View Document Text
Brochure - Form ADV Part 2A
Item 1 - Cover Page
COVENANT PARTNERS
LLC
FISCAL AND INVESTMENT COUNSEL
Covenant Partners, LLC
CRD# 110137
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure provides information about the qualifications and business practices of Covenant
Partners, LLC. Any questions about the contents of this Brochure, should be directed to us at
(615) 665-1801 or All@CovenantPartnersllc.com. The information in this Brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any
state authority.
Covenant Partners, LLC is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
information about Covenant Partners, LLC also is available on the SEC’s website at
www.AdviserInfo.sec.gov.
Item 2 - Material Changes
This Brochure is prepared in the revised format required beginning in 2011. Registered
Investment Advisers are required to use this format to inform clients of the nature of advisory
services provided, types of clients served, fees charged, potential conflicts of interest and other
information. The Brochure requirements include providing a Summary of Material Changes (the
“Summary”) reflecting any material changes to our policies, practices, or conflicts of interest
made since our last required “annual update” filing. In the event of any material changes, such
Summary is provided to all clients within 120 days after our fiscal year-end. Our last annual
update was filed on March 4, 2024. Of course, the complete Brochure is available to anyone at
any time upon request.
Item 3 - Table of Contents
Page
Item 1 - Cover Page
Item 2 - Material Changes
........................................................................................................................................................................ 1
............................................................................................................................................................. 2
Item 4 - Advisory Business
Item 3 - Table of Contents .......................................................................................................................................................... 2
Item 5 - Fees and Compensation
.......................................................................................................................................................... 3
Item 6 - Performance-Based Fees and Side-By-Side Management
................................................................................................................................................. 4
Item 7 - Types of Clients
................................................................................. 6
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
............................................................................................................................................................... 6
Item 9 - Disciplinary Information
......................................................................... 6
Item 10 - Other Financial Industry Activities and Affiliations
............................................................................................................................................... 9
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
......................................................................................... 9
Item 12 - Brokerage Practices
......................... 9
Item 13 - Review of Accounts
.................................................................................................................................................... 10
Item 14 - Client Referrals and Other Compensation
................................................................................................................................................... 12
Item 15 - Custody
.......................................................................................................... 12
Item 16 - Investment Discretion
.......................................................................................................................................................................... 13
Item 17 - Voting Client Securities
................................................................................................................................................ 13
Item 18 - Financial Information
............................................................................................................................................ 13
Brochure Supplements……………………………..….……........………………………… Exhibit A
................................................................................................................................................ 14
Page 2
Item 4 - Advisory Business
General Information
Covenant Partners, LLC (“Covenant”) was formed in 1997 and provides fiscal counsel, portfolio
management, financial planning, and general consulting services to our clients.
Todd D. Glisson and J. Banks Link, as principals, own 100% of Covenant. Please see Brochure
Supplements, Exhibit A, for more information on the principal owners who formulate
investment advice, have direct contact with clients, and have discretionary authority over client
accounts.
As of December 31, 2024, Covenant managed $730,992,249 on a discretionary basis, and
$279,956,156 assets on a non-discretionary basis.
Services Provided
At the outset of each new relationship, we spend time with the client, asking questions,
discussing investment experience and overall financial situation, and reviewing various options
that are available. Based on our review, Covenant generally develops with each client:
• a financial outline based on the client’s financial circumstances, goals and risk tolerance
level (the “Financial Profile” or “Profile”); and
• appropriate investment objectives and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to its
future goals. The Investment Plan outlines the types of investments we will make on behalf of
the client to meet those goals. The Financial Profile and the Investment Plan, which may or may
not be in writing, are discussed regularly in phone calls and meetings.
Where we provide general consulting services, we will prepare an appropriate summary of the
specific project(s) to the extent necessary or advisable under the circumstances.
Individual Retirement Advice
When we are making investment recommendations to you regarding your retirement plan
account or individual retirement account, we are acting as 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 or
otherwise are compensated creates some conflicts with your financial 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) to you;
Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
Page 3
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 what is reasonable for our services; and
Give you basic information about our conflicts of interest.
Fiscal Counsel
We are available to provide Fiscal Counsel Services on a retainer basis. The services provided
may include, but are not limited to: analysis and management of personal and business income
and expenses (including bill-paying services), revenues, consumption, profitability, cash flow,
debt service, insurance needs, tax planning, estate planning, retirement planning, and payroll
services. While Covenant itself does not serve as a trustee under ERISA, the principals may
individually serve as trustee for a client in some situations. However, these trustee services do
not include a comprehensive written financial plan.
Portfolio Management
As described above, at the beginning of a new relationship, we meet with the client, gather
information and perform research and analysis as necessary to develop an appropriate Investment
Plan. The Investment Plan will be updated from time to time when requested by the client, or
when determined to be necessary or advisable by us based on updates to the client’s financial or
other circumstances.
