defined as giving continuous advice to a
client or making investments for a client based on the individual needs of the client.
Through personal discussions in which goals and objectives based on a client's
particular circumstances are established, we create customized, structured portfolios,
tailored to each client’s individual risk tolerance. As part of our investment advisory
services, we determine the client's individual objectives, time horizons, risk tolerance,
and liquidity needs. As appropriate, we also review and discuss a client's prior
investment history, as well as family composition and background. Account supervision
is guided by the client's stated objectives (i.e., maximum capital appreciation, growth,
income, or growth and income), as well as tax considerations. Asset allocation mix may
fluctuate and vary depending on our recommendations and market conditions. We will
manage advisory accounts on both a discretionary and non-discretionary basis.
For Non-discretionary accounts, individual determinations of investment allocation and
investment vehicle selection are made by the client. All such trades must be approved
in advance either verbally or in writing by the client before they will be carried out by us.
Our investment recommendations are not limited to any specific product or service and
will generally include advice regarding the following securities: exchange-listed
securities, securities traded over-the-counter, corporate debt securities (other than
commercial paper), certificates of deposit, municipal securities, mutual fund shares,
United States governmental securities, options, structured notes and private
placements.
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Because some types of investments involve certain additional degrees of risk, they will
only be implemented/recommended when consistent with the client's stated investment
objectives, tolerance for risk, liquidity and suitability.
Family Office / Financial Planning We offer a diverse range of services to high net worth individuals and their families to
efficiently use their wealth and personal skills to meet their objectives now and into the
future.
We provide financial planning services. Financial planning is an evaluation of a client's
current and future financial state by using currently known variables to predict future
cash flows, asset values and withdrawal plans. Through the financial planning process,
all questions, information and analysis are considered as they impact and are impacted
by the entire financial and life situation of the client. Financial planning clients may
receive a written report which provides the client with a detailed financial plan designed
to assist the client in achieving his or her financial goals and objectives.
The financial plan can address any or all of the following areas:
• Personal: We review family records, budgeting, personal liability, estate
information and financial goals.
• Tax & Cash Flow: We analyze the client's income tax and spending and
planning for past, current and future years; then illustrate the impact of
various investments on the client's current income tax and future tax
liability.
• Investments: We analyze investment alternatives and their effect on the
client's portfolio.
• Insurance: We review existing policies to ensure proper coverage for life,
health, disability, long-term care, liability, home and automobile.
• Retirement: We analyze current strategies and investment plans to help
the client achieve his or her retirement goals.
• Death & Disability: We review the client's cash needs at death, income
needs of surviving dependents, estate planning and disability income.
• Estate Planning: We assist the client in assessing and developing long-
term strategies, including as appropriate, trusts, wills, powers of attorney,
and asset protection plans. These services may include, but are not
limited to:
o Comprehensive maintenance and reporting of financial
information
o Income tax planning and compliance
o Family financial literacy education and coordination
o Bill paying
We gather required information through in-depth personal interviews. Information
gathered includes the client's current financial status, tax status, future goals, returns
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objectives and attitudes towards risk. We carefully review documents supplied by the
client and may prepare a written report. Should the client choose to implement the
recommendations contained in the plan, we suggest the client work closely with his/her
attorney, accountant, insurance agent, and/or investment advisor. Implementation of
financial plan recommendations is entirely at the client's discretion.
Selection and Monitoring of Third-Party Money Managers We also offer advisory management services to our clients through our Selection and
Monitoring of Third-Party Money Managers programs (hereinafter, "Programs"). Based
on the client's individual circumstances and needs we will then perform management
searches of various unaffiliated registered investment advisers to identify which
registered investment adviser's portfolio management style is appropriate for that client.
Factors considered in making this determination include account size, risk tolerance, the
opinion of each client and the investment philosophy of the selected registered
investment adviser. Clients should refer to the selected registered investment adviser's
Firm Brochure, Form ADV Parts 2A, 2B, or other disclosure document for a full
description of the services offered. We are available to meet with clients on a regular
basis, or as determined by the client, to review the account.
Family Limited Partnerships
We provide recordkeeping, accounting, tax preparation and other tax services, and
reporting services to family limited partnerships and other registered investment
advisers.
Consulting Services
Clients can also receive investment advice on a more focused basis. This may include
advice on only an isolated area(s) of concern such as estate planning, retirement
planning, or any other specific topic.
