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Part 2A of Form ADV: Firm Brochure
GSG Advisors LLC
East Gate Corporate Center
307 Fellowship Road, Suite 210
Mt. Laurel, NJ 08054
Telephone: 856-396-6196
Email: JGREER@GSGADVISORS.COM
Web Address: WWW.GSGADVISORS.COM
March 28, 2025
This brochure provides information about the qualifications and business
practices of GSG Advisors LLC.
If you have any questions about the contents of this brochure, please contact us
at 856-396-6196 or JGREER@GSGADVISORS.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 GSG Advisors LLC also is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique
identifying number, known as a CRD number. Our firm's CRD number is
131511.
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Item 2 Material Changes
This Firm Brochure, dated as set forth above, is our most recent disclosure document
prepared according to the SEC’s requirements and rules.
GSG Advisors filed its last amendment with the SEC in March of 2024.
GSG Advisors has made the following material changes to this Brochure:
Item 5: GSG removed the lower end of its fee range. And change the minimum fee from
planning services to $10,000.
Item 10: GSG added the following new entities to Item 10: Ocean Opportunity Investment LLC
(Ocean), CADI Investment LLC (CADI), and HEEL Ventures LLC (HEEL).
We will ensure that you receive a summary of any material changes to this and subsequent
Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will
provide you with other interim disclosures about material changes as necessary.
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Item 3 Table of Contents
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Item 1 Cover Page
Item 2 Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Fiduciary Duty, Participation or Interest in Client
Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
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Item 4 Advisory Business
GSG Advisors LLC is a SEC-registered investment adviser with its principal place of business
located in New Jersey. GSG Advisors LLC began conducting business in 2002.
Listed below are the firm's principal (i.e., those individuals and/or entities controlling 25% or
more of this company) and only shareholders:
• Jon Michael Greer, Principal
• Joseph Edward Scocca, Principal
• Christopher Matthew Greer, Principal
GSG provides investment advisory services primarily to high net worth individuals, families
and closely held companies. GSG also offers its services to other entities for which they may
be appropriate including trusts and estates, and not-for-profit organizations. GSG receives no
compensation for providing investment advice from any source other than the advisory fees of
its clients.
GSG Advisors LLC offers the following advisory services to our clients:
INVESTMENT SUPERVISORY SERVICES ("ISS")
Our firm provides continuous advice to a client regarding the investment of client funds based
on the individual needs of the client. Through personal discussions in which goals and
objectives based on a client's particular circumstances are established, we develop a client's
personal investment policy and create and manage a portfolio based on that policy. During
our data-gathering process, we determine the client’s individual objectives, time horizons, risk
tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior
investment history, as well as family composition and background. GSG will seek to
recommend an appropriately diversified portfolio to clients. GSG does not typically
recommend individual stocks and/or bonds but under certain circumstances they may. GSG
usually recommends or selects third party independent managers for such decisions.
We manage these advisory accounts on a discretionary or non-discretionary basis. Account
supervision is guided by the client's stated objectives (i.e., maximum capital appreciation,
capital preservation, growth, income, or growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of
securities, or industry sectors.
Our investment recommendations are not limited to any specific product or service offered by
a broker-dealer or insurance company and will generally include advice regarding the
following securities:
• Exchange-listed securities including exchange traded funds/notes or “ETFs” or “ETNs”;
• Separately managed accounts;
• Securities traded over-the-counter;
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• Foreign issuers;
• Warrants;
• Corporate debt securities (other than commercial paper);
• Commercial paper;
• Certificates of deposit;
• Municipal securities;
• Variable life insurance;
• Variable annuities;
• Mutual fund shares;
• United States governmental securities;
• Options contracts on securities; and
• Interests in partnerships investing in real estate and in oil and gas interests.
Because some types of investments involve certain additional degrees of risk, they will only
be implemented/recommended when consistent with the client's stated investment objectives,
tolerance for risk, liquidity and suitability.
GSG will review each client portfolio at a minimum on a quarterly basis, and as necessary
recommend changes in investments, allocations and rebalancing. For cash balance plans,
reviews are conducted at least annually.
SEPARATE ACCOUNT MANAGERS
When preparing our investment strategy for our clients, GSG Advisors LLC may recommend
or select separate account managers (which may include a Manager of Manager program)
which may be incorporated with the other investment solutions listed above. Based on the
client's individual circumstances and needs we determine which separate account manager's
portfolio management style is appropriate for that client. Factors considered in making this
determination include account size, risk tolerance, the opinion of each client and the
investment philosophy of the selected asset manager.
Once we identify the most appropriate asset manager(s), our firm provides the selected
adviser with the client's personal background, risk tolerance, investment objectives, who then
creates and manages the client's portfolio based on that information. We monitor such
managers as we monitor other investment options recommended for or directed in a client’s
portfolio.
On an ongoing basis, we monitor the performance of the asset manager(s). If we determine
that a particular adviser is not providing sufficient management services to the client, or is not
managing the client's portfolio in a manner consistent with that client's goals and objectives,
then we may move the client’s portfolio to a different asset manager and/or program sponsor.
Under this scenario, our firm retains the discretion to hire and fire the asset manager
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and/or move the client’s portfolio to a different program.
At least annually, we meet with the client to review and update, as necessary, the client’s
goals and objectives. However, should there be any material change in the client's personal
and/or financial situation, we should be notified immediately to determine whether any review
and/or revision of the client's Personal Investment Advisory Statement is warranted.
PENSION CONSULTING SERVICES
(Cash Balance Plans)
We also provide several advisory services separately or in combination. While the primary
clients for these services will be defined benefit and defined contribution (i.e. cash balance
plans)-services are typically provided at the plan level to the trustees of the retirement plan.