To implement the Investment Plan, we will manage the investment portfolio on a discretionary
basis. As a discretionary investment adviser, we will have the authority to supervise and direct
the portfolio without prior consultation with the client.
Notwithstanding the foregoing, clients may prohibit the sale of certain investments held in the
account at the commencement of the relationship. However, any restrictions imposed may
adversely affect the composition and performance of the investment portfolio. Clients should
also note that the investment portfolio is treated individually by giving consideration to each
purchase or sale. For these and other reasons, performance of the investment portfolio within the
same investment objectives, goals and/or risk tolerance may differ, and clients should not expect
that the composition or performance of the investment portfolio would necessarily be consistent
with similar clients of Covenant.
Item 5 - Fees and Compensation
General Fee Information
Fees paid to us are exclusive of all custodial and transaction costs paid to account custodians,
brokers or other third-party consultants. Please see Item 12 - Brokerage Practices for additional
information. Fees paid to us are also separate and distinct from the fees and expenses charged by
mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s
prospectus or offering materials). Clients should review all fees charged by funds, brokers,
Covenant and others to fully understand the total amount of fees paid for investment and
financial-related services.
Page 4
Fiscal Counsel Fees
Our Fiscal Counsel fees are individually determined, based on the nature and complexity of
services, project time and effort, and other circumstances that may be identified. Fees are agreed
upon at the time of the engagement, and may be payable in advance or arrears, depending upon
specific arrangements with each client. We do, however, have the unrestricted right to re-
evaluate the fees charged at any time. Should the services to be provided by us deviate
significantly due to a change in a client’s financial condition or investment situation, additional
information that comes to light, or new services are requested, additional fees may apply. We
will not engage in services resulting in additional fees without prior notice to the client.
Portfolio Management Fees
The annual fee schedule, based on a percentage of assets under management, is as follows:
On the first $1 million
On the next $4 million
On the next $10 million
On the balance over $15 million
1.25%
0.70%
0.60%
0.45%
We may impose a minimum portfolio value and/or a minimum annual fee. We may, at our
discretion, make exceptions to the foregoing or negotiate special fee arrangements where we
deem appropriate under the circumstances. For example, selection and monitoring of private
investments (i.e., private funds, private equity) may be billed on a fixed fee basis as opposed to
being included in the portfolio value to which the fee schedule is applied.
The Base Fee for Portfolio Management Fees is payable quarterly and assessed in advance. Fees
are prorated for new accounts, accounts closing and capital flows into or out of the portfolio.
The Base Fee is calculated by applying the applicable fee tiers to the value of the Portfolio at the
end of the prior quarter, including accrued interest on fixed income securities. The applicable fee
tier(s) will also be applied to any capital flows into or out of the Portfolio. .
As an illustration of the impact of capital flows on a portfolio during the third
quarter, the Base Fee for the fourth quarter will be calculated based on the value of
the Portfolio on September 30. Therefore, the total fee assessed for the fourth
quarter will reflect the Base Fee for the fourth quarter and any applicable prorated
capital flow fee adjustments for the third quarter.
For accounts that open or close mid-quarter, the same proration methodology is
applied, so that fees are only paid for the number of days that Covenant is
responsible for managing funds in the portfolio.
Fees are rounded to the nearest whole dollar amount. With client authorization and unless other
arrangements are made, fees are normally debited directly from one or more designated
account(s). All fee arrangements are outlined in our written agreement(s).
For clients who choose to hold a margin balance at any time, Covenant calculates the advisory
fee on the total market value of the client’s gross investment holdings, with no deduction taken
for outstanding margin debt.
Page 5
Either the client or Covenant may terminate the Investment Advisory Agreement at any time,
subject to any written notice requirements in the agreement. In the event of termination, any
paid but unearned fees will be promptly refunded based on the number of days that the account
was managed, and any fees due to us will be invoiced or deducted from the account prior to
termination.
Trustee Fees
Covenant does not serve as a trustee under ERISA rules. However, the two principals, Todd
Glisson and/or Banks Link, are periodically named individually as trustees in certain situations.
Examples include serving as trustee for a Grantor Retained Annuity Trust (“GRAT”), for an
Irrevocable Life Insurance Trust (“ILIT”), or for a Revocable or Irrevocable Trust.
Compensation is paid in accordance with any guidelines enumerated in the applicable trust
document(s), and based upon competitive market rates.
Item 6 - Performance-Based Fees and Side-By-Side Management
We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to
a situation in which a firm manages accounts that are billed based on a percentage of assets
under management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because we have no performance-based fee accounts, we have no side-
by-side management.
