Overview
Assets Under Management: $1.4 billion
Headquarters: NEWPORT, RI
High-Net-Worth Clients: 439
Average Client Assets: $3 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $2,000,000 | 0.80% |
$2,000,001 | $5,000,000 | 0.70% |
$5,000,001 | and above | 0.55% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $8,000 | 0.80% |
$5 million | $37,000 | 0.74% |
$10 million | $64,500 | 0.64% |
$50 million | $284,500 | 0.57% |
$100 million | $559,500 | 0.56% |
Clients
Number of High-Net-Worth Clients: 439
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 84.53
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 1,992
Discretionary Accounts: 1,992
Regulatory Filings
CRD Number: 105866
Last Filing Date: 2024-03-25 00:00:00
Website: https://www.facebook.com/Richardcyoungcoltd
Form ADV Documents
Primary Brochure: FORM ADV PART 2A (2025-03-26)
View Document Text
Part 2A of Form ADV: Firm Brochure
Richard C. Young & Co., Ltd.
98 William Street
Newport, RI 02840
Telephone: (401) 849-2137
Email: cstack@younginvestments.com
Web Address: younginvestments.com
03/26/2025
This brochure provides information about the qualifications and business practices of Richard C.
Young & Co., Ltd. If you have any questions about the contents of this brochure, please contact
us at (401) 849-2137 or cstack@younginvestments.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.
Additional information about Richard C. Young & Co., Ltd. is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by our unique identifying CRD number, which
is 105866.
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Item 2 Material Changes
There have been no material changes to Part 2A of Form ADV since it was last issued on
03/21/2024.
Consistent with the new rules, we will ensure that you receive a summary of any material
changes to this and subsequent Brochures within 120 days of the close of our fiscal year.
Furthermore, we will provide you with other interim disclosures about material changes as
necessary.
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Table of Contents
Cover Page
Material Changes
Table of Contents
Advisory Business
Fees and Compensation
Performance‐Based Fees and Side‐By‐Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Brokerage Practices
Review of Accounts
Investment Discretion
Item 3
Item 1
Item 2
Item 3
Item 4
Item 5
Item 6
Item 7
Item 8
Item 9
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12
Item 13
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16
Item 17 Voting Client Securities
Item 18
Financial Information
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Item 4 Advisory Business
Richard C. Young & Co., Ltd. is a SEC-registered investment adviser with its principal place of
business located in Rhode Island. The firm also maintains an office in Florida. Richard C. Young
& Co., Ltd. began conducting business in 1989.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities
controlling 25% or more of this company).
Richard C. Young - 37.5%
The Richard C. Young Family Trust - 62.5%
Richard C. Young & Co., Ltd. offers the following advisory services to our clients:
INVESTMENT SUPERVISORY SERVICES ("ISS")
Through one of the six investment management programs described below and based on the
individual needs of the client, our firm provides continuous advice to a client regarding the
investment of client funds. The investment programs are not model portfolios. The asset
allocation and securities held in client accounts may vary based on a number of factors
including, but not limited to, account type, account size, date of investment, deposit and
withdrawal activity, and investment restrictions.
Global Income and Capital Protection Program - Seeks to provide current income with a
secondary goal of conserving principal. Targets an asset mix of 65%-80% in fixed-income
securities and 20%-35% in equity type securities.
Global Moderate Income Program - Seeks to provide current income while maintaining the
purchasing power of future income and capital. Targets an asset mix of 40%-60% in fixed
income securities and 40%-60% in equity type securities.
Global Moderate Income and Capital Appreciation Program - Seeks to provide income and
the opportunity for long-term capital appreciation. Targets an asset mix of 30%-50% in fixed-
income securities and 50%-70% in equity type securities.
Global Moderate Capital Appreciation Program - Seeks to provide capital appreciation with a
reduced amount of risk compared to an aggressive capital appreciation strategy. Targets an
asset mix of 15%-30% in fixed-income securities and 70-85% in equity type securities.
Retirement Compounders Plus - A portfolio invested 90%-100% in equity type securities
which seeks to provide long-term capital appreciation.
Custom - A customized investment program offered to clients who require an asset allocation
that differs from the programs listed above.
The client is responsible for selecting an investment management program. This decision is
made after personal discussions with Richard C. Young & Co., Ltd. in which the client's goals
and objectives, time horizons, risk tolerance, and liquidity needs are established. Other factors,
such as a client's prior investment history and family composition, may also be discussed prior
to the client's selection of an investment management program.