We offer these services, where appropriate, to small businesses, individuals and trusts,
estates and charitable organizations. Pension Consulting Services are comprised of four
distinct services. Clients may choose to use any or all of these services.
We will meet with the client (in person or over the telephone) to determine an appropriate
investment strategy that reflects the plan sponsor's stated investment objectives for
management of the overall plan. Our firm will work with the client to determine goals and a
plan on how to achieve those objectives.
Selection of Investment Vehicles:
We assist plan sponsors in constructing appropriate asset allocation models. We will then
review various investment vehicles to determine which investments are appropriate to
achieve the client's objectives.
Monitoring of Investment Performance:
We monitor client investments continually, based on the procedures and timing intervals
delineated in the Investment Policy Statement, if any. Although our firm is not involved in any
way in the purchase or sale of these investments, we supervise the client's portfolio and will
make recommendations to the client as market factors and the client's needs dictate.
FINANCIAL PLANNING
We provide financial planning services. Financial planning is a comprehensive evaluation of a
client’s current and future financial state by using currently known variables to predict future
cash flows, asset values and withdrawal plans. Through the financial planning process, all
questions, information and analysis are considered as they impact and are impacted by the
entire financial and life situation of the client. Clients purchasing this service receive a written
report which provides the client with a detailed financial plan designed to assist the client
achieve his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and
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financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for
past, current and future years; then illustrate the impact of various investments on the
client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, health,
disability, long-term care, liability, home and automobile.
• RETIREMENT: We analyze current strategies and investment plans to help the client
achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of
surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including
as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection
plans, nursing homes, Medicaid and elder law.
• BUSINESS SUCCESSION PLANNING: Analysis of various strategies and financial impact
for transferring business to family members and/or outsiders. Buy-Sell planning and
funding analysis.
• EDUCATION AND BUDGETING NEEDS: Analysis of various funding and capital needs for
education needs and planning and overall budgeting needs.
• QUALIFIED AND NON-QUALIFIED: Analysis of qualified and non-qualified benefit planning
needs.
We gather required information through in-depth personal interviews. Information gathered
includes the client's current financial status, tax status, future goals, returns objectives and
attitudes towards risk. We carefully review documents supplied by the client, including a
questionnaire completed by the client, and prepare a written report. Should the client choose
to implement the recommendations contained in the plan, we suggest the client work closely
with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of
financial plan recommendations is entirely at the client's discretion.
Following the completion of a plan, clients may engage GSG or related entities for the
implementation of all or a portion of recommendations presented in their financial plan,
however, clients are never obligated to use services provided by GSG or related
entitles/persons. A client considering use GSG or related entities for such services should
consider that GSG may reduce or waive financial planning fees for such clients.
We provide general advice on those types of securities listed above in the Investment
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Supervisory Services section. We also provide general non-securities advice on topics that
may include tax and budgetary planning, estate planning and business planning matters.
Typically the financial plan is presented to the client within six months of the contract date,
provided that all information needed to prepare the financial plan has been promptly provided.
Financial Planning recommendations are not limited to any specific product or service offered
by a broker-dealer or insurance company. Most recommendations are of a generic nature,
however, more specific recommendations may be offered to clients.
Following the completion of a financial plan and if agreed to by both GSG and the client, GSG
may be engaged on an annual flat fee basis. GSG will provide the following services in
connection with such a flat fee engagement. Clients will have access to a personalized
wealth management website providing clients with a comprehensive view of certain client
financial information. Such information shall be based on information provided to GSG by the
Client. Inclusion of information on the website is limited to the capabilities of the website. The
website may include details on a client’s financial information, daily aggregation of a client’s
investment accounts, if available, and document storage. Such retainer clients will also
receive an annual updated financial plan at the end of each anniversary year for which GSG
is engaged on a flat fee basis. Generally, access to GSG staff will be limited to the annual
updated report service. This flat fee relationship, however, may also provide for additional
conferences and access to GSG’s staff during the year if provided for in the engagement
contract, however, additional services will cause the fee to increase. Fees may vary based on
the amount of client assets supervised by GSG, the number of meetings during a given year
that are agreed to by the parties, the nature of the portfolio, complexity of client’s needs,
specific client reporting requests and other factors.
CONSULTING SERVICES
Clients can also receive investment advice on a more focused basis. This may include advice
on only an isolated area(s) of concern such as estate planning, retirement planning, or any
other specific topic. We also provide specific consultation and administrative services
regarding investment and financial concerns of the client.
Consulting recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. All recommendations are of a generic nature.
WEALTH MANAGEMENT WEBSITE
If agreed to by both GSG and client, clients may also have access to a personalized wealth
management website providing clients with certain financial information. Such information
shall be based on information provided to GSG by the Client. Inclusion of information on the
Website may be limited to the capabilities of the Website. The Website may include details on
a client’s financial information, daily aggregation of a client’s investment accounts, if available,
and document storage.
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AMOUNT OF MANAGED ASSETS
As of January 21, 2025, GSG was actively managing $642,784,542 of clients' assets on a
discretionary basis plus $72,022,986 of clients' assets on a non-discretionary basis.
Item 5 Fees and Compensation
INVESTMENT SUPERVISORY SERVICES ("ISS")
FEES
The annualized fees for Investment Supervisory Services are typically charged on a flat
annual rate basis or as a percentage of assets under management (AUM). The following is
the upper end of the fee schedule that is also used as a guide and one data point for
determining flat rate fees:
AUM
Annual Fee
First 1.0 mill
1.50%
Next 1.0 mill
1.00%
Next 1.0 mill
0.90%
Next 2.5 mill
0.70%
Next 2.5 mill
0.50%
Next 2.5 mill
0.30%
Next 5 mill
0.25%
Next 5 mill
0.15%
Next 5 mill
0.10%
A minimum of approximately $500,000 of assets under management is required for this
service. This account size may be negotiable under certain circumstances. GSG Advisors
LLC may group certain related client accounts for the purposes of achieving the minimum
account size and determining the annualized fee.