Retirement Plan Services
We provide sub advisory investment advisory services to 401(k) plans through each
plan’s primary advisor. In these instances, we provide investment recommendations to
the primary advisor for various portfolios i.e. income, balanced, growth, etc., made
available to plan participants. We do not provide discretionary or non-discretionary
investment advisory services in these circumstances.
Tailored Relationships We tailor investment advisory services to the individual needs of the client. The goals
and objectives for each client are documented in our client relationship management
system.
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Clients may impose reasonable restrictions, in writing, on investing in certain securities,
types of securities, or industry sectors.
Fiduciary Statement JNB and our employees are fiduciaries who must take into consideration the best
interests of our clients. We will act with competence, dignity, integrity, and in an ethical
manner, when dealing with clients. We will use reasonable care and exercise
independent professional judgement when conducting investment analysis, making
investment recommendations, trading, promoting our services, and engaging in other
professional activities.
As a fiduciary, we have the obligation to deal fairly with our clients. We have the
following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs,
financial circumstances and investment objectives;
• To exercise a high degree of care and diligence to ensure that information
is presented in an accurate manner and not in a way to mislead;
• To have reasonable basis, information, and understanding of the facts in
order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Wrap Fee Programs
We are the investment manager for one wrap-fee program. A “wrap-fee” program is
one that provides the client with advisory and brokerage execution services for an all-
inclusive fee. The client is not charged separate fees for the respective components of
the total service. More information on the wrap fee programs may be found in each
wrap sponsors Form ADV Part 2A Appendix 1, available upon request.
Client Assets As of July 1, 2019, we manage approximately $1,802,565,958 in assets under
management. $1,713,791,336 is managed on a discretionary basis and $88,774,622 is
managed on a non-discretionary basis.
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Compensation We may charge fees on a retainer basis or a percentage of assets under management,
depending on the client agreement. Our fees are described below.
Compensation – Investment Advisory Services Client accounts are charged an investment advisory fee as outlined in the agreement,
up to 1.00% of assets under management.
Fees may be paid quarterly, in either advance or arrears, based upon the market value
of the assets, including cash, on the last day of the relevant quarter as valued by the
custodian. The investment advisory fee for the initial quarter shall be calculated on a
pro rata basis commencing on the day the assets are under contract with us. Upon
termination, any unearned fees paid in advance will be refunded and any unbilled
earned fees will be due and payable.
Compensation – Family Office Services/Family Limited Partnerships
Family Office Services and Family Limited Partnerships are typically charged on a
retainer basis. Some Retainer Agreements may be priced based on the complexity of
work, especially when asset management is not the most significant part of the
relationship. Retainer fees vary with the complexity of the client, but typically start at
$100,000. The fee shall be paid on a prorated basis quarterly, in advance. Clients may
terminate a retainer with 30 days written notice; the Firm may terminate a retainer with 6
months written notice.
Compensation – Consulting Services
Our Consulting Service fees are determined based on the nature of the services being
provided and the complexity of each client's circumstances. All fees are agreed upon
prior to entering into a contract with any client.
Compensation – Retirement Plan Services We receive fees for these services in the amount of a quarterly revenue sharing
calculated by subtracting from gross revenues generated by the retirement plans to
which we serve as subadvisor the expenses incurred servicing those plans multiplied by
0.35%.
General Information on Compensation and Other Fees In certain circumstances, fees, account minimums and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low cost basis securities, or certain passively advised
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investments and pre-existing relationships with clients. Certain clients may pay more or
less than others depending on the amount of assets, type of portfolio, or the time
involved, the degree of responsibility assumed, complexity of the engagement, special
skills needed to solve problems, the application of experience and knowledge of the
client’s situation. Lower fees for comparable services may be available from other
sources.
Our fees are exclusive of brokerage commissions, transaction fees, and other related
costs and expenses which shall be incurred by the client. Clients may incur certain
charges imposed by custodians, brokers, third party investment and other third parties
such as fees charged by managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
taxes on brokerage accounts and securities transactions.
Mutual funds and exchange traded funds also charge management fees, other
expenses and a possible distribution charge, which are disclosed in a fund’s
prospectus. These fees will generally include a management fee, other expenses, and a
possible distribution fee. If the fund also imposes sales charges, a client may pay an
initial or deferred sales charge.
