Our Firm Brochure and Brochure Supplements, dated 03/17/2026
Bills Asset Management
SEC File Number: 801 – 61871
Bills Asset Management Brochure — Dated 03/17/2026
Contact: Sam C. Bills, Jr., Chief Compliance Officer
1724 Green Hills Drive, Nashville, Tennessee 37215
www.billsasset.com
This brochure provides information about the qualifications and business practices of Bills Asset Management (the “Registrant”). If you have any questions about the contents of this brochure, please contact us at (615) 371-5928 or Bo@Billsasset.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Bills Asset Management also is available on the SEC’s website at www.adviserinfo.sec.gov.
References herein to Bills Asset Management as a “registered investment adviser” or any reference to being “registered” does not imply a certain level of skill or training.
None.
A. Bills Asset Management (the “Registrant”) is a partnership formed on April 1, 2000 in the State of Tennessee. The Registrant became registered as an Investment Adviser Firm in February 1992. The Registrant’s Partners are Sam C. Bills, Jr. and Carter N. Bills. The Chief Executive Officer is Sam C. Bills, Jr.
B. As discussed below, the Registrant offers to its clients (individuals, business entities, trusts, estates and charitable organizations, etc.) investment advisory services. The Registrant does not hold itself out as providing financial planning, estate planning or accounting services.
C. Investment Advisory Services
The client can determine to engage the Registrant to provide discretionary investment advisory services on a fee-only basis. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management (between negotiable and 2.00%) as follows:
| Market Value of Portfolio | % of Assets |
|---|---|
| Initial $500,000 | 2.00% |
| Next $500,000 | 1.50% |
| Amounts over $1,000,000 | Negotiable |
Miscellaneous
Life Insurance Services. Sam C. Bills, Jr. and Carter N. Bills are licensed Tennessee life insurance producer/agents. As such, the Registrant may consult with client regarding life insurance needs and make recommendations regarding life insurance products. The client is under no obligation to engage the Registrant or to purchase any recommended life insurance products. The Registrant and/or Sam C. Bills, Jr. and/or Carter N. Bills may be entitled to certain commissions should the client decide to purchase an insurance product.
Limited Consulting/Implementation Services. Although the Registrant does not hold itself out as providing financial planning, estate planning or accounting services, to the extent requested by the client, the Registrant may provide consulting services regarding non-investment-related matters, such as estate planning, tax planning, etc. Neither the Registrant, nor any of its representatives, serves as an attorney, and no portion of the Registrant’s services should be construed as the same. To the extent requested by a client, the Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, etc.). 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 the Registrant. Please Note: If the client engages any such recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. Please Also Note: It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
Other Services. The Registrant also may render non-discretionary investment management services to clients relative to: (1) variable life/annuity products that they may own, and/or (2) their individual employer-sponsored retirement plans. In so doing, the Registrant either directs or recommends the allocation of client assets among the various investment subdivisions that comprise the variable life/annuity product or the various mutual funds (and/or other investment options) available on the retirement plan platform. The Registrant’s recommendations/decisions are limited to the investment options available under the variable life/annuity product or retirement plan platform. The client assets shall be maintained at either the specific insurance company that issued the variable life/annuity product which is owned by the client, or at the custodian designated by the sponsor of the client’s retirement plan.
Certified Public Accountant. Sam C. Bills, Jr., is a certified public accountant (“CPA”). To the extent that a client specifically requests accounting advice and/or tax preparation services, the Registrant may recommend the services of a CPA, for which Registrant shall not receive any fees, referral or otherwise. Sam C. Bills, Jr., does not provide any accounting advice and/or tax preparation services to Registrant’s clients and no client-CPA relationship is formed, except for a limited number of clients at no extra fees or charge.
Trade Error Policy. Registrant shall reimburse accounts for losses resulting from the Registrant’s trade errors but shall not credit accounts for such errors resulting in market gains. The gains and losses are reconciled within the Registrant’s custodian firm account and Registrant retains the net gains and losses.
Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify the Registrant if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Registrant’s previous recommendations and/or services.
Retirement Rollovers-Potential for 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 Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant provides 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), Registrant is 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 Registrant, whether it is from an employer’s plan or an existing IRA. Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation.