Item 7 - Types of Clients
We serve individuals, high net worth individuals, and trusts. In certain circumstances, we serve
privately held business entities and estates.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
In accordance with the Investment Plan, we generally select mutual funds, ETFs, limited
partnership interests in private real estate, and private investments. We will select and manage a
portfolio of individual equity securities at client request only. At times we will invest client
assets through a unified managed account (“UMA”). UMAs provide access to holding
individual equity and fixed income securities overseen and directed by professional portfolio
managers (authorized by the client) in much the same way those managers allocate and rebalance
a mutual fund.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors,
including, without limitation, past performance, fee structure, portfolio manager, fund sponsor,
overall ratings for safety and returns, and other factors.
When appropriate for client circumstances, we provide advice and recommendations related to
illiquid pooled investment partnerships (private investments). The principals of Covenant may
also invest in one or more of the offerings that are recommended to clients, but Covenant and its
principals have not and will not receive compensation on the basis of recommending such
investments. We will use our good faith efforts to apprise clients of the risk level of such
investments, and to help clients understand the nature of the investment. This information will
Page 6
be disclosed for consideration at the time partnership investments are recommended. Clients are
also welcome to seek an independent third-party opinion when considering an investment in
these or any other partnership investment.
Investment Strategies
Investment strategies used to implement investment advice are generally long-term in nature and
primarily utilize a “buy and hold” philosophy. Investment strategies may include short-term
purchases depending upon the client’s individual needs and objectives. All proposed investment
strategies are closely evaluated in advance, so that our strategies are in keeping with stated
investment policy or directives.
At Covenant Partners, we work with clients to invest their portfolio for long-term growth,
designed to meet each client’s goals and objectives. In order to accomplish this, we apply the
concept of strategic asset allocation, which simply means diversifying investments among a
number of asset classes, such as: domestic stocks as well as a meaningful level of foreign stocks;
large cap stocks and small cap stocks in both domestic and foreign securities; and fixed income
securities in the form of corporate bonds as well as government-backed securities. We usually
invest client assets into three primary “sleeves” of investment types.
We use publicly traded investments, such as mutual funds and Exchange Traded Funds
(“ETFs”) as the primary driver for the portfolio’s capital growth and appreciation.
In order to meet planned liquidity needs, we will establish an appropriate reserve
allocation. This allocation is held in one or more money market funds or very short-term
debt funds to provide assurance that these funds will be available whenever called upon.
The top priority for the reserve allocation is capital preservation, with the secondary goal
of earning whatever income is available from these secure investments.
Finally, we utilize private investments in order to take advantage of targeted or boutique
investment opportunities. Private investments are also generally less correlated to the
stock market, so their inclusion provides another avenue for diversification in a portfolio.
At its heart, strategic asset allocation seeks to achieve an efficient distribution of assets given
current market conditions, to help lessen risk while not sacrificing the effectiveness of the
portfolio in an effort to achieve the client’s stated objectives.
We endeavor to be conscious of tax-related investment considerations. However, we are not a
tax advisory firm and do not provide tax services. Clients are encouraged to seek the guidance of
a tax professional in an effort to understand how proposed or implemented investments will
affect their overall tax situation.
Risk of Loss
While we seek to diversify clients’ investment portfolios across various asset classes consistent
with the established Investment Plan in an effort to maintain the portfolio’s long-term purchasing
power, all investment portfolios are subject to risks. Accordingly, there can be no assurance that
an investment portfolio will be able to fully meet the client’s investment objectives and goals, or
that investments will not lose money.
Page 7
Below is a description of several of the principal risks that investment portfolios face.
Management Risks. While we manage client investment portfolios based on our experience,
research and proprietary methods, the value of all investment portfolios will change daily based
on the performance of the underlying securities in which they are invested. Accordingly,
investment portfolios are subject to the risk that we allocate assets to individual securities and/or
asset classes that are adversely affected by unanticipated market movements, and the risk that
our specific investment choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above,
we will invest client portfolios in mutual funds, ETFs and other pooled investment funds.
Investments in pooled investment funds are generally less risky than investing in individual
securities because of their diversified portfolios; however, these investments are still subject to
risks associated with the markets in which they invest. In addition, pooled investment funds’
success will be related to the skills of their particular managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory
restrictions applicable to registered investment companies under the Investment Company Act of
1940.
Equity Market Risks. We may invest portions of client portfolios directly into equity
investments, primarily in pooled investment funds that invest in the stock market. As noted
above, while pooled investments have diversified portfolios that may make them less volatile
than investments in individual securities, funds that invest in stocks and other equity securities
are nevertheless subject to the risks of the stock market. These risks include, without limitation,
the risks that stock values will decline due to daily fluctuations in the markets, and that stock
values will decline over longer periods (e.g., bear markets) due to general market declines in the
stock prices for all companies, regardless of any individual security’s prospects.
