A. Description of the Advisory Firm This firm has been in business since August 10, 2010, and the principal owner is Dennis William Voigt. B. Types of Advisory Services Bascomb Madison & James Capital Management (hereinafter “BMJCM”) offers the following services to advisory clients: Portfolio Management Services BMJCM offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. BMJCM creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Advisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring BMJCM evaluates the current and future investments of each client with respect to their risk tolerance levels and time horizon. BMJCM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is provided to each client. Management of Existing Investments For some clients we will agree to manage their existing investment managers. Specifically, we will:
• Assist the clients in preparing an investment policy statement;
• Balance and allocate the investment categories of the investment policy statement among the investment advisors;
• Monitor the investment advisors' performance and compare it against benchmarks for each investment category (at least quarterly and many cases monthly);
• Periodically review the performance analysis with the client (at least semi- annually and more frequently as appropriate);
• Flag substandard performance for review with the client and the advisor (at least annually and more frequently as appropriate);
• Rebalance the overall portfolio among the investment advisors periodically (at least annually and more frequently as appropriate) to meet the objectives of the investment policy statement; and
• Review the investment policy statement and investment categories periodically (at least annually) in light of changing economic conditions. The custodian of the funds will be the custodian selected by the existing investment advisor and new investment advisors as they are added to the mix. High Net-Worth Clients with Multiple Investment Managers BMJCM will offer the following services to these clients:
• Help clients develop an overall Investment Policy Statement
• Help clients select their investment managers
• Monitor and

manage the investment managers, including making recommendations for rebalancing asset allocations between and within investment manager portfolios. All funds are held by the custodians of the other investment managers. BMJCM does not have discretion to trade any securities without the authorization of the clients. The overall asset allocation is defined by the overall Investment Policy Statement developed by BMJCM and the client. Any change in asset allocation for any individual investment manager is governed by the overall Investment Policy Statement. BMJCM may be granted authority to trade a specific security in individual client accounts based on a written trade authorization. In the case of an individual written trade authorization, BMJCM may be granted discretion as to the timing of the entry, the size of the entry (up to some limit) and the timing of the exit. Selection of Other Advisors BMJCM may direct clients to third party money managers. BMJCM may be compensated via a fee share from the advisors to which it directs those clients. This relationship will be disclosed in each contract between BMJCM and each third-party advisor. The fees shared will not exceed any limit imposed by any regulatory agency. Before selecting other advisors for clients, BMJCM will always ensure those other advisors are properly licensed or registered as investment advisor. Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Services Limited to Specific Types of Investments BMJCM limits its money management to mutual funds, options, equities, bonds, fixed income, debt securities, ETFs, third party money managers, REITs, real estate, private equity, and government securities. BMJCM may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions BMJCM offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs BMJCM does not participate in any wrap fee programs. E. Amounts Under Management BMJCM has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 106,043,423 $ 0.00 December 2023