All annual fixed fees are discussed and agreed to by the parties and are based on the nature
of the services being provided and the complexity of each client’s circumstances. Such fees
are typically billed on a quarterly basis. All fees are agreed upon prior to entering into a
contract with any client.
Limited Negotiability of Advisory Fees: Although GSG Advisors LLC has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a
client-by-client basis. Client facts, circumstances and needs are considered in determining
the fee schedule. These include the complexity of the client, assets to be placed under
management, anticipated future additional assets; related accounts; portfolio style, account
composition, reporting needs, among other factors. The specific annual fee schedule is
identified in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum
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account size requirements and determining the annualized fee. Client cash and cash
equivalent assets may be included in calculating the fee.
Discounts, not generally available to our advisory clients, may be offered to family members
and friends of associated persons of our firm.
PENSION CONSULTING FEES
Our fees for Pension Consulting Services are typically charged on a flat annual rate basis or
as a percentage of assets under management (AUM). The following is the upper end of the
fee schedule that is also used as a guide and one data point for determining flat rate fees: on
a percentage of assets under advisement (AUM), according to the following schedule:
Annual Fee
AUM
First 1.0 mill
1.50%
Next 1.0 mill
1.00%
Next 1.0 mill
0.90%
Next 2.5 mill
0.70%
Next 2.5 mill
0.50%
Next 2.5 mill
0.30%
Next 5.0 mill
0.25%
Next 5.0 mill
0.15%
Next 5.0 mill
0.10%
GSG Advisors LLC offers several fee options. GSG Advisors LLC may be compensated
based on an annual percentage of plan assets for services involving ongoing reviews, or it
may be compensated by a flat fee. Alternatively, these different types of fees may also be
combined as appropriate for the different types of services requested by the client.
Typically, the annual fee ranges as a percentage of plan assets (see table above) depending
on the services requested and the size of the plan. Fees will be based upon the value of the
plan at the end of the quarterly period. Fees will not be adjusted based on additions and
withdrawals during the calendar quarter.
A fixed fee may be quoted based on time an effort for the service requested. GSG Advisors
LLC may request a retainer for fixed fee arrangements. The retainer amount will not exceed
the fee for services to be provided within the first six months of an engagement.
A typical total minimum fee of about $10,000 may be required. This minimum fee may prevent
GSG Advisors LLC from providing services to very small ERISA plans.
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FINANCIAL PLANNING FEES
GSG Advisors LLC's financial planning fee is determined based on the nature of the services
being provided and the complexity of each client’s circumstances. All fees are agreed upon
prior to entering into a contract with any client.
Our Financial Planning fees are calculated and charged on a fixed fee basis, typically ranging
from $10,000 to $50,000, depending on the specific arrangement reached with the client.
We may request a retainer upon completion of our initial fact-finding session with the client;
however, advance payment will never exceed $500 for work that will not be completed within
six months. The balance is due upon completion of the plan.
Financial Planning Fee Offset: GSG Advisors LLC reserves the discretion to reduce or
waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to
engage us for our Portfolio Management Services.
The client is billed quarterly in arrears based on actual hours accrued.
CONSULTING SERVICES FEES
GSG Advisors LLC's Consulting Services fee is determined based on the nature of the
services being provided and the complexity of each client’s circumstances. All fees are
agreed upon prior to entering into a contract with any client.
Our Consulting Services fees are calculated and charged on a fixed fee basis, typically
ranging from $10,000 to $50,000 subject to the specific arrangement reached with the client.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any
time, by either party, for any reason upon receipt of written notice. As disclosed above, certain
fees are paid in advance of services provided. Upon termination of any account, any prepaid,
unearned fees will be promptly refunded. In calculating a client’s reimbursement of fees, we
will pro rate the reimbursement according to the number of days remaining in the billing
period.
Mutual Fund Fees: All fees paid to GSG Advisors LLC for investment advisory services are
separate and distinct from the fees and expenses charged by mutual funds, ETFs and/or
other commingled vehicles to their shareholders. These fees and expenses are described in
each fund's prospectus. These fees will generally include a management fee, other fund
expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may
pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without
our services. In that case, the client would not receive the services provided by our firm which
are designed, among other things, to assist the client in determining which mutual fund or
funds are most appropriate to each client's financial condition and objectives. Accordingly, the
client should review both the fees charged by the funds and our fees to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory services
being provided.
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Wrap Fee Programs and Separately Managed Account Fees: Clients participating in
separately managed account programs may be charged various program fees in addition to
the advisory fee charged by our firm. Such fees may include the investment advisory fees of
the independent advisers, which may be charged as part of a wrap fee arrangement. In a
wrap fee arrangement, clients pay a combined fee for advisory, brokerage and custodial
services and may also pay other fees such as “trade away fees” in an effort to obtain best
execution. Client’s portfolio transactions may be executed without commission charge in a
wrap fee arrangement. In evaluating such an arrangement, the client should also consider
that, depending upon the level of the wrap fee charged by the broker-dealer, the amount of
portfolio activity in the client’s account, and other factors, the wrap fee may or may not exceed
the aggregate cost of such services if they were to be provided separately. We will review
with clients any separate program fees that may be charged to clients in addition to the fees
charged by our firm.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible
for the fees and expenses charged by custodians and imposed by broker dealers, including,
but not limited to, any transaction charges imposed by a broker dealer with which an
independent investment manager effects transactions for the client's account(s). Please refer
to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients may be
subject to GSG Advisors LLC's minimum account requirements and advisory fees in effect at
the time the client entered into the advisory relationship. Therefore, our firm's minimum
account requirements and fees may differ among clients.