Fixed Income Risks. We may invest portions of client accounts directly into fixed income
instruments, such as bonds and notes, or may invest in pooled investment funds that invest in
bonds and notes. While investing in fixed income instruments, either directly or through pooled
investment funds, is generally less volatile than investing in stock (equity) markets, fixed income
investments nevertheless are subject to risks. These risks include, without limitation, interest
rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of
default by borrowers), or maturity risk (risks that bonds or notes will change value from the time
of issuance to maturity).
into
individual foreign securities and/or pooled
investment funds
that
Foreign Securities Risks. We believe a meaningful allocation to foreign securities is an
important part of most investment portfolios. Therefore, we generally invest a portion of client
assets
invest
internationally. While foreign investments are important to the diversification of an investment
portfolio, they carry risks that may be different from U.S. investments. For example, foreign
investments may not be subject to uniform audit, financial reporting or disclosure standards,
practices or requirements comparable to those found in the U.S. Foreign investments are also
subject to foreign withholding taxes and the risk of adverse changes in investment or exchange
control regulations. Finally, foreign investments may involve currency risk, which is the risk
Page 8
that the value of the foreign security will decrease due to changes in the relative value of the U.S.
dollar and the security’s underlying foreign currency.
Liquidity Risks. We may invest portions of client assets into pooled investment funds that invest
in securities with limited liquidity. While many equity and fixed income investment strategies
involve securities with daily liquidity, some investment strategies important to overall portfolio
diversification invest in securities that are limited in the liquidity they provide. When investing
in pooled funds of private equity, privately owned real estate, or other alternative strategies,
client assets may not be accessible for periods of months or years. This “lock up” period is
described in the offering documents of the investments. The possibility that a client desires to
exit the investment because of dissatisfaction with performance or a need for personal liquidity is
a primary risk of investing in illiquid assets. Covenant does not fair value any securities. With
respect to private fund investments, we rely on each manager to determine the value of each of
their investments for billing and performance calculation purposes. Managers may provide
different types of statements for valuation purposes, such as Schedule K-1, capital statements
(which are then adjusted by capital calls and/or distributions of principle), pricing provided to
account custodian, or other means determined by the Manager.
Item 9 - Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client’s evaluation of Covenant or the integrity of
our management. We have no disciplinary events to report.
Item 10 - Other Financial Industry Activities and Affiliations
Neither Covenant nor our Management Persons have any other financial industry activities or
affiliations to report.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available upon request.
Our Code has several goals. First, the Code is designed to assist us in complying with applicable
laws and regulations governing our investment advisory business. Under the Investment
Advisers Act of 1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties,
the Code requires persons associated with us (managers, officers and employees) to act with
honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits such
associated persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for our associated persons. Under
the Code’s Professional Standards, we expect our associated persons to put the interests of our
clients first, ahead of personal interests. In this regard, our associated persons are not to take
inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. Our associated persons may invest in the same securities
Page 9
recommended to clients. Under our Code, we have adopted procedures designed to reduce or
eliminate conflicts of interest that this could potentially cause. The Code’s personal trading
policies include procedures for limitations on personal securities transactions of associated
persons, reporting and review of such trading and pre-clearance of certain types of personal
trading activities. These policies are designed to discourage and prohibit personal trading that
would disadvantage clients. The Code also provides for disciplinary action as appropriate for
violations.
Participation or Interest in Client Transactions
Because client accounts are invested almost exclusively in open-end mutual funds and ETFs,
there is little opportunity for a conflict of interest between personal trades by our associated
persons and trades in client accounts, even when such accounts invest in the same securities.
However, in the event of other identified potential trading conflicts of interest, our goal is to
place client interests first.
Consistent with the foregoing, we maintain policies regarding participation in initial public
offerings (“IPOs”) and private placements in order to comply with applicable laws and avoid
conflicts with client transactions. If an associated person wishes to participate in an IPO or
invest in a private placement, he or she must submit a pre-clearance request and obtain the
approval of the Chief Compliance Officer.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade),
and the trade is not filled in its entirety, the associated person’s shares will be included in the
block, with the shares allocated among client and associated person accounts in accordance with
our written policies.
Item 12 - Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, we
seek “best execution” for client trades, which is a combination of a number of factors, including,
without limitation, quality of execution, services provided and commission rates. Therefore, we
may use or recommend the use of brokers who do not charge the lowest available commission in
the recognition of research and securities transaction services, or quality of execution. Research
services received with transactions may include proprietary or third party research (or any
combination), and may be used in servicing any or all of our clients. Therefore, research
services received may not be used for the account for which the particular transaction was
effected.