Such charges, fees and commissions are exclusive of and in addition to our fee, and we
shall not receive any portion of these commissions, fees, and costs.
A client could invest in a mutual fund directly, without our services. In that case, the
client would not receive our services which are designed, among other things, to assist
the client in determining which mutual funds are most appropriate to each client’s
financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and the fees charged by us to fully understand the total amount of
fees to be paid by the client and to thereby evaluate the advisory services being
provided.
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Neither JNB nor any of its Supervised Persons (employees) accepts performance-
based fees (fees based on a share of capital gains on or capital appreciation of the
assets of a client).
We do not use a performance-based fee structure because of the potential conflict of
interest. Performance-based compensation may create an incentive for the adviser to
recommend an investment that may carry a higher degree of risk to the client.
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Types of Clients As described in Item 4, we provide advisory services to the following types of clients:
• Individuals
• High net worth individuals
• Pension and profit-sharing plans (other than plan participants)
• Charitable organizations
• Corporations or other businesses not listed above
• State or municipal government entities
Account Minimums We require a minimum of $500,000 of assets under management. This account size
may be negotiable under certain circumstances. We may group certain related client
accounts for the purposes of achieving the minimum account size.
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Loss Methods of Analysis We may employ the following security analysis methods:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by
looking at economic and financial factors (including the overall economy, industry
conditions, and the financial condition and management of the company itself) to
determine if the company is underpriced (indicating it may be a good time to buy) or
overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This
presents a potential risk, as the price of a security can move up or down along with
the overall market regardless of the economic and financial factors considered in
evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis
to the present in an attempt to recognize recurring patterns of investor behavior
and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company.
This presents a risk in that a poorly-managed or financially unsound company may
underperform regardless of market movement.
Quantitative Analysis. We use mathematical models in an attempt to obtain more
accurate measurements of a company's quantifiable data, such as the value of a share
price, or earnings per share, and predict changes to that data.
A risk in using quantitative analysis is that the models used may be based on
assumptions that prove to be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality
of management, labor relations, and strength of research and development factors not
readily subject to measurement and predict changes to share price based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to
identify an appropriate ratio of securities, fixed income, and cash suitable to the client's
investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a
particular security, industry or market sector. Another risk is that the ratio of securities,
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equities, fixed income, and cash will change over time due to stock and market
movements and, if not corrected, will no longer be appropriate for the client's goals.
Mutual Fund and/or ETF Analysis. We look at the experience and track record of the
manager in an attempt to determine if that manager has demonstrated an ability to
invest over a period and in different economic conditions; at the underlying assets in an
attempt to determine if there is significant overlap in the underlying investments held in
another fund(s) in the client's portfolio.
Mutual Fund/ETF Analysis presents the risk that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful
may not be able to replicate that success in the future.
Investment Strategies
The investment strategy for a specific client is based upon the objectives stated by the
client during consultations. The client may change these objectives at any time.
Other strategies may include long-term purchases, short-term purchases, short sales,
margin transactions, and option writing (including covered options, uncovered options or
spreading strategies).
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear. All
investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following
investment risks:
• Interest-rate Risk: Fluctuations in interest rates may cause investment
prices to fluctuate. For example, when interest rates rise, yields on
existing bonds become less attractive, causing their market values to
decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of risk
is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social
conditions may trigger market events.
• Inflation Risk: When any type of inflation is present, a dollar today will
not buy as much as a dollar next year, because purchasing power is
eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the
value of the dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk.
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• Reinvestment Risk: This is the risk that future proceeds from
investments may have to be reinvested at a potentially lower rate of return
(i.e. interest rate). This primarily relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a
particular company within an industry. For example, oil-drilling companies
depend on finding oil and then refining it, a lengthy process, before they
can generate a profit. They carry a higher risk of profitability than an
electric company, which generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is
like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into
cash. Generally, assets are more liquid if many traders are interested in a
standardized product. For example, Treasury Bills are highly liquid, while
real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of financial
stress, the inability to meet loan obligations may result in bankruptcy
and/or a declining market value.
Other Types of Investments Our clients may invest in hedge funds and private equity/venture capital partnerships.
We do not create, sponsor, or, sell for others any such investments. We do, however,
review offering materials for our clients to assess suitability within the client’s investment
program.