ERISA Accounts: GSG Advisors LLC is deemed to be a fiduciary to advisory clients that are
employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee
Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue
Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and
obligations under ERISA and the Internal Revenue Code that include among other things,
restrictions concerning certain forms of compensation. To avoid engaging in prohibited
transactions, GSG Advisors LLC may only charge fees for investment advice about products
for which our firm and/or our related persons do not receive any commissions or 12b-1 fees,
or conversely, investment advice about products for which our firm and/or our related persons
receive commissions or 12b-1 fees, however, only when such fees are used to offset GSG
Advisors LLC's advisory fees.
Advisory Fees in General: Clients should note that similar advisory services may (or may
not) be available from other registered (or unregistered) investment advisers for similar or
lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of
fees in excess of $1,200 more than six months in advance of services rendered.
Item 6 Performance-Based Fees and Side-By-Side Management
GSG Advisors LLC does not charge performance-based fees.
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Item 7 Types of Clients
GSG Advisors LLC provides advisory services to the following types of clients:
• Individuals (other than high net worth individuals),
• High net worth individuals,
• Closely held companies, and
• Pension and profit-sharing plans (other than plan participants – cash balance plans).
As previously disclosed in Item 5, our firm has established certain initial minimum account
requirements, based on the nature of the service(s) being provided. For a more detailed
understanding of those requirements, please review the disclosures provided in each
applicable service.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
Asset Allocation and Portfolio Structure. Rather than focusing primarily on securities
selection, our first focus is to identify the appropriate asset allocation level. We will identify
the appropriate ratio of equity, fixed income, and cash (or cash alternatives) suitable to the
client’s investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular
security, industry or market sector. Another risk is that the ratio of equities, fixed income, and
cash will change over time due to stock and market movements and, if not corrected, will no
longer be appropriate for the client’s goals. Market fluctuations and discussions with the
client may or may not warrant an investment change depending on the client’s overall
situation and circumstances.
Mutual Fund and/or ETFs/ETNs/Structured Products Analysis. We look at the
experience and track record of the manager of the mutual fund, ETF/ETN or structured
product in an attempt to determine if that manager has demonstrated an ability to invest over
a period of time and in different economic conditions. We also look at the underlying assets in
a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying
investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs
in an attempt to determine if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not
be able to replicate that success in the future. In addition, as we do not control the underlying
investments in a fund, ETF or other investment vehicle, managers of different funds held by
the client may purchase the same security, increasing the risk to the client if that security
were to fall in value. There is also a risk that a manager may deviate from the stated
investment mandate or strategy of the fund or ETF, which could make the holding(s) less
suitable for the client’s portfolio.
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Third-Party Money Manager Analysis (Separate Account Managers). We examine the
experience, expertise, investment philosophies, and past performance of independent third-
party investment managers in an attempt to determine if that manager has demonstrated an
ability to invest over a period of time and in different economic conditions. We will utilize the
information provided by many of the program sponsors to help evaluate the managers.
A risk of investing with a third-party manager who has been successful in the past is that
he/she may not be able to replicate that success in the future. In addition, as we do not
control the underlying investments in a third-party manager’s portfolio, there is also a risk that
a manager may deviate from the stated investment mandate or strategy of the portfolio,
making it a less suitable investment for our clients. Moreover, as we do not control the
manager’s daily business and compliance operations, we may be unaware of the lack of
internal controls necessary to prevent business, regulatory or reputational deficiencies.
Risks for all forms of analysis. Our securities and Separate Account Manager analysis
methods rely on the assumption that the companies whose securities we purchase and sell,
the rating agencies that review these securities, and other publicly-available sources of
information about these securities, are providing accurate and unbiased data. While we are
alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
Other: Client Defined. GSG will discuss with our clients any and all specific client
investment restrictions and incorporate them in to our clients’ investment plans.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such
strategy(ies) are appropriate to the needs of the client and consistent with the client's
investment objectives, risk tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the client's
account for a year or longer. Typically we employ this strategy when:
• we believe the securities to be currently undervalued, and/or
• we want exposure to a particular asset class over time, regardless of the current projection
for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time,
we may not take advantage of short-term gains that could be profitable to a client. Moreover,
if our predictions are incorrect, a security may decline sharply in value before we make the
decision to sell.
Margin transactions. Margin accounts allow clients to borrow against their investment
portfolios. This allows clients to withdraw funds or to purchase additional investments without
the need to sell other holdings. If applicable to the client, we utilize this strategy to help
clients more efficiently manage their debt, short-term cash needs and/or address other
issues.
Option writing. We may use options as an investment strategy. An option is a contract that
gives the buyer the right, but not the obligation, to buy or sell an asset (such as a share of
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stock) at a specific price on or before a certain date. An option, just like a stock or bond, is a
security. An option is also a derivative, because it derives its value from an underlying asset.
The two types of options are calls and puts:
• A call gives us the right to buy an asset at a certain price within a specific period of time. We
will buy a call if we have determined that the stock will increase substantially before the
option expires.
• A put gives us the holder the right to sell an asset at a certain price within a specific period
of time. We will buy a put if we have determined that the price of the stock will fall before
the option expires.
We may use options to "hedge" a purchase of the underlying security; in other words, we will
use an option purchase to limit the potential upside and downside of a security we have
purchased for your portfolio.
We may use "covered calls", in which we sell an option on security you own. In this strategy,
you receive a fee for making the option available, and the person purchasing the option has
the right to buy the security from you at an agreed-upon price.