We recommend that investment management clients establish one or more brokerage accounts
with Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer, member SIPC,
as the qualified custodian to maintain custody of the managed assets. We may also execute
trades for clients’ accounts at Schwab, or may in some instances, consistent with our duty to seek
best execution and specific agreement with clients, elect to execute trades elsewhere. Although
we may recommend that clients establish an account at Schwab, it is ultimately each client’s
decision to custody assets with Schwab. We are independently owned and operated and are not
affiliated with Schwab.
Page 10
Schwab Advisor Services provides us with access to its institutional trading, custody, reporting
and related services, which are typically not available to Schwab retail investors. Schwab also
makes available various support services. Some of those services help us manage or administer
our clients’ accounts while others help us manage and grow our business. These services
generally are available to independent investment advisors on an unsolicited basis, at no charge
to them. These services are not soft dollar arrangements but are part of the institutional platform
offered by Schwab. Schwab’s brokerage services include the execution of securities
transactions, custody, research, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly
higher minimum initial investment.
For our client accounts maintained in its custody, Schwab generally does not charge separately
for custody services but is compensated by account holders through transaction fees or other fees
on trades that it executes or that settle into client accounts. Certain trades may not incur Schwab
commissions or transaction fees. Schwab is also compensated by earning interest on the
uninvested cash in client accounts. Schwab Advisor Services also makes available to us other
products and services that benefit us but may not directly benefit our clients’ accounts. Many of
these products and services may be used to service all or a substantial number of our accounts,
including accounts not maintained at Schwab.
Schwab’s products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide pricing and other market data; (iv)
facilitate payment of our fees from our clients’ accounts; and (v) assist with back-office
functions, recordkeeping and client reporting.
Schwab Advisor Services also offers other services intended to help us manage and further
develop our business enterprise. These services may include: (i) technology, compliance, legal
and business consulting; (ii) publications and conferences on practice management and business
succession; and (iii) access to employee benefits providers, human capital consultants and
insurance providers. Schwab may make available, arrange and/or pay third-party vendors for the
types of services rendered to us. Schwab Advisor Services may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party
providing these services to us. Schwab Advisor Services may also provide other benefits such as
educational events or occasional business entertainment of our personnel. In evaluating whether
to recommend that clients custody their assets at Schwab, we may take into account the
availability of some of the foregoing products and services and other arrangements as part of the
total mix of factors it considers and not solely on the nature, cost or quality of custody and
brokerage services provided by Schwab, which may create a potential conflict of interest.
We recommend that clients who retain Covenant for Fiscal Counsel Services open one or more
accounts with Pinnacle Financial Partners (“Pinnacle”), an FDIC-insured bank holding company.
Although we may recommend that clients establish an account at Pinnacle, it is ultimately each
client’s decision to custody assets with Pinnacle. We are independently owned and operated and
are not affiliated with Pinnacle.
Page 11
Directed Brokerage
We do not generally allow directed brokerage accounts.
Aggregated Trade Policy
We typically direct trading in individual client accounts as and when trades are appropriate based
on the client’s Investment Plan, without regard to activity in other client accounts. However,
from time to time, Covenant may aggregate trades together for multiple client accounts. If such
an aggregated trade in public securities is not completely filled, we will allocate shares received
(in an aggregated purchase) or sold (in an aggregated sale) across participating accounts on a pro
rata or other fair basis. Such allocation will include the accounts of any associated persons who
participated in the original trade. For private investments, where the amount of interest of our
clients in an offering exceeds the amount available, we allocate the available amount equally per
person. To the extent any client prefers to buy less than the per-person allocation, their excess
allocation is re-allocated to other clients on a pro rata basis.
Item 13 - Review of Accounts
The holdings in client portfolios are reviewed on a regular basis. Upon receipt of information
from clients that is material to the management of the portfolio, or at any time such review is
deemed necessary or advisable by us, the client’s specific asset allocation is reviewed relative to
that client’s specific circumstances. These factors generally include but are not limited to, the
following: change in general circumstances (marriage, divorce, retirement); or economic,
political or market conditions. Todd Glisson or Banks Link, Covenant’s Principals, review all
accounts.
For those clients to whom we provide separate Fiscal Counsel and/or consulting services,
reviews are conducted on an as needed or agreed upon basis. Such reviews are conducted by one
of Covenant’s principals.
Account custodians are responsible for providing, directly to each client, monthly or quarterly
account statements which reflect the positions (and current pricing) in each account, as well as
transactions in each account, including fees paid from an account. Account custodians also
provide prompt confirmation of all trading activity and year-end tax statements, such as 1099
forms. In addition, we provide at least an annual report for each managed portfolio. This written
report normally includes a summary of portfolio holdings and performance results. Additional
reports are available upon request.