We reserve the right to advise clients on any other type of investment that it deems
appropriate based on the client’s stated goals and objectives. We may also provide
advice on any type of investment held in a client’s portfolio at the inception of the
advisory relationship or on any investment on which the client requests advice.
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Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of JNB or the
integrity of our management.
We have no information to disclose applicable to this Item.
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Financial Industry Activities – Broker-Dealers We are not registered as a broker-dealer, and none of our management persons are
registered representatives of a broker-dealer.
Financial Industry Activities – Futures and Commodities Neither JNB nor any of its management persons is registered as (or associated with) a
futures commissions merchant, commodity pool operator, or a commodity trading
advisor.
Affiliations – Accountant or Accounting Firm Several of our employees are Certified Public Accountants. These individuals do not
practice traditional accounting outside of their role at our Firm.
Affiliations – Attorney Daniel J. Rutnik and Daniel P. Nolan maintain their licenses as attorneys but do not
practice in any capacity outside of the Firm.
Other Investment Advisors We select other investment advisors for our clients. We do not receive any
compensation for the selection of other managers.
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Transactions and Personal Trading Code of Ethics Our employees must comply with a Code of Ethics and Statement for Insider Trading.
The Code describes the Firms’ high standard of business conduct, and fiduciary duty to
its clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
Joseph N. Vet, Jr., Senior Account Manager and Chief Compliance Officer, reviews all
employee trades each quarter. His trades are reviewed by Daniel J. Rutnik, President.
These reviews ensure that personal trading does not affect the markets, and that our
clients receive preferential treatment. Since most employee trades are small mutual
fund trades, exchange-traded fund trades, or broadly traded stocks, the trades do not
affect the securities markets. The Firm maintains a list of restricted securities that
employees may not purchase or sell based upon having (or possibly having) access to
inside information.
Our employees must acknowledge the terms of the Code of Ethics at least annually.
Any individual not in compliance with the Code of Ethics may be subject to termination.
Clients and prospective clients can obtain a copy of our Code of Ethics by contacting
Joseph N. Vet, Jr. at 518.218.1218.
Participation or Interest in Client Transactions – Personal Securities Transactions
Our Firm and our employees may buy or sell securities identical to those recommended
to clients for their personal accounts. The Code of Ethics, described above, is designed
to assure that the personal securities transactions, activities and interests of our
employees will not interfere with (i) making decisions in the best interest of advisory
clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts. Under the Code certain classes of
securities, primarily mutual funds, have been designated as exempt transactions, based
upon a determination that these would materially not interfere with the best interest of
our clients. In addition, the Code requires pre-clearance of many transactions.
Nonetheless, because the Code of Ethics in some circumstances would permit
employees to invest in the same securities as clients, there is a possibility that
employees might benefit from market activity by a client in a security held by an
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employee. Employee trading is continually monitored under the Code of Ethics and
designed to reasonably prevent conflicts of interest between us and our clients.
Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross Our Firm and our employees do not recommend to clients, or buy or sell for client
accounts, securities in which they have a material financial interest.
It is our policy not to affect any principal or agency cross securities transactions for
client accounts. We will also not cross trades between client accounts.
Trade Aggregation
We may aggregate our employee trades with client transactions where possible and
when compliant with our duty to seek best execution for our clients. In these instances,
participating clients will receive an average share price and transaction costs will be
shared equally and on a pro-rata basis. In the instances where there is a partial fill of a
particular batched order, we will allocate all purchases pro- rata, with each account
paying the average price. Our employee accounts may be included in the pro- rata
allocation.
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Research and Other Soft Dollar Benefits We do not receive formal soft dollar benefits other than execution from broker/dealers in
connection with client securities transactions. See disclosure below in “Directed
Brokerage – Other Economic Benefits”.
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Directed Brokerage
Clients are encouraged to select their own brokers based on experience or personal
knowledge. We will work with any broker chosen by a client. In instances where the
client does not have such experience or knowledge, we will recommend brokers based
on factors of low cost, high service level and depth of experience necessary to meet the
particular needs of the client. We receive no compensation or other consideration for its
referrals.
We shall generally recommend that portfolio management clients establish brokerage
accounts with Charles Schwab & Co., Inc. (Schwab), Fidelity Investments (Fidelity), all
registered broker-dealers, members SIPC, to maintain custody of clients' assets and to
effect trades for their accounts.
