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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Item 1: Cover Page
Ite1Itmver Pag e
SEC File No. 801-107239
Form ADV Part 2A: Firm Brochure
1 Columbus Center
283 Constitution Drive
Suite 100
Virginia Beach, VA 23462
757-351-0741
www.comptonwealth.com
March 26, 2025
This brochure provides information about the qualifications and business practices of Compton
Wealth Advisory Group, LLC (“Compton Wealth”). If you have any questions about the contents
of this brochure, please email Nancy Renshaw, our CCO, at nancy@comptonwealth.com. The
information in this brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
Compton Wealth is a registered investment advisor. References to registration as an investment
adviser does not imply a certain level of skill or training. The oral and written communications of
an advisor provide you with information to help you determine if you should hire or retain an
advisor. Additional information about Compton Wealth is available via the SEC’s website
www.adviserinfo.sec.gov. The SEC’s website also provides information about any persons
affiliated with Compton Wealth who are registered, or are required to be registered, as investment
advisor representatives of Compton Wealth. Throughout this brochure the words “Compton
Wealth”, “we”, “us” and “our” refer to Compton Wealth.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Item 2: Material Changes
Since Compton Wealth’s last Form ADV Annual Amendment filing on March 21, 2024, this
Disclosure Brochure has been materially amended to reflect changes in our advisory fees and fee
schedules, effective April 1, 2025, as outlined in Item 5.
While not material, we have revised our disclosure Item 17 to indicate our use of a third party to
support the handling of class action lawsuits.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Item 3: Table of Contents
Item 1: Cover Page ............................................................................................................................ 1
Item 2: Material Changes .................................................................................................................. 2
Item 3: Table of Contents ................................................................................................................. 3
Item 4: Advisory Business ................................................................................................................ 4
Item 5: Fees and Compensation ...................................................................................................... 13
Item 6: Performance Based Fees and Side-by-Side Management .................................................. 16
Item 7: Types of Clients .................................................................................................................. 16
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 16
Item 9: Disciplinary Information .................................................................................................... 21
Item 10: Other Financial Industry Activities and Affiliations ........................................................ 21
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 22
Item 12: Brokerage Practices .......................................................................................................... 23
Item 13: Review of Accounts ......................................................................................................... 26
Item 14: Client Referrals and Other Compensation ........................................................................ 27
Item 15: Custody ............................................................................................................................. 27
Item 16: Investment Discretion ....................................................................................................... 28
Item 17: Voting Client Securities ................................................................................................... 28
Item 18: Financial Information ....................................................................................................... 28
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Item 4: Advisory Business
Compton Wealth Advisory Group, LLC was founded in 2009 in the Commonwealth of Virginia
and operates as a limited liability company wholly owned by Mark Compton, its managing member.
In April 2016, the firm became registered as an Investment Adviser providing investment
management services to individual clients and businesses. As of December 31, 2024, we managed
$720 million in assets. All managed accounts are held with independent qualified custodians.
INVESTMENT MANAGEMENT SERVICES
At Compton Wealth we have a fiduciary duty to provide services consistent with the client’s best
interest. As part of our investment advisory services, we will review your portfolio(s) on an ongoing
basis to determine if any changes are necessary based upon various factors, including, but not
limited to investment performance, market conditions, fund manager tenure, style, drift, account
additions/withdrawals, and/or a change in your investment objective. Based on these factors, there
may be times when we determine that changes to your portfolio are neither necessary, nor prudent.
You remain subject to the fees described in Item 5 during periods of account inactivity. Of course,
there can be no assurance that investment decisions made by us will be profitable or equal any
specific performance level(s).
Our investment advisory and management services are provided on a discretionary or non-
discretionary basis as determined by you and are primarily managed by us, or when recommended,
by a third-party investment manager to oversee the fixed income portion of your account(s). When
you engage us to provide discretionary services, this allows us to buy and sell securities whenever
we believe changes are appropriate. Such securities include but are not limited to stocks, bonds,
exchange traded funds, mutual funds, cash equivalents and illiquid alternative investments (i.e.,
real estate, private equity, etc.). Account supervision is guided by your stated investment objective
(i.e., balanced, growth with income, moderate growth, etc.) You can impose restrictions on
investing in specific securities or types of securities by notifying us in writing. When you engage
us to provide non-discretionary services, you must be willing to accept that we cannot affect any
account transactions without obtaining prior consent from you. Thus, in the event we would like to
make a transaction for your account (including an event of an individual holding or general market
correction), and if you are unavailable, we will be unable to affect transactions as we would for our
discretionary clients without first obtaining your consent.
Before engaging us to provide our services, clients are required to enter into an Investment Advisory
Agreement with us setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the fee that is due from the
client. We begin by helping clients identify their particular risk tolerances and investment
objectives and then help select suitable investments or investment managers to help meet those risk
tolerances and objectives. Your investment objective is identified by determining your risk
tolerance based upon your age, income, experience, need for cash flows, investment goals,
emotional tolerance for volatility, tax situation, time horizon, legal considerations, and any other
unique circumstances. The information provided by you is collected during client meetings and
interviews. After reviewing your financial situation and defining investment guidelines, we
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
implement an investment strategy through a combination of investments. We provide ongoing
investment advisory and management services that are tailored to your needs. Once allocated, we
provide ongoing monitoring and review of account performance, asset allocation and client
investment objectives, and may rebalance and/or may recommend that clients rebalance accounts
as necessary based on such reviews. Account supervision is guided by your stated objectives and
any restrictions imposed by you. Capital market conditions and client circumstances are monitored,
and adjustments are made or recommended as needed to reflect significant changes in any or all the
above variables. Investment manager selection includes an initial third-party investment manager
due diligence, performance reporting and account monitoring, ongoing manager due diligence, and
continuous client consultation.
FINANCIAL PLANNING AND CONSULTING SERVICE (STAND-ALONE)
To the extent specifically requested by a client, we shall provide financial planning and/or
consulting services (including investment and non-investment related matters, including estate
planning, insurance planning, etc.) inclusive of our investment management engagement. We may
also provide upon client request financial planning services for clients who maintain less than
$1,000,000 in assets under management with us pursuant to a separate financial planning
agreement. We provide a wide array of general personal financial planning services in addition to
investments. Such services include some or all the following: Retirement, Educational, and
Insurance Planning. Our fees may vary depending upon the level and scope of the service(s)
required and the professional(s) rendering the service(s). Before engaging us to provide planning
or consulting services, clients are required to enter into a Financial Planning Agreement with us,
setting forth the terms and conditions of the engagement (including termination), describing the
scope of the services to be provided, and the hourly or annual fee to be charged before we
commence services. If requested by the client, we may recommend the services of other
professionals for implementation purposes, including our representatives in their individual
capacities as licensed insurance agents. You are under no obligation to engage the services of any
such recommended professional. You retain absolute discretion over all such implementation
decisions and are free to accept or reject any recommendation from us. At all times, the engaged
licensed professional[s] (i.e., attorney, accountant, etc.), and not Compton Wealth, shall be
responsible for the quality and competency of their services provided.
Please note we believe that it is important for the client to address financial planning issues on an
ongoing basis. Compton Wealth’s advisory fee, as set forth within Item 5, will remain the same
regardless of whether the client determines to address financial planning issues with Compton
Wealth.
EMPLOYER SPONSORED RETIREMENT PLAN CONSULTING SERVICES
We provide employer sponsored retirement plan consulting services, in the capacity of an ERISA
3(21) advisor, pursuant to which we assist sponsors of self-directed retirement plans with the
selection and/or monitoring of investment alternatives (generally open-end mutual funds) from
which plan participants shall choose in self-directing the investments for their individual plan
retirement accounts (which may include investment strategies devised and managed by Compton
Wealth). In addition, to the extent requested by the plan sponsor, we may also provide participant
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
education designed to assist participants in identifying the appropriate investment strategy for their
retirement plan accounts and participate in plan investment policy reviews.
FAMILY OFFICE SERVICES
We also offer Family Office services to ultra-high net worth clients separate from our investment
advisory services. We provide non-investment related strategic consulting and administrative
services which are agreed upon and outlined in your family office agreement. Clients are not under
any obligation to access these services.