Item 14 - Client Referrals and Other Compensation
As noted above, we receive an economic benefit from Schwab in the form of support products
and services it makes available to us and other independent investment advisors whose clients
maintain accounts at Schwab. These products and services, how they benefit our firm, and the
related conflicts of interest are described in Item 12 - Brokerage Practices. The availability of
Schwab’s products and services to us is based solely on our participation in the programs and not
on the provision of any particular investment advice. Neither Schwab nor any other party is paid
to refer clients to us.
Page 12
Item 15 - Custody
Schwab is the custodian of nearly all client investment accounts at Covenant. From time to time,
however, clients may select an alternate broker to hold accounts in custody. In any case, it is the
custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and
at least quarterly account statements. Clients are advised to review this information carefully,
and to notify us of any questions or concerns. Clients are also asked to promptly notify us if the
custodian fails to provide statements on each account held.
From time to time and in accordance with our written agreement, we will provide additional
reports. The account balances reflected on these reports should be compared to the balances
shown on the brokerage statements to ensure accuracy. At times there may be small differences
due to the timing of income reporting, pending trades or other similar issues.
Although we do not maintain physical custody of client investment funds or securities, we are
deemed to have constructive custody of client funds when Covenant’s principals have signatory
authority on client checking accounts for the purpose of paying clients’ bills, when clients
provide us with their own personal login credentials to access various accounts for reporting or
other purposes, or when one for our principals serves as Trustee, Executor or in a similar
capacity. Where we do have custody of client funds, the funds owned by each client are
maintained in the bank(s) chosen by the client, in an account(s) registered in the name of each
individual client. No client funds are ever held in any name other than that of the client. No
client funds are ever pooled or commingled with other client funds, with funds of any officer or
employee of ours, or with the firm’s funds. Further, we comply with the Securities and
Exchange Commission’s requirement that Advisers with custody engage an independent
Certified Public Accountant to conduct an annual surprise examination on a sampling of
accounts for which we maintain custody.
Item 16 - Investment Discretion
As described above under Item 4 - Advisory Business, we manage portfolios on a discretionary
basis. This means that after an Investment Plan is developed for an investment portfolio, we will
execute that plan without specific consent from the client for each transaction. For discretionary
accounts, a Limited Power of Attorney (“LPOA”) is executed by the client, giving us the
authority to carry out various activities in the account, generally including the following: trade
execution; the ability to request checks that are made payable to the client and mailed to the
address of record; and the withdrawal of advisory fees directly from one or more designated
accounts. We then direct investment of the portfolio using our discretionary authority. Clients
may limit the terms of the LPOA to the extent consistent with the investment advisory agreement
with us and the requirements of the account custodian. The discretionary relationship is further
described in the agreement between the client and Covenant.
Item 17 - Voting Client Securities
As a policy and in accordance with our client agreement, we do not vote proxies related to
securities held in client accounts. The custodian of the account will normally provide proxy
materials directly to the account holder of record. Clients may contact us with questions relating
Page 13
to proxy procedures and proposals; however, we generally do not research particular proxy
proposals.
Item 18 - Financial Information
We do not require nor solicit prepayment of more than $1,200 in fees per client six months or
more in advance, and therefore, have no disclosure required for this item.
Page 14
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Todd D. Glisson, CFP®
CRD# 2505847
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Todd Glisson, and supplements the
Covenant Partners, LLC (“Covenant”) Brochure. You should have received a copy of that Brochure.
Please contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Todd is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Todd D. Glisson (year of birth 1969) is a Co-Founder and Partner of Covenant. Before forming
Covenant in 1997, Todd was a Registered Representative with Lincoln Financial (1994-1997),
where he managed personal and business client relationships, advising on comprehensive financial
matters. Todd was a Corporate Credit Analyst with SunTrust Bank (1992-1994), where he
completed a two-year management training program and also analyzed existing and prospective
corporate lending relationships for Senior Bankers.
Todd received his Bachelor of Business Administration degree from Millsaps College in Jackson, MS.
In 1997, he became a CERTIFIED FINANCIAL PLANNER™ professional*. He is a member of the Financial
Planning Association.
Todd is an active member of West End Community Church. He served on the Franklin Road
Academy Board of Trustees (1997-2007) and served as President of the Franklin Road Academy
Alumni Association Board (1992-1996). He served on the board of St. Paul Christian Academy from
Exhibit A-1
2009 to 2015 and in the role of Vice-Chairman (2010-2012). Todd has served on the Millsaps
College Board of Visitors since 2013.
*
®
The CFP
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
such as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit
Certification Examination. A comprehensive examination tests the candidate’s ability
for the CFP
to apply financial planning knowledge to client situations. Qualifying work experience is also
required for certification. Qualifying experience includes work in the area of the delivery of the
personal financial planning process to clients, the direct support or supervision of others in the
personal financial planning process, or teaching all, or any portion, of the personal financial
professionals must complete 30 hours of continuing education accepted by
planning process. CFP
CFP Board every two years.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Todd has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Todd is not engaged in any other business activities.