Disclosure Statement. A copy of the Registrant’s written Brochure as set forth on Part 2A of Form ADV shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement. Any client who has not received a copy of Registrant’s written Brochure at least 48 hours prior to executing the Investment Advisory Agreement shall have five business days subsequent to executing the agreement to terminate the Registrant’s services without penalty.
D. The Registrant shall 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, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services.
E. The Registrant does not participate in a wrap fee program.
F. As of December 31, 2025, the Registrant had $63,172,000 in assets under management on a discretionary basis.
A. The client can determine to engage the Registrant to provide discretionary investment advisory services on a fee-only basis.
Investment Advisory Services
If a client determines to engage the Registrant to provide discretionary investment advisory services on a fee-only basis, the Registrant’s annual investment advisory fee shall be based upon a percentage (%) of the market value and type of assets placed under the Registrant’s management (between negotiable and 2.00%) as follows:
| Market Value of Portfolio | % of Assets |
|---|---|
| Initial $500,000 | 2.00% |
| Next $500,000 | 1.50% |
| Amounts over $1,000,000 | Negotiable |
B. Clients may elect to have the Registrant’s advisory fees deducted from their custodial account. Both Registrant’s Investment Advisory Agreement and the custodial/clearing agreement may authorize the custodian to debit the account for the amount of the Registrant’s investment advisory fee and to directly remit that management fee to the Registrant in compliance with regulatory procedures. In the limited event that the Registrant bills the client directly, payment is due upon receipt of the Registrant’s invoice. The Registrant shall deduct fees and/or bill clients quarterly in advance, based upon the market value of the assets on the last business day of the previous quarter.
C. As discussed below, unless the client directs otherwise or an individual client’s circumstances require, the Registrant shall generally recommend that Fidelity Investments, Inc. (“Fidelity”) or Charles Schwab (“Schwab”) serve as the broker-dealer/custodian for client investment management assets. Broker-dealers such as Fidelity and Schwab may charge brokerage commissions and/or transaction fees for effecting certain securities transactions (i.e. transaction fees are charged for certain no-load mutual funds, commissions may be charged for individual equity and fixed income securities transactions). In addition to Registrant’s investment management fee, brokerage commissions and/or transaction fees, 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).
D. Registrant’s annual investment advisory fee shall be prorated and paid quarterly, in advance, based upon the market value of the assets on the last business day of the previous quarter. The Registrant does not generally require an annual minimum fee or asset level for investment advisory services. The Registrant, in its sole discretion, may charge a lesser investment management fee 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, negotiations with client, etc.).
The Investment Advisory Agreement between the Registrant 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, the Registrant shall refund the pro-rated portion of the advanced advisory fee paid based upon the number of days remaining in the billing quarter.
E. Neither the Registrant, nor its representatives accept compensation from the sale of securities or other investment products.
Neither the Registrant nor any supervised person of the Registrant accepts performance-based fees.
The Registrant’s clients shall generally include individuals, business entities, trusts, estates and charitable organizations. The Registrant does not generally require an annual minimum fee or asset level for investment advisory services. The Registrant, in its sole discretion, may charge a lesser investment management fee 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, negotiations with client, etc.).
A. The Registrant may utilize the following methods of security analysis:
The Registrant may utilize the following investment strategies when implementing investment advice given to clients:
Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by the Registrant) will be profitable or equal any specific performance level(s).
B. The Registrant’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 the Registrant must have access to current/new market information. The Registrant has no control over the dissemination rate of market information; therefore, unbeknownst to the Registrant, certain analyses may be compiled with outdated market information, severely limiting the value of the Registrant’s 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.
The Registrant’s 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, the Registrant may also implement and/or recommend – short selling and/or the use of margin. Each of these strategies has a high level of inherent risk. (See discussion below).
Short selling is an investment strategy with a high level of inherent risk. Short selling involves the selling of assets that the investor does not own. The investor borrows the assets from a third-party lender (i.e. Broker-Dealer) with the obligation of buying identical assets at a later date to return to the third party lender. Individuals who engage in this activity shall only profit from a decline in the price of the assets between the original date of sale and the date of repurchase. Conversely, the short seller will incur a loss if the price of the assets rise. Other costs of shorting may include a fee for borrowing the assets and payment of any dividends paid on the borrowed assets.
