St. James Investment Company was founded in 1999. Our owners are Robert J. Mark, through his entity Sibelius
Holdings, LLC, and Larry J. Redell. As of December 31, 2023, St. James managed $661.9 million on a discretionary
basis. We also distribute our Select Value model, under which $220.5 million was managed by other advisers.
St. James does not provide regular supervisory or management services on a non-discretionary basis.
St. James is an independent, fee-only, registered investment advisory firm providing portfolio management to
private individuals, trusts and estates, registered investment companies (a mutual fund and an ETF), pension,
profit sharing and other retirement plans, charitable organizations, and foundations. We manage equity
portfolios. Each client’s portfolio is managed based on the St. James composite investment strategy they select. We
are an asset manager utilizing a value investment strategy which is implemented through the use of equity
securities, as well as open-end mutual funds and Exchange Traded Funds (“ETFs”). St. James accepts
reasonable investment restrictions from clients, which are documented in the client files.
In addition, St. James provides sub-advised portfolio management services for a number of independent
registered investment advisers and investment companies as well as distributes a model of investment
portfolio for use by other advisers.
In all matters, St. James’ portfolio management services are analytical and advisory only and do not include
legal or other professional services. St. James will work with legal, accounting, insurance or other professional
advisors, if requested by the client, to ensure the coordination of all pieces involved in the investment
management process, however, St. James is strictly a portfolio manager only and is not responsible for any of
the client’s outside service providers.
If a client’s account is a pension or other employee benefit plan governed by the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”), St. James acknowledges that it is a “fiduciary” to the plan as that
term is defined under Section 3(21)(A) under ERISA.
However, St. James does not provide legal, accounting
or tax advice, or custodial, insurance, recordkeeping, or brokerage services to the plan. The client is
responsible for maintaining the plan in compliance with requirements applicable to tax- qualified plans under
the Internal Revenue Code including, where applicable, receipt of a favorable determination letter. St. James
does not accept responsibility for the administration of the plan including, without limitation, timely
transmission of required contributions, filing required governmental reports, preparing or providing notices
and communications to the plan’s participants as required by applicable law and regulation, or notifying you
that any such notices or communications are required.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance
Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction
Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to
you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special
rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.