Item 6 - Supervision
Todd has no other income or compensation to disclose.
As a Managing Member of Covenant, Todd, along with Banks Link, supervises all duties and
activities of the firm. His contact information is on the cover page of this disclosure document.
Exhibit A-2
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
J. Banks Link, CFA®
CRD# 4373794
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Banks Link, and supplements the Covenant
Partners, LLC (“Covenant”) Brochure. You should have received a copy of that Brochure. Please
contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Banks is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
J. Banks Link (year of birth 1969) is a Co-Founder and Partner of Covenant. Before forming
Covenant in 1997, Banks was an Investment Portfolio Manager with SunTrust Bank (1992-1997),
where he managed institutional and personal investment portfolio accounts totaling more than
$100 million in assets and also completed a two-year management training program.
Banks graduated Magna Cum Laude receiving his Bachelor of Business Administration degree from
®
Millsaps College in Jackson, Mississippi. In 1996, he earned the Chartered Financial Analyst
designation*. He was a Board Member of the CFA Society of Nashville and served as its Secretary
(1999), Treasurer (2000), Vice President (2001), and President (2002) during his tenure. Banks
also served as a CFA Exam Grader for the Association of Investment Management & Research
(“AIMR”) (1997-2003).
Exhibit A-3
Banks served as a Board Member of The Oak Hill School and served as its Treasurer (2006 & 2007)
and Chairman (2008-2011). He also served on the Montgomery Bell Academy Alumni Board of
Directors. Banks served as both an Elder and a Deacon at First Presbyterian Church in Nashville,
and has previously served as Chairman on its Committee on Stewardship (2001 & 2005). Banks has
served on the Millsaps College Board of Visitors since 2013.
®
®
(“CFA
”) designation is a professional designation given by the
* The Chartered Financial Analyst
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and
security analysis. Before a candidate is eligible to become a CFA charter holder, he/she must meet
minimum experience requirements in the area of investment/financial practice. To enroll in the
program, a candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Banks has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Banks is not engaged in any other business activities.
Item 6 - Supervision
Banks has no other income or compensation to disclose.
As a Managing Member of Covenant, Banks, along with Todd Glisson, supervises all duties and
activities of the firm. His contact information is on the cover page of this disclosure document.
Exhibit A-4
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Jennifer D. Anderson, CFP®
CRD# 7521029
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Jennifer D. Anderson, and supplements the
Covenant Partners, LLC (“Covenant”) Brochure. You should have received a copy of that Brochure.
Please contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Jennifer is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Jennifer D. Anderson (year of birth 1983) joined Covenant in 2022 as an Associate Wealth Advisor.
Prior to joining the firm, she served as a Senior Financial Executive at Inflammo, LLC (2018-2021),
a self-employed accountant (2016-2021) and a Financial Consultant for Apex Revenue
Technologies (2016-2018). From 2010 to 2014, Jennifer held the position of Vice-President of
Finance at LetterLogic, Inc., and she served as their Chief Financial Officer from 2014 to 2016.
Jennifer received a Bachelor of Science in Business Administration in 2005, and a Master of
Accountancy in 2006, both from the University of Tennessee. In 2023, she became a CERTIFIED
FINANCIAL PLANNER™ professional*.
*
®
The CFP
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
Exhibit A-5
®
®
such as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit
Certification Examination. A comprehensive examination tests the candidate’s ability
for the CFP
to apply financial planning knowledge to client situations. Qualifying work experience is also
required for certification. Qualifying experience includes work in the area of the delivery of the
personal financial planning process to clients, the direct support or supervision of others in the
personal financial planning process, or teaching all, or any portion, of the personal financial
professionals must complete 30 hours of continuing education accepted by
planning process. CFP
CFP Board every two years.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Jennifer has no such disciplinary
information to report.
Item 4 - Other Business Activities
Item 5 - Additional Compensation
Jennifer is not engaged in any other business activities.
Item 6 - Supervision
Jennifer has no other income or compensation to disclose.
The Managing Members of Covenant, Todd Glisson and Banks Link, supervise all duties and
activities of the firm. Their contact information is on the cover page of this disclosure document.
Exhibit A-6
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Andrew E. Wood, CFA®
CRD# 6210366
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Andrew (“Andy”) Wood, and supplements
the Covenant Partners, LLC (“Covenant”) Brochure. You should have received a copy of that
Brochure. Please contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you
have any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Andy is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Andrew E. Wood (year of birth 1993) joined Covenant in 2021 as a Portfolio Strategist. Prior to
joining the firm, he was an Investment Analyst for Merrill Lynch (2019-2021) and from 2015 to
2018 he served in various roles, including Portfolio Associate, at U.S. Trust, now known as Bank of
America Private Bank. He also served as a Private Wealth Management Intern while attending
college.