MISCELLANEOUS
Retirement Plan Rollovers – No Obligation / Conflict of Interest. A client or prospective client
leaving an employer typically has four options regarding an existing retirement plan (and may
engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are
permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account
value (which could, depending upon the client’s age, result in adverse tax consequences). If we
recommend that you roll over your retirement plan assets into an account to be managed by us, such
a recommendation creates a conflict of interest if we earn a new (or increase its current) advisory
fee on the rolled over assets. If we provide a recommendation as to whether a client should engage
in a rollover or not (whether it is from an employer’s plan or an existing IRA), we are acting as a
fiduciary 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. No client is
under any obligation to roll over retirement plan assets to an account managed by Compton
Wealth, whether it is from an employer’s plan or an existing IRA.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services.
To the extent requested by a client, we may provide financial planning and related consulting services
regarding non-investment-related matters, such as education planning, estate planning, tax and
retirement planning, insurance planning, etc. as part of our investment management services. We
may also provide, upon client request, financial planning services pursuant to a separate financial
planning agreement. Compton Wealth does not serve as an attorney or accountant, and no portion of
its services should be construed as legal or accounting services. Accordingly, Compton Wealth does
not prepare estate planning documents or tax returns. To the extent requested by a client, we may
recommend the services of other professionals for certain non-investment implementation purposes
(i.e., attorneys, accountants, insurance agents, etc.), including certain of Compton Wealth’s related
persons in their separate individual capacities as licensed insurance agents. The client is under no
obligation to engage the services of any such recommended professional. The client retains absolute
discretion over all such implementation decisions and is free to accept or reject any recommendation
from Compton Wealth and/or its representatives. If the client engages any recommended unaffiliated
professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek
recourse exclusively from and against the engaged professional. Neither Compton Wealth, nor its
investment adviser representatives, assist clients with the implementation of any financial plan,
unless they have agreed to do so in writing. Also, Compton Wealth does not monitor a client’s
financial plan, and it is the client’s responsibility to revisit the financial plan with Compton Wealth,
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
if desired. At all times, the engaged licensed professional(s) (i.e. attorney, accountant, insurance
agent, etc.), and not Compton Wealth, shall be responsible for the quality and competency of the
services provided. If the client engages any unaffiliated professional, and a dispute arises thereafter
relative to such engagement, the engaged professional (and not Compton Wealth) shall remain
exclusively responsible for resolving any such dispute with the client.
Conflict of Interest: The recommendation by Compton Wealth’s representative that a client
purchase an insurance commission product through Compton Wealth presents a conflict of interest,
as the receipt of commissions may provide an incentive to recommend insurance products based on
commissions to be received, rather than on a particular client’s need. No client is under any
obligation to purchase any insurance commission products through Compton Wealth. Clients are
reminded that they may purchase insurance products recommended by Compton Wealth through
other non-affiliated insurance agencies.
Use of Mutual and Exchange Traded Funds. Most mutual funds and exchange traded funds are
available directly to the public. Thus, a prospective client can obtain many of the funds that may be
utilized by Compton Wealth independent of engaging us as an investment advisor. However, if a
prospective client determines to do so, he/she will not receive Compton Wealth’s initial and
ongoing investment advisory services.
In addition to Compton Wealth’s investment advisory fee described in Item 5, and transaction
and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g. management fees and other
fund expenses).
Custodian Charges-Additional Fees: As discussed below in Item 12, when requested to
recommend a broker-dealer/custodian for client accounts, we generally recommend that Charles
Schwab & Co, Inc. (“Schwab”) serve as the broker-dealer/custodian for client investment
management assets. Broker-dealers such as Schwab charge transaction fees for effecting certain
securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups,
dealer spreads and mark-downs charged for fixed income transactions, etc.). The types of securities
for which transaction fees, commissions, and/or other type fees (as well as the amount of those
fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including
Schwab, do not currently charge fees on individual equity transactions or ETFs, others do). Please
Note: There can be no assurance that Schwab will not change its transaction fee pricing in the
future. Please Also Note: Schwab may also assess fees to clients who elect to receive trade
confirmations and account statements by regular mail rather than electronically. In addition to
Compton Wealth’s investment advisory fee referenced in Item 5, the client will also incur: (a)
transaction fees to purchase certain securities for the client’s account (i.e., mutual funds and fixed
income securities purchased by Compton Wealth and/or Independent Managers.) Compton Wealth
does not receive any portion of the fees or commissions charged by the custodian.
Unaffiliated Alternative Investments. For certain qualified clients who want exposure to asset
classes beyond equity and fixed income we may recommend unaffiliated alternative investments at
your request. Alternative investments provide exposure to markets and investment strategies that
cannot be accessed through other more traditional asset classes or mutual funds. Alternative
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
investments, typically illiquid, may be used with traditional fixed income and equity strategies to
potentially enhance overall portfolio performance with lower volatility. Our alternative investment
role is based on thoroughly evaluating the investment and its managers. Among the factors we
consider in selecting alternatives include terms, conditions, conflicts, performance, the use of
leverage, understanding sources of risk, and cost set forth in the alternative’s offering documents.
In addition to attractive risk-adjusted return potential, alternatives provide diversification through
lower correlated asset classes to reduce the volatility of your overall portfolio. If you choose to
invest in an unaffiliated alternative investment recommended by us, the amount of assets invested
in the alternative shall be included as part of your “assets under management” for purposes of
calculating your investment advisory fee. Investing in alternative investments is speculative and
not suitable for all investors. You are under absolutely no obligation to consider or invest in any
alternative investment. Alternatives are meant for experienced and sophisticated investors who are
willing to bear the risks of the investment, which can include but are not limited to:
• Lack of liquidity in that there may be no secondary market
• Loss of all or a substantial portion of the investment due to leveraging and/or short selling
• Restrictions on transferring interests in the investment
• Absence of information regarding valuations and pricing
• Delays in tax reporting
• Less regulation and higher fees
One form of alternative investment used by the firm is a real estate investment trust “REIT”.
Subscribing to/investing in a REIT may entail certain risks:
Investing in REITs involves certain distinct risks in addition to those risks associated with investing
in the real estate industry in general. Equity REITs may be affected by changes in the value of the
underlying property owned by the REITs, while mortgage REITs may be affected by the quality of
credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest
rates rise, the value of the REIT may decline).
Please Note: A complete discussion of the above-mentioned risks is set forth in each alternative
investment’s offering documents, which will be provided to each client for review and
consideration. Unlike liquid investments that a client may own, alternative investments do not
provide daily liquidity or pricing. Each prospective client investor will be required to complete the
alternative investment’s Subscription Agreement, pursuant to which the client shall establish that
he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors
that are associated with such an investment.
Unaffiliated Private Investment Funds. We may also provide investment advice regarding
unaffiliated private investment funds at your request. On a non-discretionary basis, we may
recommend that certain qualified clients consider an investment in private investment funds, the
description of which (the terms, conditions, risks, conflicts and fees, including incentive
compensation) is set forth in the fund’s offering documents. Our role relative to unaffiliated private
investment funds shall be limited to its initial due diligence and investment monitoring services. If
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
a client determines to become an unaffiliated private fund investor, the amount of assets invested
in the fund(s) shall be included as part of “assets under management” for purposes of Compton
Wealth calculating its investment advisory fee. Compton Wealth’s fee shall be in addition to the
fund’s fees. You are under absolutely no obligation to consider or make an investment in any private
investment fund(s).
Please Note: Private investment funds generally involve various risk factors, including, but not
limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a
complete discussion of which is set forth in each fund’s offering documents, which will be provided
to each client for review and consideration. Unlike liquid investments that a client may own, private
investment funds do not provide daily liquidity or pricing. Each prospective client investor will be
required to complete the private fund’s Subscription Agreement, pursuant to which the client
establishes that he/she is qualified for investment in the fund and acknowledges and accepts the
various risk factors that are associated with such an investment.