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Clients with multiple accounts may select more than one investment management program if
the accounts or group of accounts have different investment objectives. In this situation, each
account or group of accounts will be managed according to the program selected. For clients
with multiple accounts with the same investment objectives, all accounts are viewed as one unit
for investment management purposes.
We manage accounts on a discretionary basis. Account supervision is guided by the client's
selection of an investment management program and by their individual needs.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company and may include advice regarding the following securities:
Exchange-listed securities
Securities traded over-the-counter
Foreign equity and debt securities
Asset Backed Securities
Certificates of Deposit
Corporate debt securities (other than commercial paper)
Currencies
Federal agency securities
Municipal securities
Mutual fund shares
Preferred securities
United States governmental securities
Upon written notice to clients, Richard C. Young & Co., Ltd. may purchase securities not
listed above for client accounts.
AMOUNT OF MANAGED ASSETS
As of 12/31/2024, we were actively managing $1,562,885,060 of client assets on a
discretionary basis.
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Item 5 Fees and Compensation
The annualized fee for Investment Supervisory Services, which is charged quarterly in
arrears, will be charged as a percentage of assets under management, according to the
following schedule:
Assets Under Management
Annual Fee
First $2,000,000
0.80%
$2,000,001 to $5,000,000
0.70%
Above $5,000,000
0.55%
Limited Negotiability of Advisory Fees: Although Richard C. Young & Co., Ltd. has
established the fee schedule listed above, we retain the discretion to negotiate alternative fee
arrangements on a client-by-client basis. Circumstances that may be considered in determining
an alternative fee schedule include but are not limited to: the complexity of the client’s financial
situation, assets to be placed under management, anticipated future additional assets,
related accounts, and account composition.
Richard C. Young & Co., Ltd. has a minimum of $500,000 of assets under management for our
services. This account size is negotiable at our discretion, and we may group certain related
client accounts for the purpose of achieving the minimum account size and determining the
annualized fee.
Discounts, not generally available to advisory clients, may be offered to family members and
friends of associated persons of our firm.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time
by either party for any reason upon receipt of written notice. Upon termination of any account,
any fees or expenses owed will be pro-rated as of the date of termination and paid to us from
the account and/or by the client if insufficient cash and/or securities are in the account.
Mutual Fund Fees: All fees paid to Richard C. Young & Co., Ltd. for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds and/or
ETFs to their shareholders. These fees and expenses are described in each fund's prospectus.
These fees will generally include a management fee, other fund expenses, and a possible
distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred
sales charge. A client could invest in a mutual fund directly without our services. In that case,
the client would not receive the services provided by our firm, which are designed, among other
things, to assist the client in determining which mutual fund or funds are most appropriate to
each client's financial condition and objectives. Accordingly, the client should review both the
fees charged by the funds and our fees to fully understand the total amount of fees to be paid by
the client and to thereby evaluate the advisory services being provided.
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Wrap Fee Programs and Separately Managed Account Fees: Richard C. Young & Co., Ltd.
does not offer Wrap Fee Programs or Separately Managed Accounts.
Additional Fees and Expenses: In addition to our advisory fees, clients are also
responsible for the fees and expenses charged by custodians and imposed by broker-
dealers, including, but not limited to, any transaction charges imposed by a broker-dealer with
which an independent investment manager effects transactions for the client's account(s).
Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional
information.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject
to Richard C. Young & Co., Ltd.'s minimum account requirements and advisory fees in effect at
the time the client entered into the advisory relationship. Therefore, our firm's minimum account
requirements may differ among clients.
Advisory Fees in General: Clients should note that similar advisory services may (or may not)
be available from other registered (or unregistered) investment advisers for similar or lower
fees.
Limited Prepayment of Fees: Under no circumstance do we require or solicit payment of fees
in advance of services rendered.
Item 6 Performance-Based Fees and Side-By-Side Management
Richard C. Young & Co., Ltd. does not charge performance-based fees.
Item 7 Types of Clients
Richard C. Young & Co., Ltd. provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Small businesses
401(k) plans
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or
managing client assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by analyzing
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the security is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to
sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market,
regardless of the economic and financial factors considered in evaluating the security.