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 the Registrant 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 the Registrant 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 the Registrant. Accordingly, the decision as to whether to employ margin is left totally to the discretion of client.
C. Registrant shall generally allocate the investment management assets of its clients, among various mutual funds, exchange traded funds (ETFs) and/or investment subdivisions of variable investment products, in accordance with Registrant’s proprietary asset management programs (i.e., Conservative, Moderate and Aggressive Portfolios), whereby Registrant shall exchange and/or transfer funds owned by the client among different asset categories within the same (or different) fund family(ies) and/or ETFs, on a discretionary basis in accordance with the investment objective(s) of the client.
D. Cryptocurrency-Related Investment Risks - As part of our investment strategies, we may recommend pooled investment vehicles, such as exchange-traded funds (ETFs), trusts, or private funds, that seek to provide indirect exposure to digital assets (commonly referred to as “cryptocurrencies”), such as Bitcoin or Ethereum. We do not recommend or facilitate direct investment in cryptocurrencies, nor do we provide custody or trading services for individual digital assets.
Investments in cryptocurrency-related funds and similar vehicles involve unique and significant risks, including, but not limited to:
Due to these heightened risks, cryptocurrency-related investments may not be suitable for all clients. We generally recommend such exposure only to clients with a high-risk tolerance, a long-term investment horizon, and the financial capacity to bear the risk of significant loss. Clients should carefully consider whether such investments are appropriate in light of their investment objectives and risk profile. Each client has the opportunity to opt out of such investments.
Mutual Fund and/or Security Asset Allocation Programs - The Registrant may allocate investment management assets of its client accounts, on a discretionary basis, among one or more of its mutual fund/security asset allocation programs (i.e. Conservative, Moderate and Aggressive) as designated on the Investment Advisory Agreement. Registrant’s proprietary programs have been designed to comply with the requirements of Rule 3a-4 of the Investment Company Act of 1940. Rule 3a-4 provides similarly managed investment programs, with a non-exclusive safe harbor from the definition of an investment company. In accordance with Rule 3a-4, the following disclosure is specifically applicable to Registrant’s management of client assets:
Registrant’s annual investment management fee may be higher or lower than that charged by other investment advisers offering similar services/programs. Registrant’s investment programs may involve above-average portfolio turnover which could negatively impact upon the net after-tax gain experienced by an individual client in a taxable account.
The Registrant has not been the subject of any disciplinary actions.
A. Neither the Registrant, nor its representatives, are registered or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer.
B. Neither the Registrant, 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.
C. The Registrant has no other relationship or arrangement with a related person that is material to its advisory business.
D. The Registrant does not receive, directly or indirectly, compensation from investment advisors that it recommends or selects for its clients.
A. The Registrant maintains an investment policy relative to personal securities transactions. This investment policy is part of Registrant’s overall Code of Ethics, which serves to establish a standard of business conduct for all of Registrant’s 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, the Registrant also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by the Registrant or any person associated with the Registrant.
B. Neither the Registrant nor any related person of Registrant recommends, buys, or sells for client accounts, securities in which the Registrant or any related person of Registrant has a material financial interest.
C. The Registrant and/or representatives of the Registrant may buy or sell securities that are also recommended to clients. This practice may create a situation where the Registrant and/or representatives of the firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential 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 the Registrant 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 prior to those of the Registrant’s clients) and other potentially abusive practices.
The Registrant has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of the Registrant’s “Access Persons”. The Registrant’s securities transaction policy requires that an Access Person of the Registrant must provide the Chief Compliance Officer or his/her designee with a written report of their current securities holdings within ten (10) days after becoming an Access Person. Additionally, each Access Person must provide the Chief Compliance Officer or his/her designee with a written report of the Access Person’s current securities holdings at least once each twelve (12) month period thereafter on a date the Registrant selects; provided, however that at any time that the Registrant has only one Access Person, he or she shall not be required to submit any securities report described above.