®
Andy received a Bachelor of Science in Finance and a Bachelor of Arts in Economics in 2015 from
designation*
the University of Texas at Dallas. In 2019, he earned the Chartered Financial Analyst
and is a member of the Nashville CFA Society.
®
®
(“CFA
* The Chartered Financial Analyst
”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and
security analysis. Before a candidate is eligible to become a CFA charter holder, he/she must meet
Exhibit A-7
minimum experience requirements in the area of investment/financial practice. To enroll in the
program, a candidate must hold a bachelor’s degree.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Andy has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Andy is not engaged in any other business activities.
Andy has no other income or compensation to disclose.
Item 6 - Supervision
The Managing Members of Covenant, Todd Glisson and Banks Link, supervise all duties and
activities of the firm. Their contact information is on the cover page of this disclosure document.
Exhibit A-8
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Samuel J. Martin, CFA®
CRD# 6574185
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Samuel (“Sam”) Martin, and supplements
the Covenant Partners, LLC (“Covenant”) Brochure. You should have received a copy of that
Brochure. Please contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you
have any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Sam is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Samuel J. Martin (year of birth 1994) joined Covenant in 2021 as a Portfolio Strategist. Prior to
joining the firm, he served as an Assistant Vice President for Callan, LLC (2020-2021). From 2016 to
2020, he was Performance Analyst, and later an Investment Analyst at LCG Associates.
®
Sam received a Bachelor of Science in Business Administration 2016 from the University of
Tennessee. In 2021, he earned the Chartered Financial Analyst
designation* and is a member of
the Nashville CFA Society.
®
®
(“CFA
* The Chartered Financial Analyst
”) designation is a professional designation given by the
CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is
a graduate-level self-study program that combines a broad-based curriculum of investment
principles with professional conduct requirements. Candidates are required to pass three levels of
examinations covering areas such as accounting, economics, ethics, money management and
security analysis. Before a candidate is eligible to become a CFA charter holder, he/she must meet
minimum experience requirements in the area of investment/financial practice. To enroll in the
program, a candidate must hold a bachelor’s degree.
Exhibit A-9
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Sam has no such disciplinary
information to report.
Item 4 - Other Business Activities
Sam is not engaged in any other business activities.
Item 5 - Additional Compensation
Item 6 - Supervision
Sam has no other income or compensation to disclose.
The Managing Members of Covenant, Todd Glisson and Banks Link, supervise all duties and
activities of the firm. Their contact information is on the cover page of this disclosure document.
Exhibit A-10
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Serena (“Macy”) M. Rickman, CFP®
CRD# 7114923
of
Covenant Partners, LLC
3811 Bedford Avenue
Suite 201
Nashville, Tennessee 37215
(615) 665-1801
www.CovenantPartnersLLC.com
March 3, 2025
This Brochure Supplement provides information about Serena (“Macy”) Rickman, and supplements
the Covenant Partners, LLC (“Covenant”) Brochure. You should have received a copy of that
Brochure. Please contact Covenant at (615) 665-1801 if you did not receive our Brochure, or if you
have any questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Macy is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Serena (“Macy”) M. Rickman (year of birth 1998) joined Covenant in 2023 as an Associate Wealth
Advisor. Prior to joining the firm, she served as a Tax Planning Associate at Robert W. Baird &
Company (2020-2023). While attending the University of Tennessee, she served as a Financial
Advisor intern (2019).
In 2020, Macy received two Bachelor of Science degrees, one in Accounting, another in Finance,
both from the University of Tennessee at Martin. She became a CERTIFIED FINANCIAL PLANNER™
professional* in 2022.
*
®
The CFP
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
such as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit
for the CFP
Certification Examination. A comprehensive examination tests the candidate’s ability
Exhibit A-11
®
to apply financial planning knowledge to client situations. Qualifying work experience is also
required for certification. Qualifying experience includes work in the area of the delivery of the
personal financial planning process to clients, the direct support or supervision of others in the
personal financial planning process, or teaching all, or any portion, of the personal financial
professionals must complete 30 hours of continuing education accepted by
planning process. CFP
CFP Board every two years.
Item 3 - Disciplinary Information
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Macy has no such disciplinary
Item 4 - Other Business Activities
information to report.
Item 5 - Additional Compensation
Macy is not engaged in any other business activities.
Macy has no other income or compensation to disclose.
Item 6 - Supervision
The Managing Members of Covenant, Todd Glisson and Banks Link, supervise all duties and
activities of the firm. Their contact information is on the cover page of this disclosure document.
Exhibit A-12