Technical Analysis. We analyze past market movements and apply that analysis to the
present in an attempt to recognize recurring patterns of investor behavior and potentially
predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This
presents a risk in that a poorly-managed or financially unsound company may underperform
regardless of market movement.
Cyclical Analysis. In this type of technical analysis, we measure the movements of a
particular security against the overall market in an attempt to predict the price movement of the
security.
Quantitative Analysis. We use mathematical models to obtain more accurate measurements
of a company’s quantifiable data, such as the value of a share price or
earnings per share and predict changes to that data.
A risk in using quantitative analysis is that the models used may be based on assumptions that
prove to be incorrect.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of
management, labor relations, and strength of research and development factors not readily
subject to measurement and predict changes to share price based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Asset Allocation. We attempt to identify an appropriate ratio of equities, fixed-income, precious
metals/currencies and cash suitable to a client’s investment goals and risk tolerance.
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A risk of asset allocation is that the client may not participate in sharp increases in the value of a
particular security, industry or market sector. Another risk is that the ratio of equities, fixed-
income, precious metals/currencies and cash will change over time due to stock and market
movements and, if not corrected, may no longer be appropriate for the client’s goals.
Mutual Fund and/or ETF Analysis. We review the experience and track record of the
manager of a mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions.
We also analyze the underlying assets in a mutual fund or ETF in an attempt to determine if
there is significant overlap in the underlying investments held in other fund(s) in the client's
portfolio. We also monitor the funds or ETFs to determine if they are continuing to follow their
stated investment strategies.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not
be able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund or ETF, managers of different funds held by the client may purchase the
same security, increasing the risk to the client if that security were to fall in value. There is also
a risk that a manager may deviate from the stated investment mandate or strategies of the fund
or ETF, which could make the holding(s) less suitable for the client's portfolio.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that
the companies whose securities we purchase and sell, the rating agencies that review these
securities, and other publicly-available sources of information about these securities, are
providing accurate and unbiased data. While we are alert to indications that data may be
incorrect, there is always a risk that our analysis may be compromised by inaccurate or
misleading information.
INVESTMENT STRATEGIES
We use the following strategies in managing client accounts, provided that such strategies are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the intent of holding them in the client's
account for a year or longer. Typically, we employ this strategy when:
we believe the securities to be currently undervalued and/or;
we want exposure to a particular asset class over time, regardless of the current projection for
this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we
may not take advantages of short-term gains that could be profitable to a client. Moreover, if our
predictions are incorrect, a security may decline sharply in value before we make the decision to
sell.
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Short-term purchases. When utilizing this strategy, we purchase securities with the intent to
sell them within a relatively short time (typically a year or less). We do this to take advantage of
conditions that we believe will soon result in price swings in the securities we purchase.
Risk of Loss. Investing involves risk and is not guaranteed. You may lose money on your
investment. We ask that you work with us to help us understand your tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Our Chairman, Richard C. Young, serves as the Chairman of Young Research and Publishing.
Young Research and Publishing provides economic, financial, and monetary data and analysis
to our firm and is responsible for maintaining the websites youngresearch.com,
richardcyoung.com, youngsworldmoneyforecast.com, and yoursurvivalguy.com.
Christopher J. Stack, a member of our firm's management, is an attorney licensed to practice
law in the state of Massachusetts. However, he does not currently practice law and, therefore,
will not act in this capacity for any advisory client of Richard C. Young & Co., Ltd.
Item 11 Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Our firm has adopted a Code of Ethics that sets forth high ethical standards of business conduct
that we require of our employees, including compliance with applicable federal securities laws.
Richard C. Young & Co., Ltd. and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients and have an obligation to adhere not only to the specific provisions of the
Code of Ethics but to the general principles that guide the code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as annual securities holdings reports that must be submitted by the
firm’s access persons. Among other things, our Code of Ethics also requires employees to
obtain pre-clearance before acquiring or disposing of various equity securities. Our code also
provides for oversight and recordkeeping provisions.
Richard C. Young & Co., Ltd.'s Code of Ethics further includes the firm's policy prohibiting the
use of material non-public information. While we do not believe that we have any particular
access to non-public information, all employees are reminded that such information may not be
used in a personal or professional capacity.
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A copy of our Code of Ethics is available to our advisory clients and prospective clients. You
may request a copy by emailing cstack@younginvestments.com, or by calling us at (401) 849-
2137.