Valuation. In the event that we reference private investment funds or alternative investments
owned by you on any supplemental account reports prepared by us, the value(s) for all alternatives
owned by you shall reflect the most recent valuation provided by the fund sponsor. However, if
after purchase, an updated valuation has not been provided, the valuation shall reflect the initial
purchase price. If after purchase, an updated valuation is provided, then the statement will reflect
that updated value. The updated value will continue to be reflected in the report until the alternative
investment provides a further updated value. As a result of the valuation process, if the valuation
reflects the initial purchase price or an updated value after purchase price, the current value(s) of
an investor’s holding(s) could be significantly more or less than the value reflected on the report.
Unless otherwise indicated, we shall calculate its fee based upon the latest value provided by the
fund sponsor.
Independent Managers. We may recommend that you allocate a portion of your investment assets
among unaffiliated independent investment managers (“Independent Manager(s)”) in accordance
with your designated investment objective(s). In such situations, the Independent Manager(s) will
have day-to-day responsibility for the active discretionary management of the allocated assets. We
will continue to render investment supervisory services to you relative to the ongoing monitoring
and review of account performance, asset allocation, and your investment objectives. We generally
consider the following factors when recommending Independent Manager(s): the client’s
designated investment objective(s), management style, performance, reputation, financial strength,
reporting, pricing, and research. The investment management fees charged by the designated
Independent Manager(s) are exclusive of, and in addition to, our ongoing investment advisory fee,
subject to the terms and conditions of a separate agreement between the client and the Independent
Manager(s). Our advisory fee is set forth in the fee schedule under Item 5. Compton Wealth’s Chief
Compliance Officer remains available to address any questions that a client or prospective client
may have regarding the allocation of account assets to an Independent Manager(s), including the
specific additional fee to be charged by such Independent Manager.
Asset-Based Pricing Arrangements and Limitations. Relative to Independent Manager
engagements, we generally recommend clients enter an “Asset-Based” pricing agreement with the
account broker-dealer/custodian. Under an asset-based pricing arrangement, the amount that a
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
client will pay the custodian for account commission/transaction fees is based upon a percentage
(%) of the market value of the account, generally expressed in basis points and/or a percentage.
One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or 0.01% (0.0001).
This differs from transaction-based pricing, which assesses a separate commission/transaction fee
against the account for each account transaction. Account investment decisions are driven by
security selection and anticipated market conditions and not the amount of transaction fees payable
by you to the account custodian. Under either the asset-based or transaction-based pricing scenario,
the fees charged by the respective broker-dealer/custodian are separate from, and in addition to, the
advisory fee payable by you to us per Item 5. We do not receive any portion of the asset-based
transaction fees payable by you to the account custodian. You are under no obligation to enter into
an asset-based arrangement, and, if you do, you can request at any time to switch from asset-based
pricing to transactions-based pricing, However, there can be no assurance that the volume of
transactions will be consistent from year-to-year given changes in market events and security
selection. Thus, given the variances in trading volume, any decision by you to switch to transaction-
based pricing could prove to be economically disadvantageous.
Portfolio Activity. We have a fiduciary duty to provide services consistent with the client’s best
interest. We will review client portfolios on an ongoing basis to determine if any changes are
necessary based upon various factors, including, but not limited to, investment performance, market
conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the
client’s investment objective. Based upon these factors, there may be extended periods of time
when we determine that changes to a client’s portfolio are unnecessary. Clients remain subject to
the fees described in Item 5 during periods of portfolio inactivity. Of course, as indicated below,
there can be no assurance that investment decisions made by us will be profitable or equal any
specific performance level(s).
eMoney Advisor Platform. We may provide you with access to an online platform hosted by
“eMoney Advisor” (“eMoney”). The eMoney platform allows you to view your complete asset
allocation, including those assets that we do not manage (the “Excluded Assets”). We do not
provide investment management, monitoring, or implementation services for the Excluded Assets.
Unless otherwise specifically agreed to in writing, our service, relative to the Excluded Assets, is
limited to reporting only. Therefore, we shall not be responsible for the investment performance of
the Excluded Assets. Rather, you and/or your advisor(s) that maintain management authority for
the Excluded Assets, and not Compton Wealth, shall be exclusively responsible for such investment
performance. Without limiting the above, we shall not be responsible for any implementation error
(timing, trading, etc.) related to the Excluded Assets. You may choose to engage us to manage some
or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory
Agreement between us and you, the client. The eMoney platform also provides access to other types
of information and applications including financial planning concepts and functionality, which
should not, in any manner whatsoever, be construed as services, advice, or recommendations
provided by Compton Wealth. Finally, we shall not be held responsible for any adverse results you
may experience if you engage in financial planning or other functions available on the eMoney
platform without our assistance or oversight.
Variable Annuities. If you own a variable annuity product, you can engage us to provide
investment management services related to the investment subdivisions that comprise the variable
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
annuity product. Our investment selection shall be limited to those investments provided by the
variable annuity sponsor. If so engaged, we shall charge an ongoing advisory fee based upon the
market value of the assets per its fee schedule in Item 5. Please Note: Neither Compton Wealth,
nor any of its employees, offers to sell variable annuity products to its clients. Neither Compton
Wealth, nor any of its employees, are registered as, or associated with, a broker-dealer or an
insurance agency. If you seek to purchase or exchange a variable annuity product, we shall refer
you to an unaffiliated broker-dealer/insurance agency to advise on same, and if agreed upon by you,
engage the unaffiliated broker-dealer/insurance agency to purchase a new or exchange an existing
variable annuity product. Neither Compton Wealth, nor any of its employees, shall receive any
portion of the fees earned by the unaffiliated broker-dealer/insurance agency. Our only
compensation shall be limited to the management of the investment subdivisions that comprise the
variable annuity product, should you engage us to do so. You are under no obligation to engage us
to provide such management services, nor are you under any obligation to consider addressing
variable annuity issues with the unaffiliated broker-dealer/insurance agency that may be
recommended by us. Please Also Note: Because we could earn an advisory fee on the variable
annuity assets, a potential conflict of interest arises if we recommend you engage us to provide
investment management services on your variable annuity. Please Further Note: Variable
annuities are long-term investment products. Variable annuity product sponsors generally impose
financial penalties for early withdrawals as set forth in the variable annuity documents. Thus, the
client must consider such potential penalties prior to agreeing to exchange or purchase a variable
annuity product.
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account
transactions or new deposits be swept into and/or initially maintained in a specific custodian
designated sweep account. The yield on the sweep account will generally be lower than those
available for other money market accounts. When this occurs, to help mitigate the corresponding
yield dispersion, We shall (usually within 30 days thereafter) generally (with exceptions) purchase
a higher yielding money market fund (or other type security) available on the custodian’s platform,
unless we reasonably anticipate that we will utilize the cash proceeds during the subsequent 30-day
period to purchase additional investments for the client’s account. Exceptions and/or modifications
can and will occur with respect to all or a portion of the cash balances for various reasons, including,
but not limited to the amount of dispersion between the sweep account and a money market fund,
the size of the cash balance, an indication from the client of an imminent need for such cash, or the
client has a demonstrated history of writing checks from the account.
Please Note: The above does not apply to the cash component maintained within the Compton
Wealth’s actively managed investment strategy (the cash balances for which shall generally remain
in the custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager, and cash balances maintained
for fee billing purposes. Please Also Note: The client shall remain exclusively responsible for yield
dispersion/cash balance decisions and corresponding transactions for cash balances maintained in
any of Compton Wealth’s unmanaged accounts.
Margin/Securities Based Loans. We do not generally recommend the use of margin loans or
securities-based loans (collectively, “SBLs”) as an investment strategy, in which you would
leverage borrowed assets as collateral for the purchase of additional securities. However, we may
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
recommend that you establish a margin account with your broker-dealer/custodian or your affiliated
banks (each, an “SBL Lender”) to access SBLs for financial planning and cash flow management
purposes. For example, we may deem it advisable for a client to borrow money on margin to pay
bills or other expenses such as financing the purchase, construction, or maintenance of a real estate
project. Unlike a traditional real estate-backed loan, an SBL has the potential benefit of enabling
borrowers to access funds in a shorter time period, providing greater repayment flexibility, and may
also result in the borrower receiving certain tax benefits. Clients interested in learning more about
the potential tax benefits of borrowing money on margin should consult with an accountant or tax
advisor.
