James River Capital Corp.
2017 Annual Disclosures

Patriot Act Notice. Important information about procedures for opening a new account:to help the government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.
What this means for you: when you open an account, we will ask you for your name, address, date of birth and other information that will allow us to identify you. We may also ask to see identifying documents.
A corporation, partnership, trust or other legal entity may need to provide other information, such as its principal place of business, local office, Employer Identification Number, Articles of Incorporation, government-issued business license, partnership agreement or trust agreement.

Changes to Account Information. We strive to maintain complete and accurate information about you and your accounts. If you believe that our records contain inaccurate or incomplete information about you, including changes in account information such as your address, financial circumstances or investment objectives, please let us know immediately. We are committed to resolving any inaccuracies as quickly as possible.

SIPC. James River Securities Corp., an affiliated Broker-Dealer of James River Capital Corp (“JRCC”), is a member of the Securities Investor Protection Corporation (“SIPC”). You may obtain information about SIPC, including the SIPC brochure, by contacting them directly at 202-371-8300 or visiting their website at www.sipc.com.

2017 Privacy Policy. James River Capital Corp. (“JRCC”) believes that protecting the privacy of investors’ nonpublic personal information (“personal information”) is of the utmost importance. Personal information is nonpublic information about a natural person investor that is personally identifiable and that JRCC obtains in connection with providing a financial product or service to an investor. For example, personal information includes information regarding an investor’s account balance and investment activity. This policy describes the personal information that JRCC collects about investors, and JRCC’s treatment of that information. JRCC collects personal information about investors from the following sources: (i) information that JRCC receives from an investor on managed account agreements or fund subscription documents and related forms (for example, name, address, Social Security number, birth date, assets, income, and investment experience); and (ii) information about an investor’s transactions with JRCC, its affiliates, or others (for example, account activity and balances). JRCC does not disclose any personal information it collects, as described above, about its customers or former customers other than in connection with the administration, processing and servicing of customer accounts and funds or to JRCC’s accountants, attorneys and auditors, or otherwise as permitted by law. JRCC restricts access to personal information it collects about an investor to its personnel who need to know that information in order to provide products or services to such investor. JRCC maintains physical, electronic and procedural controls in keeping with U.S. federal standards to safeguard investors’ nonpublic personal information.

Business Continuity Plan. JRCC plans to quickly recover and resume business operations after a Significant Business Disruption (“SBD”) and respond by safeguarding our employees and property, making a financial and operational assessment, protecting the Firm’s books and records, and allowing our customers to transact business. If you would like to receive a summary of this Plan, please ask your account representative.

Form ADV Part 2. As you may know, James River Capital Corp., the Fund’s General Partner or Sponsor, is registered as an Investment Adviser with the U.S. Securities and Exchange Commission and its latest Form ADV Part 2 is available for review at www.adviserinfo.sec.gov.  If you are interested in receiving this document by email or hard copy, please contact Laura P. McGrath, General Counsel of James River Financial Corp., by telephone at (804) 578-4508; by email at laura.mcgrath@jrfcorp.net; and/or by regular mail at 58 Broad Street Road, Manakin-Sabot, Virginia 23103.

Summary of Material Changes to Form ADV Part 2: James River’s Form ADV Part 2 was last updated in mid-2016, which reflects two new advisory funds launched by James River in 2016: James River Value Fund LLC and Summit Action Fund. These two funds are outlined in more detail in Item 4, Advisory Business.

Security Breach. JRCC shall notify any client, at no charge, if there has been a breach of the security of the adviser’s information data system following discovery of the breach. The disclosure notification shall be made in the most expedient way possible and without delay after the breach. The notification may be done by written or, electronic notice. The disclosure notification shall include but not be limited to: i) informing the owner of the data (the client) that a breach has occurred along with the date or approximate date of the breach, ii) informing the client of the nature of the breach, and iii) informing the client of the steps the adviser has taken or plans to take relating to the breach.

Complaints. All complaints should be directed to Laura P. McGrath, General Counsel of James River Financial Corp., by telephone at (804) 578-4508; by e-mail at laura.mcgrath@jrfcorp.net; and/or by regular mail at 58 Broad Street Road, Manakin-Sabot, Virginia 23103.