D. The Registrant and/or representatives of the Registrant may buy or sell securities, at or around the same time as those securities are recommended to clients. This practice creates a situation where the Registrant and/or representatives of the firm are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above in Item 11 C, the Registrant has a personal securities transaction policy in place to monitor the personal securities transaction and securities holdings of each of Registrant’s Access Persons.
A. In the event that the client requests that the Registrant recommend a broker-dealer/custodian for execution and/or custodial services (exclusive of those clients that may direct the Registrant to use a specific broker-dealer/custodian), Registrant generally recommends that investment management accounts be maintained at Fidelity or Schwab. Prior to engaging Registrant to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with Registrant setting forth the terms and conditions under which Registrant shall manage the client’s assets, and a separate custodial/clearing agreement with each designated broker-dealer/custodian. Factors that the Registrant considers in recommending Fidelity or Schwab (or any other broker-dealer/custodian to clients) include historical relationship with the Registrant, financial strength, reputation, execution capabilities, pricing, research, and service. Although the commissions and/or transaction fees paid by Registrant’s clients shall comply with the Registrant’s duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where the Registrant determines, in good faith, that the commission/transaction fee 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 services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although Registrant will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker-dealer/custodian are exclusive of, and in addition to, Registrant’s investment management fee. The Registrant’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.
1. Research and Additional Benefits
Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Registrant may receive from Fidelity or Schwab (or another broker-dealer/custodian) without cost (and/or at a discount) support services and/or products, certain of which assist the Registrant to better monitor and service client accounts maintained at such institutions. Included within the support services that may be obtained by the Registrant 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 Registrant in furtherance of its investment advisory business operations.
As indicated above, certain of the support services and/or products that may be received may assist the Registrant in managing and administering client accounts. Others do not directly provide such assistance, but rather assist the Registrant to manage and further develop its business enterprise.
Registrant’s clients do not pay more for investment transactions effected and/or assets maintained at Fidelity or Schwab as a result of this arrangement. There is no corresponding commitment made by the Registrant to Fidelity or 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 as result of the above arrangement.
The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., remains available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest such arrangement may create.
2. The Registrant does not receive referrals from broker-dealers.
3. The Registrant does not generally accept directed brokerage arrangements (when a client requires that account transactions be effected through a specific broker-dealer). In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker-dealer, and Registrant will not seek better execution services or prices from other broker-dealers or be able to “batch” the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Registrant. As a result, client may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case.
Please Note: In the event that the client directs Registrant to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction may cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative clearing arrangements that may be available through Registrant.
The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., remains available to address any questions that a client or prospective client may have regarding the above arrangement.
B. To the extent that the Registrant provides investment management services to its clients, the transactions for each client account generally will be effected independently, unless the Registrant decides to purchase or sell the same securities for several clients at approximately the same time. The Registrant may (but is not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among the Registrant’s clients to mitigate 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. The Registrant shall not receive any additional compensation or remuneration as a result of such aggregation.
A. For those clients to whom Registrant provides investment supervisory services, account reviews are conducted on an ongoing basis by the Registrant’s Principals and/or representatives. All investment supervisory clients are advised that it remains their responsibility to advise the Registrant of any changes in their investment objectives and/or financial situation. All clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with the Registrant on an annual basis.
B. The Registrant may conduct account reviews on an other than periodic basis upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market corrections and client request.
C. 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 the client accounts. The Registrant may also provide a written periodic report summarizing account activity and performance.
A. As referenced in Item 12.A.1 above, the Registrant may receive an indirect economic benefit from Fidelity or Schwab. The Registrant, without cost (and/or at a discount), may receive support services and/or products from Fidelity or Schwab.
Registrant’s clients do not pay more for investment transactions effected and/or assets maintained at Fidelity or Schwab as a result of this arrangement. There is no corresponding commitment made by the Registrant to Fidelity or 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 as result of the above arrangement.
The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., remains available to address any questions that a client or prospective client may have regarding the above arrangement and any corresponding perceived conflict of interest any such arrangement may create.