Risk of Loss. Securities investments are not guaranteed and you may lose money on your
investments. We ask that you work with us to help us understand your tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or
prospective client's evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Our firm and our related persons are not engaged in other financial industry activities and
have no other industry affiliations. The principals of GSG hold various professional licenses
and offer additional services to GSG's advisory clients as stand alone services and also to
assist with the implementation of the financial planning and investment services. The primary
business activities of GSG's principal's shall consist of providing its advisory services to
clients. As much as 5% to 30% of their business time, however, may consist of the various
business activities described below. Each of these activities is provided for separate and
distinct compensation from GSG's advisory services. Clients are under no obligation to
engage GSG's affiliated persons/entities for these additional services.
Greer, Scocca & Lau LLC (GSL)
Jon Greer and Joseph Scocca are Partners in the law firm of Greer Scocca & Lau LLC. Their
practice of law focuses on estate planning, real estate and general corporate matters. The
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implementation of advisory recommendations by GSG may require legal services, particularly
including the preparation of legal documents (including will and trusts). The receipt of fees
related to GSG's advisory recommendations creates a conflict of interest, however, clients are
not under any obligation to engage GSL when considering implementation of advisory
recommendations. All conflicts are disclosed to the client. During any given week, Joe
Scocca may devote approximately 5% to 20% of his time to GSL and Jon Greer may devote
approximately 5% to 20% of his time to GSL.
Valens Group LLC (VG)
GSG owns 100% of VG and the Managers of GSG are also officers of VG, an insurance
agency, and individually licensed in several different states to sell life, health, disability and
long-term care insurance products and annuity products through numerous insurance
carriers. Insurance products may be recommended to advisory clients of GSG as part of a
financial plan, or to other advisory clients on a case-by-case basis, including product
recommendations to qualified and/or nonqualified benefit plans. These individuals may
receive separate, yet customary commission compensation resulting from implementing
product transactions on behalf of advisory clients. The receipt of commissions related to
GSG's advisory recommendations creates a conflict of interest, however, clients are not under
any obligation to engage these individuals when considering implementation of advisory
recommendations. The implementation of any or all recommendations is solely at the
discretion of the client. During any given week, Joe Scocca may devote approximately 5% to
10% of his time to VG and Jon Greer may devote approximately 0% to 5% of his time to VG
and Chris Greer may devote approximately 0% to 5% of his time to VG.
Real Estate Agent
Jon Greer is also a licensed real estate agent. He may provide services to clients and receive
normal and customary real estate commissions. He may also share commissions with a real
estate agent or broker to whom he introduces a client. All conflicts, if any, are disclosed to
the client. During any given week, Jon Greer may devote approximately 0% to 5% of his time
as a real estate agent.
Sage Ventures LLC (Sage)
The Managers of GSG are also managers of or work with Sage Ventures LLC, a limited
liability company that engages in real estate and other venture investment transactions. At
times, Sage may act as a general partner of another partnership or limited liability company
that invests in real estate ventures or other investment vehicles. Clients of GSG may be
offered the opportunity to invest in such investment partnerships (where Sage is a general
partner) and the managers of GSG may earn fees associated with such investment
partnerships. The receipt of such fees related to GSG's advisory recommendations creates a
conflict of interest. During any given week, Joe Scocca may devote approximately 0% to
10% of his time to Sage and Jon Greer may devote approximately 10% to 30% of his time to
Sage.
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HEEL Ventures LLC (HEEL)
The Managers of GSG are also managers of or work with HEEL Ventures LLC, a limited
liability company that engages in Private Equity (PE) and other venture investment (VI)
transactions. At times, HEEL may act as a general partner of another partnership or limited
liability company that invests in PE ventures or other investment vehicles. Clients of GSG
may be offered the opportunity to invest in such investment partnerships (where HEEL is a
general partner) and the managers of GSG may earn fees associated with such investment
partnerships. The receipt of such fees related to GSG's advisory recommendations creates a
conflict of interest. During any given week, Joe Scocca may devote approximately 0% to
10% of his time to HEEL and Chris Greer may devote approximately 10% to 30% of his time
to HEEL.
FHGA Investment LLC (FHGA); SWR Investment LLC (SWR), PSS Investment LLC
(PSS) & WBC Investment LLC (WBC)
Sage Ventures LLC (the Members of GSG Advisors are also members of or work with Sage)
is the manager of FHGA Investment LLC (FHGA), SWR Investment LLC (SWR), PSS
Investment LLC (PSS) and WBC Investment LLC (WBC), which are real estate investment
entities. GSG does not provide investment advice to these entities. GSG may recommend
these entities to its advisory clients, however, GSG does not itself receive a fee from such
entities. Sage, however, does charge fees to the entities. The recommendation of investing
in such entities, therefore has an inherent conflict of interest. While GSG could recommend
other investments and charge a management fee, the fees that the members may ultimately
receive from a client's investment in these entities may be higher or lower than those fees
depending on the ultimate performance of these entities. All clients must evaluate such
investments themselves based on each entity’s private offering memoranda and GSG will
have no authority to direct the investment of a client's assets into such entities. All conflicts
are disclosed to the client. During any given week, Joe Scocca may devote approximately
0% to 5% of his time to such entities and Jon Greer may devote approximately 5% to 30% of
his time to such entities and Chris Greer may devote approximately 0% to 5% of his time to
such entities.
Ocean Opportunity Investment LLC (Ocean) and CADI Investment LLC (CADI)
HEEL Ventures LLC (HEEL) is the manager of Ocean Opportunity Investment LLC (Ocean)
and CADI Investment LLC (CADI), which are Private Equity investment entities. GSG does
not provide investment advice to these entities. GSG may recommend these entities to its
advisory clients, however, GSG does not itself receive a fee from such entities. HEEL,
however, does charge fees to the entities. The recommendation of investing in such entities,
therefore, has an inherent conflict of interest. While GSG could recommend other
investments and charge a management fee, the fees that the members may ultimately
receive from a client's investment in these entities may be higher or lower than those fees
depending on the ultimate performance of these entities. All clients must evaluate such
investments themselves based on each entity’s private offering memoranda and GSG will
have no authority to direct the investment of a client's assets into such entities. All conflicts
are disclosed to the client. During any given week, Joe Scocca may devote approximately
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0% to 5% of his time to such entities and Chris Greer may devote approximately 10% to 30%
of his time to such entities.