The terms and conditions of each SBL are contained in a separate agreement between the client and
the SBL Lender selected by the client, which terms and conditions may vary from client to client.
Borrowing funds on margin is not suitable for all clients and is subject to certain risks, including
but not limited to: increased market risk, increased risk of loss, especially in the event of a
significant downturn; liquidity risk; the potential obligation to post collateral or repay the SBL if
the SBL Lender determines that the value of collateralized securities is no longer sufficient to
support the value of the SBL; the risk that the SBL Lender may liquidate the client’s securities to
satisfy its demand for additional collateral or repayment / the risk that the SBL Lender may
terminate the SBL at any time. Before agreeing to participate in an SBL program, clients should
carefully review the applicable SBL agreement and all risk disclosures provided by the SBL Lender
including the initial margin and maintenance requirements for the specific program in which the
client enrolls, and the procedures for issuing “margin calls” and liquidating securities and other
assets in the client’s accounts.
Socially Responsible Investing Limitations. Socially Responsible Investing involves the
incorporation of Environmental, Social and Governance considerations into the investment due
diligence process (“ESG”). ESG investing incorporates a set of criteria/factors used in evaluating
potential investments: Environmental (i.e., considers how a company safeguards the environment);
Social (i.e., the manner in which a company manages relationships with its employees, customers,
and the communities in which it operates); and Governance (i.e., company management
considerations). There are potential limitations associated with allocating a portion of an investment
portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments
in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.) The number of
companies that meet an acceptable ESG mandate can be limited when compared to those that do
not and could underperform broad market indices. Investors must accept these limitations,
including the potential for underperformance. Correspondingly, the number of ESG mutual funds
and exchange-traded funds are limited when compared to those that do not maintain such a mandate.
As with any type of investment (including any investment and/or investment strategies
recommended and/or undertaken by Compton Wealth), there can be no assurance that investment
in ESG securities or funds will be profitable or prove successful. We do not maintain or advocate
an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If
implemented, we shall rely upon the assessments undertaken by the unaffiliated mutual fund,
exchange traded fund or separate account portfolio manager to determine that the funds or
portfolio’s underlying company securities meet a socially responsible mandate.
Wrap Fee Program. Compton Wealth does not participate in a wrap fee program.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Cash Positions. We continue to treat cash as an asset class. As such, unless determined to the
contrary by us, all cash positions (money markets, etc.) shall continue to be included as part of the
assets under management for the purpose of calculating our advisory fee. At any specific point in
time, depending upon perceived or anticipated market conditions/events (there being no guarantee
that such anticipated market conditions/events will occur), we may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could miss
market advances. Depending upon current yields, at any point in time, our advisory fee could
exceed the interest paid by the client’s money market fund.
Client Obligations. In performing our services, we shall not be required to verify any information
received from you or from your other professionals and are expressly authorized to rely thereon.
Moreover, each client is advised that it remains their responsibility to promptly notify us if there is
ever any change in their financial situation or investment objectives for the purpose of reviewing,
evaluating or revising our previous recommendations and/or services.
Disclosure Brochure. A copy of this written ADV Part 2 Brochure along with our Form CRS
Relationship Summary, shall be provided to each client prior to, or contemporaneously with, the
execution of the Investment Advisory Agreement, Retirement Plan Services Agreement or
Financial Planning and Consulting Agreement.
We will provide investment advisory services specific to the needs of each client. Prior to providing
investment advisory services, an investment adviser representative will ascertain each client’s
investment objective(s). Thereafter, we shall allocate and/or recommend the client allocate
investment assets consistent with the designated investment objective(s). The client may, at any
time, impose reasonable restrictions, in writing, on our services.
As of December 31, 2024, we had $613,977,235 in assets under management on a discretionary
basis and the remaining $106,086,580 was managed on a non-discretionary basis.
Item 5: Fees and Compensation
Investment Advisory and Management Services. If you choose to engage us to provide
discretionary and/or non-discretionary investment advisory services on a fee basis, our annual
investment advisory fee shall be based upon a percentage (%) of the assets in accordance with the
following fee schedules.
Investment Advisory and Management Services Fee Schedule
Tiers $
First $1,000,000
Next $2,000,000
Next $3,000,000
Next $4,000,000
Household AUM
$1,000,000.00
$3,000,000.00
$6,000,000.00
$10,000,000.00
Standard Advisory Fee
1.00%
0.90%
0.80%
0.70%
*** This Fee Schedule Applies to Accounts Held at Charles Schwab***
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Unless otherwise agreed to, in writing, we shall debit the account(s) for its fee. The annual fee shall
be paid quarterly, in arrears, based upon the average daily balance of the assets during the preceding
quarter.
Please note the annual investment advisory fee for account(s) held at American Funds and annuities
held at Nationwide will be charged .80%. American Funds 529 Plan accounts will be charged .50%.
These accounts will not be included in the fee schedule above and will not apply when calculating
your Household AUM.
Corporate cash accounts will follow the below tiered fee schedule and will not be included when
calculating your Household AUM.
Corporate Cash Account Fee Schedule
Tiers $
First $1,000,000
Next $2,000,000
Next $3,000,000
Next $4,000,000
Household AUM
$1,000,000.00
$3,000,000.00
$6,000,000.00
$10,000,000.00
Standard Advisory Fee
0.50%
0.40%
0.30%
0.20%
*** This Fee Schedule Applies to Accounts Held at Charles Schwab***
Fee Dispersion. We may charge, in our discretion, a lesser investment advisory fee, charge a flat
fee, waive our fee entirely, or charge fees on a different interval, based upon certain criteria (i.e.
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, complexity of the engagement, anticipated
services to be rendered, grandfathered fee schedules, employees and family members, courtesy
accounts, competition, negotiations with clients, etc.). Please note: Similarly situated clients could
pay different fees. In addition, similar advisory services may be available from other investment
advisors for similar or lower fees.
Compton Wealth includes the value of a certain month or quarter end interest or dividend payments
when calculating client fees. Because these payments may be credited to the appropriate account
after the issuance of the applicable brokerage statement, the market value reflected on the client
brokerage statement may differ slightly from the value used in Compton Wealth’s fee billing
process.
Please note neither Compton Wealth, nor its representatives, accept compensation from the sale of
securities or other investment products.
Clients may elect to have our advisory fees deducted from their custodial account. Both Compton
Wealth’s Agreement and the custodial/clearing agreement may authorize the custodian to debit the
account for our investment advisory fee and to directly remit that management fee to us in
compliance with regulatory procedures. Compton Wealth charges fees quarterly in arrears based
on the fee schedule noted above. The fee will be calculated in arrears as a percentage of the average
daily balance of all assets in the client's account during each calendar quarter. In any partial calendar
quarter, the advisory fee will be pro-rated based upon the number of days that the account was open
during the quarter. Payment of fees will be made through a quarterly debit to the client’s account
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
at the custodian. Indirect billing, i.e., paying one account’s fee from a different account, can be
utilized by Compton Wealth. If a client terminates its agreement with Compton Wealth in the
middle of a billing period, the Company will either deduct fees automatically from the client’s
account or will send an invoice to the client for an amount that is pro-rated based on the number of
days that the account was managed during that quarter. The investment advisory and management
services fees are negotiable at the discretion of Compton Wealth. The client must provide notice of
termination in accordance with the terms of the investment advisory agreement.
Custodian Charges – Additional Fees.
As discussed under Item 12, unless the client directs otherwise or an individual client’s
circumstances require, Compton Wealth shall generally recommend that Schwab, an independent
and unaffiliated SEC-registered broker-dealer and FINRA member, serve as the broker-
dealer/custodian for client investment management assets. Broker-dealers such as Schwab charge
brokerage commissions and/or transaction fees for affecting certain securities transactions. A
schedule of the fees charged by Schwab will be provided with the account application. In addition
to the program fees, clients can also incur the management fees and any other expenses of any
mutual funds or other investment vehicles that we select for a client’s portfolio. Since these fees
and expenses are typically deducted directly from the investment vehicle, they are not necessarily
obvious to shareholders, but they represent a real cost to our clients.