B. If a client is introduced to the Registrant by either an unaffiliated or an affiliated solicitor, Registrant may pay that solicitor a referral fee in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements. Any such referral fee shall be paid solely from the Registrant’s investment management fee, and shall not result in any additional charge to the client. If the client is introduced to the Registrant by an unaffiliated solicitor, the solicitor, at the time of the solicitation, shall disclose the nature of his/her/its solicitor relationship, and shall provide each prospective client with a copy of the Registrant’s written Brochure with a copy of the written disclosure statement from the solicitor to the client disclosing the terms of the solicitation arrangement between the Registrant and the solicitor, including the compensation to be received by the solicitor from the Registrant.
The Registrant shall have the ability to have its advisory fee for each client debited by the custodian on a quarterly 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 the client accounts. The Registrant may also provide a written periodic report summarizing account activity and performance.
Please Note: To the extent that the Registrant provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by the Registrant with the account statements received from the account custodian. Please Also Note: The account custodian does not verify the accuracy of the Registrant’s advisory fee calculation.
The client can determine to engage the Registrant to provide investment advisory services on a discretionary basis. Prior to the Registrant assuming discretionary authority over a client’s account, the client shall be required to execute an Investment Advisory Agreement, naming the Registrant as the client’s attorney and agent in fact, granting the Registrant full authority to buy, sell, or otherwise effect investment transactions involving the assets in the client’s name found in the discretionary account.
Clients who engage the Registrant on a discretionary basis may, at any time, impose restrictions, in writing, on the Registrant’s discretionary authority (i.e. limit the types/amounts of particular securities purchased for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe the Registrant’s use of margin, etc.).
A. The Registrant does not vote client proxies. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets.
B. Clients will receive their proxies or other solicitations directly from their custodian. Clients may contact the Registrant to discuss any questions they may have with a particular solicitation.
A. The Registrant does not solicit fees of more than $500, per client, six months or more in advance.
B. The Registrant is unaware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments relating to its discretionary authority over certain client accounts.
C. The Registrant has not been the subject of a bankruptcy petition.
A. Please see Item 2 of Form ADV Part 2B (Brochure Supplement) for each of the Principals of Bills Asset Management.
B. Bills Asset Management does not engage in any other business activities other than giving investment advice.
C. Bills Asset Management does not charge any performance-based fees.
D. Bills Asset Management including any management person(s) has not been found liable in any arbitration claim alleging damages or in any civil, self-regulatory organization, or administrative proceeding.
E. Bills Asset Management including any management person(s) does not have any material relationship or arrangement with any issuer of securities.
Any Questions: The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., remains available to address any questions that a client or prospective client may have regarding the above disclosures and arrangements.
Bills Asset Management — Brochure Supplement
Contact: Sam C. Bills, Jr., Chief Compliance Officer
1724 Green Hills Drive, Nashville, TN 37215
This Brochure Supplement provides information about Sam C. Bills, Jr. that supplements the Bills Asset Management Brochure. Additional information about Sam C. Bills, Jr. is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 1 — Education Background and Business Experience
Sam C. Bills, Jr. was born in 1966. Mr. Bills graduated from the University of Tennessee in 1988, with a Bachelor of Science degree in Accounting and in 1989 with a Master of Science degree in Accounting. Mr. Bills has been the Co-Portfolio Manager of Bills Asset Management since March 2000.
Mr. Bills has held the designation of Certified Public Accountant (“CPA”) since 1990. CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours over a three year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. The vast majority of state boards of accountancy have adopted the AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own.
Mr. Bills has held the designation of Certified Financial Planner (CFP®) since 2001. The CFP® designation identifies individuals who have completed the mandatory examination, education, experience, and ethics requirements mandated by the CFP Board. Candidates must have at least three years of qualifying work experience that relates to financial planning. Candidates are required to hold a bachelors degree from an accredited university. CFP® candidates must pass an examination that covers over 100 financial planning topics, which broadly include: general principles of financial planning, insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. Finally, candidates have ongoing ethics requirements and oversight by the CFP Board.
Mr. Bills has been licensed to sell life insurance in the state of Tennessee since 2012. The Tennessee Department of Commerce and Insurance issues licenses to individuals that have completed the requirements as set forth in the state statutes. The state statutes include pre-licensing education requirements, fingerprint-based background checks, and the successful completion of a mandatory examination. In order to maintain the insurance license, the State requires 24 hours of continuing education every 2 years with a minimum of 3 hours in ethics training.