Item 11 Code of Ethics, Fiduciary Duty; Participation or Interest in Client
Transactions and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business
conduct that we require of our employees, including compliance with applicable federal
securities laws.
GSG Advisors LLC and our personnel owe a fiduciary duty to our clients when providing
investment advice and recommendations, and have an obligation to adhere not only to the
specific provisions of the Code of Ethics but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities
transactions reports as well as initial and annual securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics also requires
the prior approval of any acquisition of securities in a limited offering (e.g., private placement)
or an initial public offering. Our code also provides for oversight, enforcement and
recordkeeping provisions.
GSG Advisors LLC's Code of Ethics further includes the firm's policy prohibiting the use of
material non-public information. While we do not believe that we have any particular access to
non-public information, all employees are reminded that such information may not be used in
a personal or professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You
may request a copy by email sent to JGREER@GSGADVISORS.COM, or by calling us at
856-396-6196.
As disclosed in the preceding section of this Brochure (Item 10), the principals of GSG
Advisors LLC are also the principals of Sage Ventures LLC, a limited liability company that
engages in real estate and other venture investment transactions. At times, Sage may act as
a general partner of another partnership or limited liability company that invests in real estate
ventures or other investment vehicles such as those listed above. Clients of GSG may be
offered the opportunity to invest in such investment partnerships (where Sage is a general
partner) and the managers of GSG may earn fees associated with such investment
partnerships. The receipt of such fees related to GSG's advisory recommendations creates a
conflict of interest. GSG's members, officers and employees will devote as much time to
such investment vehicles as we deem necessary and appropriate to manage such business.
GSG does not provide investment advice to Sage Ventures LLC. GSG Advisors LLC and our
affiliates are not restricted from forming additional investment funds or engaging in other
business activities, even though such activities may be in competition with the other
investment vehicles and/or may involve substantial time and resources of our firm and our
affiliates.
Investments in the real estate entities listed above or other similar investment vehicles may
be recommended to advisory clients for whom a partnership investment may be suitable.
Clients who invest in such investment vehicles are not charged any additional fees other than
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the stated fees associated with such investment vehicles for all limited partners in such
vehicles.
The real estate entities listed above are not required to register as an investment company
under the Investment Company Act of 1940 in reliance upon an exemption available to funds
whose securities are not publicly offered.
As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm
are (i) separately licensed as an insurance agent/broker of various insurance companies, (ii)
separately licensed as a real estate agent of a real estate company, and (iii) partners in a law
firm. Please refer to Item 10 for a detailed explanation of these relationships and important
conflict of interest disclosures.
Item 12 Brokerage Practices
For discretionary clients, GSG Advisors LLC requires these clients to provide us with written
authority to determine the broker dealer to use and the commission costs that will be charged
to these clients for these transactions.
These clients must include any limitations on this discretionary authority in this written
authority statement. Clients may change/amend these limitations as required. Such
amendments must be provided to us in writing.
GSG Advisors LLC will endeavor to select those brokers or dealers which will provide the best
services at the lowest commission rates possible. The reasonableness of commissions is
based on the broker's stability, reputation, ability to provide professional services, competitive
commission rates and prices, research, trading platform, and other services which will help
GSG Advisors LLC in providing investment management services to clients. GSG Advisors
LLC may, therefore recommend (or use) the use of a broker who provides useful research
and securities transaction services even though a lower commission may be charged by a
broker who offers no research services and minimal securities transaction assistance.
Research services may be useful in servicing all our clients, and not all of such research may
be useful for the account for which the particular transaction was effected.
Consistent with obtaining best execution for clients, GSG Advisors LLC may direct brokerage
transactions for clients' portfolios to brokers who provide research and execution services to
GSG Advisors LLC and, indirectly, to GSG Advisors LLC's clients. These services are of the
type described in Section 28(e) of the Securities Exchange Act of 1934 and are designed to
augment our own internal research and investment strategy capabilities. This may be done
without prior agreement or understanding by the client (and done at our discretion). Research
services obtained through the use of soft dollars may be developed by brokers to whom
brokerage is directed or by third-parties which are compensated by the broker. GSG Advisors
LLC does not attempt to put a specific dollar value on the services rendered or to allocate the
relative costs or benefits of those services among clients, believing that the research we
receive will help us to fulfill our overall duty to our clients. GSG Advisors LLC may not use
each particular research service, however, to service each client. As a result, a client may pay
brokerage commissions that are used, in part, to purchase research services that are not
used to benefit that specific client. Broker-dealers we select may be paid commissions for
effecting transactions for our clients that exceed the amounts other broker-dealers would
have charged for effecting these transactions if GSG Advisors LLC determines in good faith
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that such amounts are reasonable in relation to the value of the brokerage and/or research
services provided by those broker-dealers, viewed either in terms of a particular transaction or
our overall duty to its ('brokerage') discretionary client accounts.
Certain items obtainable with soft dollars may not be used exclusively for either execution or
research services. The cost of such "mixed-use" products or services will be fairly allocated
and GSG Advisors LLC makes a good faith effort to determine the percentage of such
products or services which may be considered as investment research. The portions of the
costs attributable to non-research usage of such products or services are paid by our firm to
the broker-dealer in accordance with the provisions of Section 28(e) of the Securities
Exchange Act of 1934.