While certain custodians, including Schwab, generally (with exceptions) do not currently charge
fees on individual equity transactions (including ETFs), others do. There can be no assurance that
Schwab will not change their transaction fee pricing in the future. Schwab may also assess fees for
clients who elect to receive trade confirmations and account statements by regular mail rather than
electronically.
Financial Planning and Consulting Services (Stand-Alone). To the extent specifically requested
by a client, Compton Wealth will generally provide financial planning and/or consulting services
(including investment and non-investment-related matters, including estate planning, insurance
planning, etc.) as part of its investment management engagement. We may also provide, upon client
request, financial planning services pursuant to a separate financial planning agreement. Compton
Wealth’s planning and consulting fees are negotiable, depending upon the level and scope of the
service(s) required and the professional(s) rendering the service(s). At Compton Wealth’s
discretion, any fee paid related to investment services can be applied to financial planning services.
Our financial planning fee ranges from $150 to $450 on an hourly basis.
Investment Management clients who maintain investment assets under management with us below
$1,000,000 will typically enter into an arrangement that does not include financial planning. Such
clients, if they seek additional financial planning services, would need to engage the firm separately
for financial planning, subject to the above hourly fee schedule.
If separately billed for financial planning services, the client shall pay us within 30 days from the
date of the invoice or upon presentation of the written financial plan. A client can cancel the
financial planning agreement and receive a full refund if we are notified within five business days
after signing an agreement. If cancellation occurs thereafter, the client is responsible only for
expenses incurred to that point. In such an event, an itemized invoice will be provided documenting
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
the expenses that have been incurred.
Employer Sponsored Retirement Plan Consulting Services. Compton Wealth provides pension
consulting services, in the capacity of an ERISA 3(21) advisor, pursuant to which it assists sponsors
of self-directed retirement plans with the selection and/or monitoring of investment alternatives
from which plan participants shall choose in self-directing the investments for their individual plan
retirement accounts. Compton Wealth’s annual fee for these services generally ranges from
negotiable up to 1.00% of the total assets maintained within the plan.
As noted above, we shall generally deduct fees and/or bill clients quarterly in arrears, based upon
the average daily balance of the client’s assets under management during the preceding quarter. In
the instance that Compton Wealth has been engaged to provide Retirement Plan Consulting
Services, we shall deduct fees and/or bill clients monthly or quarterly in arrears, based upon the
average daily balance of the Plan assets during the preceding month/quarter. Fee deduction is
generally undertaken by the third-party administrator and a portion of the advisory fee is remitted
to Compton Wealth. The Investment Advisory Agreement between Compton Wealth and the client
will continue in effect until terminated by either party by written notice in accordance with the
terms of the Investment Advisory Agreement. Upon termination, Compton Wealth shall invoice
the client for a pro-rated portion of the monthly advisory fee, based upon the average daily balance
of the client’s assets under management and the number of days that services were rendered during
the final billing period.
Family Office Services. Family Office services are provided for a separate and additional fee per
the terms and conditions of a separate written agreement between us and the client. If Family Office
clients wish to engage us to provide our investment advisory services, they will enter into an
Investment Advisory Agreement separate from their Family Office Agreement. The fees for these
services are specified in the written agreement and calculated using a tiered structure based on a
percentage ranging from 0.20% to 0.65% of the average daily market value of assets under
management in the account(s) during the previous quarter.
Item 6: Performance Based Fees and Side-by-Side Management
We do not charge any performance-based fees. Some investment advisers experience conflicts of
interest in connection with the side-by-side management of accounts with different fee structures.
However, these conflicts of interest are not applicable to us.
Item 7: Types of Clients
We primarily provide customized investment management services to high-net-worth individuals
and associated trusts, estates, and other legal entities.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis and Investment Strategies. During initial meetings with prospective clients,
we explain the services we offer and our compensation. We will define each other’s responsibilities
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
and how to make decisions. Both parties will determine if working together makes sense, and all
necessary disclaimers will be made.
If the client decides to engage our firm, we will discuss their current financial situation and gather
all necessary documents. Together we define their goals and objectives, retirement goals, income
needs, education funding for children and grandchildren, family legacy or estate planning concepts,
charitable gifting, tax considerations, and investment risk tolerance.
After the client provides the required information and documents, we will analyze their situation to
identify strategies that are believed to be in the best interest of meeting the client’s goals and
objectives. These strategies are discussed with the client prior to implementation to be sure the
client understands and is comfortable with the strategies and agrees with the investment
recommendations. At this stage, we discuss any concerns the client has and revise the
recommendations if necessary.
Once we have finished planning and implementing, we enter the monitoring phase of the
relationship. We meet regularly with the clients to track their progress toward accomplishing their
goals and objectives. Clients are also provided quarterly account statements from Charles Schwab
& Co., Inc. (“Schwab”). Our services are ongoing until either party chooses to terminate the
relationship.
Compton Wealth may utilize the following methods of security analysis:
• Fundamental - (analysis performed on historical and present data, with the goal of making
financial forecasts)
• Technical – (analysis performed on historical and present data, focusing on price and trade
volume, to forecast the direction of prices)
Compton Wealth may utilize the following investment strategies when implementing investment
advice given to clients:
• Long Term Purchases (securities held at least a year)
• Short Term Purchases (securities sold within a year)
• Margin Transactions (use of borrowed assets to purchase financial instruments)
Third-Party Investment Managers. Compton Wealth can recommend clients use the investment
advisory services of professional portfolio management firms for the individual management of
client accounts. Compton Wealth will assist clients in identifying a third-party portfolio manager
(Portfolio Manager). The Portfolio Manager manages the client’s assets on a discretionary basis.
Compton Wealth will provide initial and ongoing assistance regarding the Portfolio Manager
selection process. The Portfolio Manager can have a minimum account value (e.g., $100,000) that
is required for a client to invest with them.
Risks. The description below is an overview of the risks entailed in our investment strategies and
is not intended to be complete. All investing involves the risk of loss and the investment strategy
offered by us could lose money over short or long periods. Performance could be hurt by several
different market risks including but not limited to:
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Investment Risk. Investing in securities involves the risk of loss that clients should be prepared to
bear. Different types of investments involve varying degrees of risk, and it should not be assumed
that the future performance of any specific investment or investment strategy (including the
investments and/or investment strategies recommended or undertaken by Compton Wealth) will be
profitable or equal any specific performance level(s).
Compton Wealth’s methods of analysis and investment strategies do not present any significant or
unusual risks. However, every method of analysis has its own inherent risks. To perform an accurate
market analysis Compton Wealth must have access to current/new market information. Compton
Wealth has no control over the dissemination rate of market information; therefore, unbeknownst
to Compton Wealth, certain analyses may be compiled with outdated market information, severely
limiting the value of Compton Wealth’ analysis. Furthermore, an accurate market analysis can only
produce a forecast of the direction of market values. There can be no assurances that a forecasted
change in market value will materialize into actionable and/or profitable investment opportunities.
Compton Wealth’ primary investment strategies – Long Term Purchases and Short-Term Purchases
- are fundamental investment strategies. However, every investment strategy has its own inherent
risks and limitations. For example, longer-term investment strategies require a longer investment
time-period to allow for the strategy to potentially develop. Shorter-term investment strategies
require a shorter investment time-period to potentially develop but, as a result of more frequent
trading, may incur higher transactional costs when compared to a longer-term investment strategy.
In addition to the fundamental investment strategies discussed above, we may also implement
and/or recommend the use of margin transactions. Margin investment strategies have a high level
of inherent risk.
Margin is an investment strategy with a high level of inherent risk. A margin transaction occurs
when an investor uses borrowed assets to purchase financial instruments. The investor generally
obtains the borrowed assets by using other securities as collateral for the borrowed sum. The effect
of purchasing a security using margin is to magnify any gains or losses sustained by the purchase
of the financial instruments on margin. Please Note: To the extent that a client authorizes the use
of margin, and margin is thereafter employed by us in the management of the client’s investment
portfolio, the market value of the client’s account and corresponding fee payable by the client to us
may be increased. As a result, in addition to understanding and assuming the additional principal
risks associated with the use of margin, clients authorizing margin are advised of the potential
conflict of interest whereby the client’s decision to employ margin may correspondingly increase
the management fee payable to us. Accordingly, the decision as to whether to employ margin is
left totally to the discretion of client.