Richard C. Young & Co., Ltd. and individuals associated with our firm are prohibited from
engaging in principal transactions.
Richard C. Young & Co., Ltd. and individuals associated with our firm do not engage in
agency cross-transactions.
Our Code of Ethics is designed to ensure that the personal securities transactions, activities and
interests of our employees will not interfere with (i) making decisions in the best interest of
advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal
accounts securities identical to or different from those recommended to our clients. In
addition, any related person(s) may have an interest or position in (a) certain security(ies) which
may also be recommended to a client.
It is the express policy of our firm that employees receive pre-clearance before purchasing or
selling certain securities. One goal of this policy is to prevent an employee from buying or selling
a security prior to a transaction being implemented for (an) advisory account(s), thereby
preventing such employee from benefiting from the transaction placed on behalf of the advisory
account(s). Factors that are considered when reviewing an employee transaction requests
include but are not limited to the size of the employee transaction, the average daily share
volume (liquidity) of the security being purchased or sold, the timing of the employee's purchase
or sale, and the size of the anticipated advisory account(s) transaction.
Item 12 Brokerage Practices
Richard C. Young & Co., Ltd. requires clients to provide us with written authority to determine
the broker-dealer to use and the commission costs that will be charged for transactions.
Richard C. Young & Co., Ltd. does not have any soft-dollar arrangements and does not
receive any soft-dollar benefits.
Richard C. Young & Co., Ltd. will block trades at its discretion. The blocking of trades allows for
equal treatment of client accounts in the allocation of larger trades. This blocking of trades
permits the trading of aggregate blocks of securities composed of assets from multiple client
accounts.
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Block trading may allow us to execute trades in a timelier, more equitable manner, at an
average share price. Richard C. Young & Co., Ltd.'s block trading policy and procedures are as
follows:
1. Transactions for any client account may not be aggregated for execution if the practice is
prohibited by or inconsistent with the client's advisory agreement with Richard C. Young &
Co., Ltd.
2. Richard C. Young & Co., Ltd. will determine if the purchase or sale of the particular security
involved is consistent any investment guidelines or restrictions applicable to the client's
account.
3. Richard C. Young & Co., Ltd. must reasonably believe the order aggregation will enable us
to seek best execution for each client participating in the aggregated order. This requires a
good faith judgment at the time the order is placed for the execution. It does not mean that
the determination made in advance of the transaction must always prove to have been
correct in light of a "20/20 hindsight" perspective. Best execution includes the duty to seek
the best quality of execution, as well as the best net price.
4. Upon entry of an aggregated order, a written order ticket is completed, which identifies each
client account participating in the order and the proposed allocation of the order, upon
completion, to those clients.
5. If the order cannot be executed in full at the same price or time, Richard C. Young & Co.,
Ltd. will allocate the executed shares among the participating accounts at its discretion.
Richard C. Young & Co., Ltd. will look to avoid having odd amounts of a security held in any
client account, or to avoid multiple ticket charges in client accounts.
6. Generally, each client that participates in the aggregated order must do so at the average
price for all separate transactions made to fill the order. Transaction costs will be determined
based on the client’s agreement with the custodian/broker.
7. Richard C. Young & Co., Ltd.'s client account records separately reflect, for each account in
which the aggregated transaction occurred, the securities which are held by, and bought
and sold for, that account.
8. Funds and securities for aggregated orders are clearly identified on Richard C. Young &
Co., Ltd.'s records and to the broker-dealers or other intermediaries handling the
transactions, by the appropriate account numbers for each participating client.
9. No client or account will be favored over another.
Richard C. Young & Co., Ltd. has an arrangement with National Financial Services LLC, and
Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity
provides our firm with their "platform" services. The platform services include, among others,
brokerage, custodial, administrative support, record keeping and related services that are
intended to support intermediaries like Richard C. Young & Co., Ltd. in conducting business and
in serving the best interests of our clients but that may also benefit us.
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Fidelity may charge brokerage commissions and transaction fees for effecting certain
securities transactions (i.e., transactions fees are charged for certain no-load mutual funds,
commissions may be charged for individual equity and debt securities transactions). Fidelity
enables Richard C. Young & Co., Ltd. to obtain many no-load mutual funds without transaction
charges and other no-load funds at nominal transaction charges. Fidelity’s commission rates are
determined by the size and/or nature of the client's relationship with Fidelity and may be higher
or lower than those charged by other custodians and broker-dealers. As part of the
arrangement, Fidelity also makes available to our firm, at no additional charge to us, certain
research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. These research and brokerage services presently
include services such as financial industry seminars, updates and white papers and are used by
our firm to manage accounts for which we have investment discretion.