Item 2 — Disciplinary Information
None.
Item 3 — Other Business Activities
A. The supervised person is not actively engaged in any other investment-related businesses or occupations.
B. The supervised person is not actively engaged in any non-investment-related business or occupation for compensation.
Item 4 — Additional Compensation
None.
Item 5 — Supervision
The Registrant provides investment advisory and supervisory services in accordance with the Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with the requirements of supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act (“Act”). The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., is primarily responsible for the implementation of the Registrant’s policies and procedures and overseeing the activities of the Registrant’s supervised persons. Should an employee, independent contractor, investment adviser representative, or solicitor of the Registrant have any questions regarding the applicability/relevance of the Act, the Rules thereunder, any section thereof, or any section of the policies and procedures, he/she should address those questions with the Chief Compliance Officer. Should a client have any questions regarding the Registrant’s supervision or compliance practices, please contact Mr. Bills at (615) 371-5928.
Item 6 — Requirements for State-Registered Advisers
A. The supervised person has not been involved or found liable in any arbitration claim, civil, self-regulatory organization, or administrative proceeding.
B. The supervised person has not been the subject of any bankruptcy petition.
Bills Asset Management — Brochure Supplement
Contact: Sam C. Bills, Jr., Chief Compliance Officer
1724 Green Hills Drive, Nashville, TN 37215
This Brochure Supplement provides information about Carter N. Bills that supplements the Bills Asset Management Brochure. Additional information about Carter N. Bills is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 1 — Education Background and Business Experience
Carter N. Bills was born in 1994. Mr. Bills graduated from the University of Tennessee in 2017, with a Bachelor of Science degree in Finance and a collateral degree in Marketing. Mr. Bills joined the firm in June of 2018. Mr. Bills has been the Co-Portfolio Manager of Bills Asset Management since June 2020.
Mr. Bills has held the designation of Certified Financial Planner (CFP®) since 2020. The CFP® designation identifies individuals who have completed the mandatory examination, education, experience, and ethics requirements mandated by the CFP Board. Candidates must have at least three years of qualifying work experience that relates to financial planning. Candidates are required to hold a bachelors degree from an accredited university. CFP® candidates must pass an examination that covers over 100 financial planning topics, which broadly include: general principles of financial planning, insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning. Finally, candidates have ongoing ethics requirements and oversight by the CFP Board.
Mr. Bills has been licensed to sell life insurance in the state of Tennessee since 2020. The Tennessee Department of Commerce and Insurance issues licenses to individuals that have completed the requirements as set forth in the state statutes. The state statutes include pre-licensing education requirements, fingerprint-based background checks, and the successful completion of a mandatory examination. In order to maintain the insurance license, the State requires 24 hours of continuing education every 2 years with a minimum of 3 hours in ethics training.
Item 2 — Disciplinary Information
None.
Item 3 — Other Business Activities
A. The supervised person is not actively engaged in any other investment-related businesses or occupations.
B. The supervised person is not actively engaged in any non-investment-related business or occupation for compensation.
Item 4 — Additional Compensation
None.
Item 5 — Supervision
The Registrant provides investment advisory and supervisory services in accordance with the Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with the requirements of supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act (“Act”). The Registrant’s Chief Compliance Officer, Sam C. Bills, Jr., is primarily responsible for the implementation of the Registrant’s policies and procedures and overseeing the activities of the Registrant’s supervised persons. Should an employee, independent contractor, investment adviser representative, or solicitor of the Registrant have any questions regarding the applicability/relevance of the Act, the Rules thereunder, any section thereof, or any section of the policies and procedures, he/she should address those questions with the Chief Compliance Officer. Should a client have any questions regarding the Registrant’s supervision or compliance practices, please contact Mr. Bills at (615) 371-5928.
Item 6 — Requirements for State-Registered Advisers
A. The supervised person has not been involved or found liable in any arbitration claim, civil, self-regulatory organization, or administrative proceeding.
B. The supervised person has not been the subject of any bankruptcy petition.
Our Chief Compliance Officer is available to address any questions you may have about our Form ADV, fees, or services.
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