Advisory Exemption Disclosures

Federal Register (PTE) 86-128
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Pershing LLC is the clearing firm for our securities business.  We do not recommend Broker/Dealers other than Pershing LLC for client transactions for our managed accounts.  We do permit you to direct brokerage to another Broker/Dealer of your choice.  Directing brokerage to a Broker/Dealer other than Pershing LLC may cost you more money in transaction costs and may result in less favorable execution prices.  The investment advisory division of Davenport relies upon Pershing LLC’s broker/dealer services for best execution.

We are a full‐service brokerage firm. As such, we effect securities transactions for our advisory clients, for compensation. For Fee plus Commission and Commission Only accounts the commissions and other charges on transactions executed by us will be charged according to our standard retail commission schedule. The standard commission schedule is approximately 1.5%‐3% of the principal amount of the transaction, subject to a minimum commission of $85 per transaction. Some clients may have negotiated discounts different from the posted rates. However, we consider the commission costs when determining our fee schedule for investment advice and believe that the total fees paid by clients are reasonable. We report to our ERISA and IRA discretionary advisory clients, on an annual basis, the total commissions paid per year along with the portfolio turnover ratio for their account. This information is available to our non‐ERISA clients upon request.