Currently, we primarily allocate client investment assets among individual municipal and corporate
bonds, bond funds, various no-load equity mutual fund classes, individual equities, and Independent
Manager(s), on both a limited discretionary and non-discretionary basis in accordance with the
client’s designated investment objective(s). With respect to our non-discretionary management
services, we maintain ongoing responsibility for selecting or making recommendations, based upon
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
the needs of the client, as to the specific securities or other investments the account may purchase
or sell, and we are responsible for arranging or affecting the purchase or sale.
Risk of Loss – General. All investing involves a risk of loss and the investment strategy offered
by Compton Wealth could lose money over short or even long periods. Performance could be
negatively impacted by several different market risks, including, but not limited to, portfolio
management techniques used by Compton Wealth, which do not produce the desired results. This
could cause accounts to decline in value. In addition, Compton Wealth can rely on information that
turns out to be inaccurate. Compton Wealth selects investments based, in part, on information
provided by issuers to regulators or made directly available to Compton Wealth by the issuers or
other sources. Compton Wealth is not always able to confirm the completeness or accuracy of such
information, and in some cases, complete and accurate information is not available. Incorrect or
incomplete information increases risk and could result in losses.
Stock Market Risk. Stock market risk is the chance that stock prices overall will decline. An
investment in individual securities or in a portfolio of securities could lose money. We cannot give
any guarantee that we will achieve the client’s investment objectives or that any client will receive
a return from their investment. Stock markets tend to move in cycles, with periods of rising prices
and periods of falling prices.
Alternative Strategy Mutual Funds. Certain mutual funds invest primarily in alternative
investments and/or strategies. Investing in alternative investments and/or strategies involves special
risks, such as risks associated with commodities, real estate, leverage, selling securities short, the
use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity.
There are special risks associated with mutual funds that invest principally in real estate securities,
such as sensitivity to changes in real estate values, interest rates and price volatility because of the
fund’s concentration in the real estate industry.
Exchange-Traded Funds (“ETFs”). ETFs are typically investment companies that are legally
classified as open-end mutual funds or UITs. However, they differ from traditional mutual funds,
in particular, in that ETF shares are listed on a securities exchange. Shares can be bought and sold
throughout the trading day like shares of other publicly traded companies. ETF shares can trade at
a discount or premium to their net asset value. This difference between the bid price and the ask
price is often referred to as the “spread.” The spread varies over time based on the ETF’s trading
volume and market liquidity and is generally lower if the ETF has a lot of trading volume and
market liquidity and higher if the ETF has little trading volume and market liquidity. Although
many ETFs are registered as an investment company under the Investment Company Act of 1940
like traditional mutual funds, some ETFs, particularly those that invest in commodities, are not
registered as an investment company.
Foreign Securities Risk. Foreign securities are subject to the same market risks as U.S. securities,
such as general economic conditions and company and industry prospects. However, foreign
securities involve the additional risk of loss due to political, economic, legal, regulatory, and
operational uncertainties; differing accounting and financial reporting standards; limited
availability of information; currency conversion; and pricing factors affecting investment in the
securities of foreign businesses or governments.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Emerging Market Securities Risk. Securities markets in emerging market countries can be
smaller than those in more developed countries, making it more difficult to sell securities to take
profits or avoid losses. Companies in these markets can have limited product lines, markets or
resources, making it difficult to measure the value of the company. Potential political instability
and corruption, as well as lower standards of regulation for business practices, increase the
possibility of fraud and other legal problems. Public information can be limited with respect to
emerging markets issuers and emerging markets issuers might not be subject to uniform accounting,
auditing and financial standards and requirements comparable to those applicable to U.S.
companies. Therefore, the value of strategies that invest in emerging markets can rise and fall
substantially.
Interest Rate Risk. Bonds also experience market risk as a result of changes in interest rates. The
general rule is that if interest rates rise, bond prices will fall and so will the mutual funds and ETF’s
share price. The reverse is also true: if interest rates fall, bond prices will generally rise. A bond
with a longer maturity (or a bond fund with a longer average maturity) will typically fluctuate more
in price than a shorter-term bond. Because of their very short-term nature, money market
instruments carry less interest rate risk.
Credit Risk. Bonds and bond mutual funds and ETFs are also exposed to credit risk, which is the
possibility that the issuer of a bond will default on its obligation to pay interest and/or principal.
U.S. Treasury securities, which are backed by the full faith and credit of the U.S. Government, have
limited credit risk, while securities issued or guaranteed by U.S. Government agencies or
government-sponsored enterprises that are not backed by the full faith and credit of the U.S.
Government are subject to varying degrees of credit risk. Corporate bonds rated BBB or above by
Standard & Poor's are generally considered to carry moderate credit risk. Corporate bonds rated
lower than BBB are considered to have significant credit risk. Of course, bonds with lower credit
ratings generally pay a higher level of income to investors.
Objective/Style Risk. All the mutual funds and ETFs are subject, in varying degrees, to
objective/style risk, which is the possibility that returns from a specific type of security in which a
mutual fund invests will trail the returns of the overall market.
U.S. Government Agency Securities Risk. Securities issued by U.S. Government agencies or
government-sponsored entities are not guaranteed by the U.S. Treasury. If a government- sponsored
entity is unable to meet its obligations, the securities of the entity will be adversely impacted.
Cybersecurity Risks. Compton Wealth and its service providers are subject to risks associated
with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology,
processes and practices designed to protect networks, systems, computers, programs and data from
both intentional cyber-attacks and hacking by other computer users as well as unintentional damage
or interruption that, in either case, can result in damage or interruption from computer viruses,
network failures, computer and telecommunications failures, infiltration by unauthorized persons
and security breaches, usage errors by their respective professionals, power outages and
catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. A cybersecurity
breach could expose both Compton Wealth and its clients to substantial costs including, without
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
limitation, those associated with forensic analysis of the origin and scope of the breach, increased
and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation,
adverse client reaction, the dissemination of confidential and proprietary information, reputational
damage, civil liability as well as regulatory inquiry and/or action.
The information technology systems and networks that Compton Wealth and its third-party service
providers use to provide services to Compton Wealth’s clients employ various controls that are
designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that
could cause significant interruptions in Compton Wealth’s operations and/or result in the
unauthorized acquisition or use of clients’ confidential or non-public personal information. In
accordance with Regulation S-P, we are committed to protecting the privacy and security of our
clients' non-public personal information by implementing appropriate administrative, technical, and
physical safeguards. We have established processes to mitigate the risks of cybersecurity incidents,
including the requirement to restrict access to such sensitive data and to monitor its systems for
potential breaches. Compton Wealth and its clients are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur financial losses and/or other
adverse consequences. Although we have established processes to reduce the risk of cybersecurity
incidents, there is no guarantee that these efforts will always be successful, especially considering
that we do not control the cybersecurity measures and policies employed by third-party service
providers, issuers of securities, broker-dealers, qualified custodians, governmental and other
regulatory authorities, exchanges, and other financial market operators and providers. In
compliance with Regulation S-P, we will notify clients in the event of a data breach involving their
non-public personal information as required by applicable state and federal laws.
Item 9: Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of the adviser or the integrity of
the adviser’s management. Neither the firm nor any of our personnel have been involved in any
legal or disciplinary events that would require disclosure in response to this Item.
Item 10: Other Financial Industry Activities and Affiliations
Neither Compton Wealth, nor its representatives, are registered or have an application pending to
register, as a broker-dealer or a registered representative of a broker-dealer.
Neither Compton Wealth, nor its representatives, are registered or have an application pending to
register, as a futures commission merchant, commodity pool operator, a commodity trading advisor,
or a representative of the foregoing.