As a result of receiving such services at a reduced cost, we may have an incentive to continue
to use or expand the use of Fidelity's services. We examined this potential conflict of interest
when we chose to enter into the relationship with Fidelity and have determined that the
relationship is in the best interests of Richard C. Young & Co., Ltd.'s clients and satisfies our
client obligations, including our duty to seek best execution. A client may pay a commission that
is higher than another qualified broker-dealer might charge to effect the same transaction where
we determine in good faith that the commission is reasonable in relation to the value of the
brokerage and research services received. In seeking best execution, the determinative factor is
not the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of a broker-dealer’s services, including the
value of research provided, execution capability, commission rates, and responsiveness.
Accordingly, while Richard C. Young & Co., Ltd. will seek competitive rates, to the benefit of all
clients, we may not necessarily obtain the lowest possible commission rates for specific client
account transactions. Although the investment research products and services that may be
obtained by us will generally be used to service all of our clients, a brokerage commission paid
by a specific client may be used to pay for research that is not used in managing that specific
client’s account. Richard C. Young & Co., Ltd. and Fidelity are not affiliated.
Item 13 Review of Accounts
INVESTMENT SUPERVISORY SERVICES
Reviews: While the underlying securities within client accounts are continually monitored, each
account is reviewed at least annually. Accounts are reviewed in the context of each client's
investment management program and their stated investment objectives and guidelines. More
frequent reviews may be triggered by material changes in variables such as the client's
individual circumstances, or the market, political or economic environment.
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These accounts are reviewed by: Matthew A. Young, President and CEO, and/or Christopher
Stack, Senior Vice President and Chief Compliance Officer.
Reports: In addition to the statements and confirmations of transactions that clients receive
from their broker-dealer, we provide quarterly reports summarizing account balances and
holdings. In addition, performance summaries are provided upon request.
Item 14 Client Referrals and Other Compensation
It is Richard C. Young & Co., Ltd.'s policy to not engage solicitors or not pay related or
non-related persons for referring potential clients to our firm.
It is Richard C. Young & Co., Ltd.'s policy to not accept or allow our related persons to accept
any form of material compensation, including cash, sales awards or other prizes, from a non-
client in conjunction with the advisory services we provide to our clients.
Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this brochure that
our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required to
send to the client a statement showing all transactions within the account during the reporting
period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy of the
calculation, among other things. Clients should contact us directly if they believe that there may
be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, we also
send account statements directly to our clients on a quarterly basis. We urge our clients to
carefully compare the information provided on these statements to ensure that all account
transactions, holdings, and values are correct and current.
Our firm does not have actual or constructive custody of client accounts.
Item 16 Investment Discretion
Clients engage us to provide discretionary asset management services. We place trades in a
client's account without contacting the client prior to each trade to obtain the client's
permission.
Our discretionary authority includes the ability to do the following without contacting the client:
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Determine the security to buy or sell;
Determine the amount of the security to buy or sell;
Change the allocation within an investment management program; and
Allow the allocation of a client account to drift outside the target allocation of an
investment management program.
Clients grant us discretionary authority when they sign a discretionary agreement with our firm
and may limit this authority by providing us with written instructions. Clients may also
change/amend such limitations by providing us with written instructions.
Item 17 Voting Client Securities
As a general rule, we do not vote proxies on behalf of clients. Therefore, although our firm may
provide investment advisory services relative to client investment assets, clients maintain
responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings, or other type of events pertaining to the
client’s investment assets. Clients are responsible for instructing each custodian of the assets,
to forward to the client copies of all proxies and shareholder communications relating to the
client’s investment assets.
Notwithstanding the above, we may provide clients with assistance regarding proxy issues if
they contact us with questions regarding a particular issue.
Item 18 Financial Information
Richard C. Young & Co., Ltd. has no additional financial circumstances to report.
Under no circumstance do we require or solicit payment of fees in excess of $1,200 per client
more than six months in advance of services rendered. Therefore, we are not required to
include a financial statement.
Richard C. Young & Co., Ltd. has not been the subject of a bankruptcy petition at any time
during the past 10 years.
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