Exeter Investment Management is a investment adviser based in Rancho Palos Verdes, CA, that holds a 90.0/100 Fidelon TransparencyScore (57th percentile among state-registered advisers), with 1 registered advisor. Score based on public SEC and FINRA filings.
Exeter Investment Management
Exeter Investment Management · CRD #335442
A fee-only investment adviser with a clean regulatory record and fiduciary commitment.
Fidelon Fact Sheet
Exeter Investment Management is a state-registered investment adviser in Rancho Palos Verdes, CA. It has one registered advisor. It manages $27 million across 14 client accounts. It charges a yearly percentage of your account, and it does not report earning commissions. Its services include financial planning. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
4th of 15,825
state-registered advisers
Top 43%
1st of 2,392
state-registered advisers in CA
#1 ranked
1st of 4
state-registered advisers in Rancho palos verdes, CA
#1 ranked
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Does not earn commissions on product sales
What you’d pay
Your balance falls in the All accounts band, charged at 0.10%–0.20% on the full amount. The brochure files a range for this band, so the exact rate is set in your agreement.
Not included above
- • Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. Exeter Investment Management’s fees for investment advisory services are separate and distinct from custodial and execution fees charged by broker-dealers, and the expenses charged by ETFs funds to their shareholders.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| All accounts | 0.10%–0.20% |
Billed quarterly in arrears
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Fee-only compensation — no commission income reported
- Registered as investment adviser with fiduciary obligation
- No broker-dealer registration — advisory services only
- Clean regulatory record — no disclosures, arbitrations, or fines
- Transparent fee structure — charges advisory fees, no commissions
Conflict Audit
Our analysis identified 1 potential conflict of interest in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
93/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
86/100
Strong
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
Not required
This firm is not required to file a Form CRS.
Without a Form CRS, the score above cannot go over 90. A firm that gives us one is scored on the same yardstick and can earn up to 10 more points.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Management fees range from 0.1% to 0.2% (10 to 20 basis points) per annum.p. 5
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
These fees are non-negotiable.p. 5
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
The client will give written authorization permitting the Advisor to be paid directly from their account held by the custodian.p. 5
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
payable quarterly in arrearsp. 5
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer.p. 5
- Does it say how you get money back if you leave mid-period?Does not applyItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Does it explain each conflict of interest and what it could cost you?Brochure Conflict Specificity81/100
The SEC asks the brochure to name each way the firm gets paid besides your fee, what that tempts the firm to do, and what it can cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
If the firm gets research or services from a custodian or broker, does it explain them?
Research or services received from a custodian or broker (soft dollars)
- Does the brochure name this conflict where the SEC requires?CoveredItems 10/11/12.B/14
A conflict named in the right place is one the firm has thought about; one buried elsewhere is easy to miss.
Exeter Investment Management may receive proprietary research services or other products (i.e., soft dollar benefits) as a result of recommending a particular broker which may result in the client paying higher commissions than those obtainable through other brokers.p. 14
- Does it explain what this arrangement tempts the firm to do?CoveredStaff Bulletin Q11
You can only judge advice when you know which way it is being pulled.
This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution.p. 14
- Does it describe what the arrangement actually is?CoveredStaff Bulletin Q11
A conflict described in one vague sentence tells you it exists but not how it works.
This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution.p. 14
- Does it say what the firm is paid for it?Not found in the brochureStaff Bulletin Q11
The size of the payment tells you how strong the pull is.
What to askAsk how much the firm or its people receive from this arrangement in a typical year.
- Does it say how the firm comes out ahead?CoveredStaff Bulletin Q11
Benefits that are not cash, like free services or referrals, still shape advice.
The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securitiesp. 14
- Does it say what it can cost you?CoveredStaff Bulletin Q11
Every conflict has a price; the question is whether the brochure puts it in your hands.
Exeter Investment Management may receive proprietary research services or other products (i.e., soft dollar benefits) as a result of recommending a particular broker which may result in the client paying higher commissions than those obtainable through other brokers.p. 14
- Does it say how the firm keeps this conflict in check?Not assessed yetItems 10.C-D, 11.B-D, 14.A
A conflict with no control on it is left to the advisor's goodwill.
What to askAsk what the firm receives from the custodian or broker it uses for you, and whether that costs you anything.
- Hedged wording
Exeter Investment Management may receive proprietary research services or other products (i.e., soft dollar benefits) as a result of recommending a particular broker which may result in the client paying higher commissions than those obtainable through other brokers.p. 14
Do they earn commissions on products, and do they say so?Brochure Sales CompensationNot applicable
Not applicable: the brochure describes no product-sales commissions
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars100/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
The brochure answers every one of these.
- Does it list what the firm gets from brokers for free?CoveredItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and the performance of accounts; or (3) effecting securities transactions and performing functions incidental thereto.p. 14
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution.p. 14
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution.p. 14
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
If Exeter Investment Management does receive such products or services, it will follow procedures which ensure compliance with Section 28(e) of the Securities Exchange Act of 1934 or applicable state securities rules.p. 14
- Does it say whether you pay more in trading costs because of those perks?CoveredItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
Exeter Investment Management may receive proprietary research services or other products (i.e., soft dollar benefits) as a result of recommending a particular broker which may result in the client paying higher commissions than those obtainable through other brokers.p. 14
- Does it say whether every client benefits or only some?CoveredItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
Such research furnished by broker-dealers may be used to service any or all of Exeter Investment Management’s clients and may be used in connection with accounts other than those that pay commissions to the broker-dealers providing the research.p. 14
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
1 advisor
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Jacob James Saroyan | 5679597 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #335442