Licensed Insurance Agents. Certain of Compton Wealth’s representatives, in their individual
capacities, are licensed insurance agents. As referenced in Item 4, Compton Wealth and/or its
representatives may recommend the purchase of certain insurance-related products on a
commission basis.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Conflict of Interest. The recommendation by representatives of Compton Wealth that a client
purchase an insurance commission product presents a conflict of interest, as the receipt of
commissions provides an incentive to recommend insurance products based on commissions to be
received, rather than on a particular client’s need. No client is under any obligation to purchase any
commission products from representatives of Compton Wealth or through Compton Wealth in its
capacity as a licensed insurance agency. Clients are reminded that they may purchase insurance
products recommended by Compton Wealth through other nonaffiliated insurance agents.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
We have adopted a written Code of Ethics (“Code”) that is applicable to all employees describing
our high standards of business conduct and fiduciary duty to our clients. The Code includes
provisions relating to the confidentiality of client information, a prohibition of insider trading,
restrictions on the acceptance of significant gifts and the reporting of certain gifts and business
entertainment items, and personal securities trading procedures, among other things. In addition,
the Code requires our employees to act in the clients’ best interests, abide by all applicable
regulations, and pre-clear and report on many types of personal securities transactions. Our
restrictions on personal securities trading apply to employees, as well as employees’ family
members living in the same household. A copy of our Code is available upon request by emailing
Nancy Renshaw at nancy@comptonwealth.com.
We maintain an investment policy related to personal securities transactions. This investment
policy is part of our overall Code of Ethics, which serves to establish a standard of business conduct
for all of Compton Wealth’ representatives that is based upon fundamental principles of openness,
integrity, honesty and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisers Act of 1940, Compton Wealth also
maintains and enforces written policies reasonably designed to prevent the misuse of material non-
public information by Compton Wealth or any person associated with Compton Wealth.
Neither Compton Wealth nor any related person at Compton Wealth recommends, buys, or sells
for client accounts, securities in which Compton Wealth or any related person of Compton Wealth
has a material financial interest.
Compton Wealth and/or representatives of Compton Wealth may buy or sell securities that are also
recommended to clients. This practice may create a situation where Compton Wealth and/or
representatives of the firm are in a position to materially benefit from the sale or purchase of those
securities. Therefore, this situation can create a conflict of interest. Practices such as “scalping”
(i.e., a practice whereby the owner of shares of a security recommends that security for investment
and then immediately sells it at a profit upon the rise in the market price which follows the
recommendation) could take place if Compton Wealth did not have adequate policies in place to
detect such activities. In addition, this requirement can help detect insider trading, “front-running”
(i.e., personal trades executed before those of Compton Wealth’ clients) and other potentially
abusive practices.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Compton Wealth has a personal securities transaction policy in place to monitor the personal
securities transactions and securities holdings of each of Compton Wealth’s “Access Persons.”
Compton Wealth’ securities transaction policy requires that an Access Person of Compton Wealth
must provide the Chief Compliance Officer or his/her designee with their current securities holdings
within ten (10) days after becoming an Access Person by entering this information into the firm’s
compliance software program. Additionally, each Access Person must provide the Chief
Compliance Officer or his/her designee with the Access Person’s current securities holdings by
entering this information into the compliance software program at least once each twelve (12)
month period thereafter on a date Compton Wealth selects. If at any time that Compton Wealth has
only one Access Person, he or she shall not be required to submit any securities reports.
As noted above, our employees are generally permitted to trade alongside client accounts as long
as they receive the average price that is applicable to clients and pay their share of any transaction
costs. However, no employees are allowed to participate in partially filled orders until all clients’
orders have been filled. The Chief Compliance Officer monitors employee trading, related to client
trading, to ensure that employees do not engage in improper transactions. Therefore, this situation
can create a conflict of interest. As indicated above, Compton Wealth has a personal securities
transaction policy in place to monitor the personal securities transaction and securities holdings of
each of Compton Wealth’s Access Persons.
Item 12: Brokerage Practices
If the client requests that we recommend a broker-dealer/custodian for execution and/or custodial
services (exclusive of those clients that may direct us to use a specific broker-dealer/custodian), we
generally recommend that investment management accounts be maintained at Schwab. Prior to
engaging us to provide investment management services, the client will be required to enter into a
formal Investment Advisory Agreement with us setting forth the terms and conditions under which
we shall manage the client's assets, and a separate custodial/clearing agreement with each
designated broker-dealer/ custodian.
Factors that Compton Wealth considers in recommending Schwab (or any other broker-
dealer/custodian to clients) include historical relationship with us, financial strength, reputation,
execution capabilities, pricing, research, and service. Broker-dealers such as Schwab can charge
transaction fees for effecting certain securities transactions. To the extent that a transaction fee will
be payable by the client to Schwab, the transaction fee shall be in addition to our investment
advisory fee referenced in Item 5.
the value of research provided, execution capability,
To the extent that a transaction fee is payable, we shall have a duty to obtain best execution for such
transaction. However, that does not mean that the client will not pay a transaction fee that is higher
than another qualified broker-dealer might charge to affect the same transaction where we
determine, in good faith, that the transaction fee is reasonable. 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,
transaction rates, and
including
responsiveness. Accordingly, although we will seek competitive rates, it may not necessarily obtain
the lowest possible rates for client account transactions.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian
are exclusive of, and in addition to, our investment management fee. Compton Wealth’s best
execution responsibility is qualified if securities that it purchases for client accounts are mutual
funds that trade at net asset value as determined at the daily market close.
Research and Benefits.
Although not a material consideration when determining whether to recommend that a client utilize
the services of a particular broker-dealer/custodian, Compton Wealth receives from Schwab or
another broker-dealer/custodian, investment platform, unaffiliated investment manager, vendor,
unaffiliated product/fund sponsor, or vendor) support services and/or products, certain of which
assist us to better monitor and service client accounts maintained at such institutions. Included
within the support services that may be obtained by us may be investment-related research, pricing
information and market data, software and other technology that provide access to client account
data, compliance and/or practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or
social events, marketing support, computer hardware and/or software and/or other products used
by us in furtherance of our investment advisory business operations.
As indicated above, certain of the support services and/or products that may be received may assist
us in managing and administering client accounts. Others do not directly provide such assistance
but rather assist us to manage and further develop our business enterprise.
There is no corresponding commitment made by us to Schwab or any other entity to invest any
specific amount or percentage of client assets in any specific mutual funds, securities or other
investment products because of the above arrangement.
Products and Services Provided by Schwab.
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms
like Compton Wealth. Schwab provides us and our clients with access to its institutional
brokerage - trading, custody, reporting, and related services, many of which are not typically
available to retail customers. Schwab also makes available various support services. Some of
those services help us manage or administer clients’ accounts, while others help us manage and
grow our business.
Services that Benefit Clients.
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products available
through Schwab include some to which Compton Wealth might not otherwise have access or that
would require a significantly higher minimum initial investment from Compton Wealth’s clients.
Services that Do Not Directly Benefit Clients.
Schwab also makes available other products and services that benefit Compton Wealth but do not
directly benefit clients. These products and services assist Compton Wealth in managing and
administering Compton Wealth’s clients’ accounts. Schwab includes investment research and that
of third parties. Compton Wealth can use this research to service all or a substantial number of its
clients’ accounts, including accounts not maintained at Schwab. In addition to investment research,
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Schwab also purchases, reimburses or makes available benefits, software, and other technology
that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Generate performance reports for clients
• Facilitate payment of Compton Wealth’s fees from Clients’ accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that Generally Benefit Only Compton Wealth.
Schwab also offers other services intended to help Compton Wealth manage and further develop
its business enterprise. These services include:
• Educational conferences and events
• Consulting on technology, compliance, legal, and business needs
• Publications and conferences on practice management and business succession
Schwab provides some of these services themselves. In other cases, they will arrange for third-party
vendors to provide the services to Compton Wealth. Schwab can also discount or waive their fees
for some of these services or pay all or a part of a third party’s fees.
Compton Wealth’s Interest in Schwab’s Services.
The availability of these services from Schwab benefits Compton Wealth because Compton Wealth
does not have to produce or purchase them. Compton Wealth does not have to pay for Schwab’s
services so long as Compton Wealth’s clients maintain a minimum level of assets in accounts at
Schwab. Beyond that, these services are not contingent upon Compton Wealth committing any
specific amount of business to Schwab in trading commissions or assets in custody.