Directed Brokerage – Other Economic Benefits
We may receive from Schwab, and/ or Fidelity, without cost to us, computer software
and related systems support, which allow us to better monitor client accounts
maintained at Schwab and/or Fidelity; facilitate trade execution (and allocation of
aggregated trade orders for multiple client accounts); provide research, pricing
information and other market data; and assist with back-office functions, recordkeeping
and client reporting. We may receive the software and related support without cost
because we render investment management services to clients that maintain assets at
Schwab or Fidelity. In addition, Schwab and/or Fidelity may make available, arrange, or
pay for services rendered to us by independent third parties, including services intended
to assist with back office functions such as recordkeeping and client reporting. Schwab
and/or Fidelity may discount or waive fees it would otherwise charge for some of these
services or pay all or a part of the fees of a third party providing these services to us.
We may receive the following benefits from Schwab and/or Fidelity: receipt of duplicate
client confirmations and bundled duplicate statements; access to a trading desk that
services our clients; access to block trading which provides the ability to aggregate
securities transactions and then allocate the appropriate shares to client accounts; and
access to an electronic communication network for client order entry and account
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information. In addition, Schwab and/or Fidelity also makes available to us other
services intended to help us manage and further develop its business enterprise. These
services may include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance, and
marketing.
We are independently owned and operated and not affiliated with Schwab and/or
Fidelity. Schwab and/or Fidelity provides us with access to its institutional trading and
custody services, which are typically not available to Schwab or Fidelity retail investors.
These services generally are available to independent investment advisors on an
unsolicited basis and are not otherwise contingent upon JNB committing to
Schwab or Fidelity any specific amount of business (assets in custody or trading).
For our client accounts maintained there, Schwab and/or Fidelity is compensated
through commissions or other transaction-related fees for securities trades that are
executed through Schwab or Fidelity, or that settle into Schwab or Fidelity accounts.
The brokerage commissions and/or transaction fees charged by Schwab or Fidelity
or
any other designated broker-dealer are exclusive of and in addition to our fees.
The commissions paid by our clients shall comply with our duty to obtain “best
execution.” However, a client may pay a commission that is higher than another
qualified broker-dealer might charge to affect the same transaction where we determine,
in good faith, that the commission is reasonable in relation to the value of the brokerage
and research services received. In seeking best execution, the determinative factor is
not the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of a broker-dealer’s services,
including among others, the value of research provided, execution capability,
commission rates, and responsiveness. Consistent with the foregoing, while we will
seek competitive rates, we may not necessarily obtain the lowest possible commission
rates for client transactions.
Trade Aggregation
Trade aggregation is the act of trading a large block of a security in a single order.
Shares of a purchased security are then allocated to the appropriate accounts in the
appropriate proportion. The main purposes of order aggregation are (i) for ease of
trading and (ii) to obtain a lower transaction cost associated with trading a larger
quantity.
At our discretion aggregate purchases or sales of the same security, instrument or
obligation may be transacted on the same day for multiple accounts of one or more of
our clients. Although such aggregations potentially could be either advantageous or
disadvantageous to any one or more accounts, they will be affected only when we
believe that to do so will be in the best interest of the affected accounts. When
transactions are so aggregated the actual prices applicable to the aggregation
transaction will be deemed to have purchased or sold its share of the security,
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instrument or obligation at the average price. If a partial execution is attained at the end
of the trading day, we will generally allocate shares on a pro rata basis but may fill small
orders entirely before applying the pro rata allocation.
Accounts for our employees may be included in a block trade with client accounts.
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Reviews Daniel J. Rutnik and Daniel Nolan, Co-Presidents; Daniel Curran, Financial Advisor;
Christopher M. Denisulk, Senior Account Manager; Robert Hennes, Managing Director;
Hugh Johnson, Chairman; Dianne McKnight, Vice President; Susan Reese, Senior Vice
President; Roberta Rocas, Managing Director; Kim Saba, Fixed Income Portfolio
Manager; Charles Brown, Vice President; and Joseph N. Vet, Jr., Senior Account
Manager and Chief Compliance Officer, review client accounts. Once a client
determines an allocation of assets and chooses investment vehicles, we review these
investment vehicles and aggregate portfolios periodically to determine adherence to the
agreed upon allocation, performance, and volatility. If any of these three factors is in
variance with expectations, discussions will be held with the client to determine if
substitutions should be made.