When GSG Advisors LLC uses client brokerage commissions to obtain research or brokerage
services, we receive a benefit to the extent that GSG Advisors LLC does not have to produce
such products internally or compensate third-parties with our own money for the delivery of
such services. Therefore, such use of client brokerage commissions results in a conflict of
interest, because we have an incentive to direct client brokerage to those brokers who
provide research and services we utilize, even if these brokers do not offer the best price or
commission rates for our clients.
Within our last fiscal year, we have not obtained any products and services on a soft-dollar
basis.
As a matter of policy and practice, GSG Advisors LLC does not generally block client trades
and, therefore, we implement client transactions separately for each account. Consequently,
certain client trades may be executed before others, at a different price and/or commission
rate. Additionally, our clients may not receive volume discounts available to advisers who
block client trades.
GSG Advisors LLC may recommend that clients establish brokerage accounts with the
Schwab Institutional division of Charles Schwab & Co., Inc. ("Schwab"), a FINRA registered
broker-dealer, member SIPC, to maintain custody of clients' assets and to effect trades for
their accounts. Although we recommend that clients establish accounts at Schwab, it is the
client's decision to custody assets with Schwab. GSG Advisors LLC is independently owned
and operated and not affiliated with Schwab.
Schwab provides GSG Advisors LLC with access to its institutional trading and custody
services, which are typically not available to Schwab retail investors. These services generally
are available to independent investment advisers on an unsolicited basis, at no charge to
them so long as a total of at least $10 million of the adviser's clients' assets are maintained in
accounts at Schwab Institutional. These services are not contingent upon our firm committing
to Schwab any specific amount of business (assets in custody or trading commissions).
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 commissions
and other transaction-related or asset-based fees for securities trades that are executed
20
through Schwab or that settle into Schwab accounts.
Schwab Institutional also makes available to our firm other products and services that benefit
GSG Advisors LLC but may not directly benefit our clients' accounts. Many of these products
and services may be used to service all or some substantial number of our client accounts,
including accounts not maintained at Schwab.
Schwab's products and services that assist us in managing and administering our 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 research, pricing and other market data;
iv. facilitate payment of our fees from clients' accounts; and
v. assist with back-office functions, recordkeeping and client reporting.
Schwab Institutional also offers other services intended to help us manage and further
develop our business enterprise. These services may include:
i. 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 GSG Advisors LLC. Schwab Institutional 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 our firm. Schwab Institutional may also provide other benefits such
as educational events or occasional business entertainment of our personnel. In evaluating
whether to recommend or require 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 we consider 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.
GSG Advisors LLC's receipt of Additional Services does not diminish our duty to act in the
best interests of our clients, including seeking best execution of trades for client accounts.
In some instances, GSG might recommend money managers within a Manager of Manager’s
Program (wrap fee program). In a wrap fee program, a client may pay one fee for advisory
services, the execution of a client's transactions, and custodial services, however, additional
fees may also be charge to the client, including “trade away” fees used to try to obtain best
execution. In evaluating such an arrangement, a client should recognize that brokerage
commissions for the execution of transactions in the client's account are effected 'net,' i.e.,
without commission, and a portion of the wrap fee is generally considered as being in lieu of
commissions. Managers in such programs generally execute all transactions through a broker
dealer which sponsors the wrap fee program because of the absence of separate commission
21
costs. Managers might execute client transactions away from the sponsoring broker only if the
manager believes that other factors associated with achieving best execution outweigh the
additional transactions costs that may be incurred. When investing through a wrap fee
program, it should be considered that, depending upon the level of the wrap fee charged by
the broker dealer, the amount of portfolio activity in the client's account, the value of custodial
and other services which are provided under the arrangement, and other factors, the wrap fee
may or may not exceed the aggregate cost of such services if they were to be provided
separately. GSG will evaluate such factors in making recommendations to clients.
Item 13 Review of Accounts
INVESTMENT SUPERVISORY SERVICES ("ISS")
REVIEWS: While the underlying securities within Individual Portfolio Management Services
accounts are continually monitored, these accounts are reviewed at least quarterly, some
annual retainer-based clients may have accounts reviewed less frequently, however, at a
minimum annually). Accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic
environment and potential cash flow needs.
These accounts are reviewed by: Chris Greer, Principal
REPORTS: In addition to the monthly statements and confirmations of transactions that
clients receive from their broker-dealer, we provide quarterly reports summarizing account
balances and holdings. As part of the annual review, GSG shall prepare for the client a
performance (in connection with the applicable custodian/investment manager may prepare
the performance report) and asset allocation reports regarding the client’s investments.
Clients may also request additional specific reporting information.
MANAGER OF MANAGERS
REVIEWS: If utilized, the performance of the registered investment adviser(s) selected to
manage client portfolios within a Manager of Managers program is continually monitored by
GSG Advisors LLC. Furthermore, accounts within this program are formally reviewed at least
quarterly. More frequent reviews may be triggered by material changes in variables such as
the client’s individual circumstances, or the market, political/economic environment or
manager changes.
These accounts are reviewed by: Chris Greer, Principal
REPORTS: In addition to the monthly statements and confirmations of transactions that these
clients receive from their respective broker-dealer, the asset manager(s) selected by GSG
Advisors LLC to manage the client’s portfolio(s) within the Manager of Managers Program
provides the client with written quarterly performance reports. We may provide performance
22
reporting during review meetings (if not quarterly, at least annually). Unless otherwise
contracted for, we do not typically provide additional reports.
PENSION CONSULTING SERVICES
REVIEWS: GSG Advisors LLC will review the client's investment objectives whenever the
client advises us of a change in circumstances regarding the needs of the plan.