Maintaining a minimum level of assets can give Compton Wealth an incentive to recommend that
clients maintain accounts with Schwab based on Compton Wealth’s interest in receiving Schwab’s
services that benefit Compton Wealth’s business rather than based on clients’ interests in receiving
the best value in custody services and the most favorable execution of transactions. This is a
potential conflict of interest. Compton Wealth believes, however, that its recommendation of
Schwab, when appropriate, as custodian and broker is in the best interests of clients. Compton
Wealth’s recommendation is primarily supported by the scope, quality, and price of Schwab’s
services. Compton Wealth does not believe that recommending clients to collectively maintain a
minimum level of assets at Schwab in order to avoid paying Schwab quarterly service fees presents
a material conflict of interest.
Compton Wealth does not receive referrals from broker-dealers.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
Directed Brokerage.
As noted above, Compton Wealth generally recommends the establishment of brokerage accounts
with Schwab to maintain custody of clients’ assets and to affect trades for their accounts.
If a client has instructed Compton Wealth to execute any or all securities transactions for his/her
account with or through one or more brokers, the client represents and warrants that he/she has
negotiated the terms and conditions (including, but not limited to, commission rates) relating to all
services provided by such brokers and that the client is satisfied with such terms and conditions.
We shall not have any responsibility for obtaining for the client’s account from any such broker the
best prices or any particular commission rates for transactions with or through any such designated
broker. The client recognizes that he/she might not obtain rates as low as it might otherwise obtain
if we had discretion to select broker/dealers other than those he/she chose. The client further agrees
that if we believe, in our exclusive discretion, that we cannot satisfy our fiduciary duty of best
execution by executing a securities transaction for a client’s account with a broker designated by
the client, we will execute that securities transaction with a different broker. The client shall
promptly inform Compton Wealth in writing if he/she desires that we cease executing transactions
with or through any such designated broker.
To the extent that we provide investment management services to our clients, the transactions for
each client account generally will be affected independently, unless we decide to purchase or sell
the same securities for several clients at approximately the same time. We may (but are not
obligated to) combine or “bunch” such orders to seek best execution, to negotiate more favorable
commission rates or to allocate equitably among Compton Wealth’s clients differences in prices
and commissions or other transaction costs that might have been obtained had such orders been
placed independently. Under this procedure, transactions will be averaged as to price and will be
allocated among clients in proportion to the purchase and sale orders placed for each client account
on any given day. We shall not receive any additional compensation or remuneration because of
such aggregation.
Best Execution Reviews.
As a fiduciary, we seek to obtain best execution in all securities transactions. However, this does
not mean that we will always obtain the best possible price or the lowest commission. On at least
an annual basis Compton Wealth evaluates the pricing and services offered by Schwab and other
trading counterparties with those offered by other reputable firms. Compton Wealth has sought to
make a good-faith determination that Schwab and other chosen trading counterparties provide
clients with good services at competitive prices. However, clients should be aware that this
determination could have been influenced by Compton Wealth’s receipt of products and services
from Schwab.
Item 13: Review of Accounts
For those clients to whom we provide investment supervisory services, account reviews are
conducted on an ongoing basis by Compton Wealth’ representatives. We will review client
portfolios to determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, market conditions, fund manager tenure, style drift, account
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
additions/withdrawals, and/or a change in the client’s investment objective. Based upon these
factors, there may be extended periods of time when we determine that changes to a client’s
portfolio are unnecessary. Clients remain subject to the fees described in Item 5 during periods of
portfolio inactivity.
We will conduct account reviews upon the occurrence of a triggering event, such as a change in
your investment objectives and/or financial situation, market corrections and by request. All clients
are advised that it remains their responsibility to advise us of any changes in their investment
objectives and/or financial situation. In addition, all clients (in person or via telephone) are
encouraged to review financial planning issues (to the extent applicable), investment objectives and
account performance with us on an annual basis.
Clients are provided, at least quarterly, with written transaction confirmation notices and regular
written summary account statements directly from the broker-dealer/custodian and/or program
sponsor for their accounts. We also provide a written periodic report summarizing account activity
and performance.
Item 14: Client Referrals and Other Compensation
Compton Wealth does not compensate any individuals or entities for client introductions, nor do
we recommend or select other investment advisors for our clients for which we receive a fee.
We do receive an economic benefit from Schwab in the form of the support products and services
they make available to us and our investment advisers that have their client accounts at Schwab.
These products and services, how they benefit us, and the related conflicts of interest are described
within Item 12 – Brokerage Practices. The availability of Schwab’s products and services to us is
not based on our giving particular investment advice or buying particular securities for our clients.
Item 15: Custody
Advisers have custody of client assets when they hold, “directly or indirectly, client funds or
securities or has any authority to obtain possession of them. Under government regulations, we are
deemed to have “custody” of your assets when you authorize us to instruct the custodian to deduct
our advisory fees directly from your account; request your advisor to act as trustee on your account;
when we provide bill pay services; when we have usernames and passwords to your financial
accounts; when we forward funds or securities we inadvertently receive by a third party to your
account at the custodian (i.e.: tax refund checks, settlement checks from class action lawsuits,
dividend checks, stock certificates); or when you provide us with a standing letter of authorization
to move funds or securities to a third party.
We engage in the above-mentioned custody related
services and/or practices that are disclosed in Item 9 of Part 1 of Form ADV l. These services and
practices are included in an annual surprise CPA examination. Compton Wealth does not maintain
actual custody of client funds or securities, nor are we authorized to hold or receive any stock, bond,
investment certificate, cash (except in the payment of our advisory fee) or other security that is part
of your account. All clients’ accounts are held in custody by unaffiliated qualified custodians such
as a broker/dealer or bank.
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Form ADV Part 2 Brochure | Compton Wealth Advisory Group, LLC March 26, 2025
You will receive account statements directly from the broker/dealer, bank or custodian(s) holding
your account assets on no less than a quarterly basis. Statements will be sent to the email or postal
address you provide to the custodian. The account statements from these qualified custodian(s) will
detail all transactions during the period, including the amount of our advisory fees deducted from
your account(s) each billing period. We urge you to carefully review these statements and you
should compare these statements to any account information provided by us. Please note that the
custodians’ account statement serves as the client’s permanent record of the assets held with each
custodian.
Item 16: Investment Discretion
Compton Wealth typically is granted investment discretion over its clients’ accounts. For accounts
managed on a discretionary basis, we are given the authority to determine and execute the securities
to be bought and sold without obtaining prior client consent for specific transactions. This discretion
is subject to any reasonable restrictions placed by the client. Clients grant Compton Wealth trading
discretion through the execution of a limited power of attorney included in Compton Wealth’s
investment advisory contract.
Item 17: Voting Client Securities
As a matter of policy, we disclaim responsibility for voting client securities. You can contact us for
advice or information about a particular proxy vote, but we do not exercise proxy voting authority
over client securities and should not be designated by custodians as the party to receive information
on voting client proxies. You will receive your proxies or other solicitations directly from your
custodian. The obligation to vote client proxies rests with you, the client, including making all
elections related to mergers, acquisitions, tender offers, bankruptcy proceedings or other events
pertaining to your investment assets. We will, however, direct clients to an unaffiliated service
provider to support class actions.
Class Actions: You shall maintain exclusive responsibility for all legal proceedings or other types
of events pertaining to the assets managed by us, including, but not limited to, class action lawsuits.
We have identified an unaffiliated service provider (Chicago Clearing Corporation or “CCC”) to
assist you, for a fee of 12.5% of the recovery, with class-action matters. We shall not receive any
compensation from the service provider. Please Note: You are under no obligation to engage the
service provider. Please Also Note: We do not participate in class action proceedings on behalf of
our clients. Thus, if you choose not to engage CCC, you will be exclusively responsible for
monitoring and pursuing all class action claims.
Item 18: Financial Information
A balance sheet or other financial disclosures are not required to be provided as Compton Wealth
(i) does not solicit fees of more than $1200, more than six months in advance, (ii) does not have a
financial condition that is likely to impair its ability to meet contractual commitments to clients or
(iii) has never filed bankruptcy.
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