Review Triggers
Other conditions that may trigger a review are changes in market, political or economic
conditions, tax laws, new investment information, and changes in a client's own
situation.
Reporting
Clients will receive periodic statements (typically monthly) from their brokers or other
investment providers documenting account value, individual positions (where relevant)
and account activity for their underlying investment accounts. We may provide clients
with supplemental reports, as appropriate, depending upon the nature of the services
provided.
Financial Planning – Reviews and Reporting Financial Planning clients will be reviewed as contracted for at the inception of the
engagement and receive reports as contracted for at the inception of the engagement.
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Other Compensation We do not receive any formal economic benefits (other than normal compensation and
benefits described in Item 12) from any firm or individual for providing investment
advice.
Other Compensation – Brokerage Arrangements
See disclosure in Item 12 regarding compensation, including economic benefits
received in connection with giving advice to clients.
Compensation – Client Referrals – Solicitation Arrangements
From time to time, we enter into written arrangements to pay referral fees to individuals
or companies (solicitors) who refer prospective clients to the Firm. In each instance,
there will be a written agreement between our Firm and the solicitor, which will clearly
define the duties and responsibilities of the solicitor under this arrangement. In addition,
the client will be provided with a written disclosure document (Solicitors Disclosure
Document), which explains to the prospective client the terms and compensation
structure under which the solicitor is working with our Firm. We will ensure that our
Form ADV Part 2 is delivered to the prospective client and will obtain a written
acknowledgement from the client that both the Solicitor's Disclosure Document and our
Form ADV Part 2 have been received. Our fee will remain the same regardless of
whether a solicitation fee is paid.
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Custody – Fee Debiting Clients may authorize us (in the client agreement) to debit fees directly from the client’s
account at the broker dealer, bank or other qualified custodian (custodian). Client
investment assets will be held with a custodian agreed upon by the client and JNB. The
custodian is advised in writing of the limitation of our access to the account. The
custodian sends a statement to the client, at least quarterly, indicating all amounts
disbursed from the account including the amount of advisory fees paid directly to us.
Custody – Check Writing
Certain JNB employees have check writing authority over client accounts. This form of
custody is offered on a limited basis. We comply with the SEC’s Custody Rule with
regard to the check signing authority; annually the Firm is subject to a Surprise
Examination by an independent accountant.
Custody – Trusteeship/Executor
Certain JNB employees act as trustee for client trusts. This form of custody is offered
on a limited basis. We comply with the SEC’s Custody Rule with regard to the custody
of the trust assets; annually the Firm is subject to a Surprise Examination by an
independent accountant.
Custody – First Party Money Transfers
Clients may provide us with written ongoing authorization to transfer money between
the client’s accounts held with the qualified custodian directly to an outside financial
institution (i.e. a client’s bank account). A copy of this authorization is provided to the
qualified custodian. The authorization includes the client’s name and account number(s)
at the outside financial institution(s) as required.
Custody – Account Statements As described above and in Item 13, clients receive at least quarterly statements from
the broker dealer, bank or other qualified custodian that holds and maintains client’s
investment assets. Clients are urged to carefully review such statements and compare
such official custodial records to the account statements or other reports that we
provide. Our statements may vary from custodial statements based on accounting
procedures, reporting dates, or valuation methodologies of certain securities.
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We may accept limited power of attorney to act on a discretionary basis on behalf of
clients. A limited power of attorney allows us to execute trades on behalf of clients.
When such limited powers exist, we have the authority to determine, without obtaining
specific client consent, both the amount and type of securities to be bought to satisfy
client account objectives.
If we have not been given discretionary authority, we consult with the client prior to each
trade.
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We do not have any authority to and do not vote proxies on behalf of clients; clients
retain the responsibility for receiving and voting proxies. Clients receive these proxies
directly from custodians or transfer agents.
If requested, we may provide advice to clients regarding proxy votes. Any conflict of
interest exists will be disclosed to the client. Clients may contact Joseph N. Vet, Jr. at
518.218.1218 for more information about proxy voting.
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We have no financial commitment that impairs our ability to meet contractual and
fiduciary commitments to clients and have not been the subject of a bankruptcy
proceeding.
We are not required to provide a balance sheet; we do not require prepayment of fees
of more than $1,200 per client, and six months or more in advance.
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Open Brochure from SEC website