These accounts are reviewed by: Chris Greer, Principal
REPORTS: These client accounts will receive reports as contracted for at the inception of the
consulting relationship.
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms
of the specific engagement, typically no formal reviews will be conducted for Financial
Planning clients unless otherwise contracted for.
REPORTS: Financial Planning clients will receive a completed financial plan. Additional
reports will not typically be provided unless otherwise contracted for.
CONSULTING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms of
the specific engagement, typically no formal reviews will be conducted for Consulting
Services clients unless otherwise contracted for. Such reviews will be conducted by the
client's account representative.
REPORTS: Consulting Services clients will not typically receive reports due to the nature of
the service.
Item 14 Client Referrals and Other Compensation
It is GSG Advisors LLC's policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our firm, however, if GSG does pay a person for
referring a potential client that potential client will be fully informed of all fees paid to every
party.
It is GSG Advisors LLC's policy not to accept or allow our related persons to accept any form
of compensation, including cash, sales awards or other prizes, from a non-client in
conjunction with the advisory services we provide to our clients.
To further ensure GSG’s fiduciary responsibilities, all clients are informed that GSG Advisors
or related persons may receive separate compensation when effecting transactions during the
implementation process.
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Item 15 Custody
We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure
that our firm directly debits advisory fees from client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be
deducted from that client's account. On at least a quarterly basis, the custodian is required to
send to the client a statement showing all transactions within the account during the reporting
period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy of the
calculation, among other things. Clients should contact us directly if they believe that there
may be an error in their statement.
In addition to the periodic statements that clients receive directly from their custodians, we
also send account information directly to our clients on a quarterly basis. We urge our clients
to carefully compare the information provided on these statements to ensure that all account
transactions, holdings and values are correct and current.
Our firm does not have actual or constructive custody of client accounts.
Item 16 Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we
place trades in a client's account without contacting the client prior to each trade to obtain the
client's permission.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with our firm,
and may limit this authority by giving us written instructions. Clients may also change/amend
such limitations by once again providing us with written instructions.
MANAGER OF MANAGERS PROGRAM
As previously disclosed in Item 4 of this brochure, we do not "manage" client portfolios in the
traditional sense of the definition, rather GSG Advisors LLC manages the managers of client
portfolios within this program. Accordingly, clients participating in this program grant us
authority to hire and fire the selected asset manager(s) managing client accounts.
Clients give us this authority when they sign a discretionary agreement with our firm, and may
limit this authority by giving us written instructions. Clients may change/amend these
limitations by once again providing us with written instructions.
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Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our
firm may provide investment advisory services relative to client investment assets, clients
maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by
issuers of securities beneficially 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. Clients are responsible for instructing
each custodian of the assets, to forward to the client copies of all proxies and shareholder
communications relating to the client’s investment assets.
We may provide clients with consulting assistance regarding proxy issues if they contact us
with questions at our principal place of business.
Item 18 Financial Information
We do not require or solicit prepayment of fees six months or more in advance and, as a
result, are not required to include with this brochure a balance sheet for our most recent fiscal
year.
We have never been the subject of a bankruptcy petition, nor do we have any financial
condition that is reasonably likely to impair our ability to meet contractual commitments to
clients.
As an advisory firm that maintains discretionary authority for client accounts, we are also
required to disclose any financial condition that is reasonable likely to impair our ability to
meet our contractual obligations. GSG Advisors LLC has no additional financial
circumstances to report.
25
Part 2B of Form ADV: Brochure Supplement
Jon Michael Greer
GSG Advisors LLC
East Gate Corporate Center
307 Fellowship Road, Suite 210
Mt. Laurel, NJ 08054
856-396-6196
March 2025
This brochure supplement provides information about Jon Michael Greer that
supplements the GSG Advisors LLC brochure. You should have received a copy of that
brochure. Please contact Jon Greer if you did not receive GSG Advisors LLC's brochure
or if you have any questions about the contents of this supplement.
Additional information about Jon Michael Greer is available on the SEC’s website at
www.adviserinfo.sec.gov
26
Item 2 Educational, Background and Business Experience
Full Legal Name: Jon Michael Greer Born: 1967
Education
• Rutgers University - School of Law; JD, Law; 1998
• Temple University - School of Business; MBA, Finance; 1995
• Kenyon College; BA, Economics; 1990
Business Experience
• GSG Advisors LLC; Partner; from 07/2002 to Present
• Greer Scocca & Lau LLC; Partner; from 5/2003 to Present
• Valens Group LLC; Partner; from 6/2004 to Present
• Sage Ventures LLC; Manager; from 11/2004 to Present
• SVRE GP, LLC; Manager; from 10/2005 to Present
• Keystone Equities Group; Registered Representative; from 7/2006 to 5/2009
• Horner, Townsend & Kent, Inc.; Registered Representative and IAR; from 02/2003 to 7/2004
• Morgan, Lewis & Bockius, LLP; Associate; from 8/1998 to 2/2003
Item 3 Disciplinary Information
Jon Michael Greer has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Jon Michael Greer is also engaged in the following investment-related
activities:
Valens Group LLC (VG)
GSG owns 100% of Valens Group. Jon Greer is an officer of Valens Group LLC, an insurance
agency, and individually licensed in several different states to sell life, health, disability and
long term care insurance products and annuity products through numerous insurance carriers.
Insurance products may be recommended to advisory clients of GSG as part of a financial plan,
or to other advisory clients on a case-by-case basis, including product recommendations to
qualified and/or nonqualified benefit plans. These individuals may receive separate, yet
customary commission compensation resulting from implementing product transactions on
behalf of advisory clients. The receipt of commissions related to GSG's advisory
recommendations creates a conflict of interest, however, clients are not under any obligation to
27
engage these individuals when considering implementation of advisory recommendations. All
conflicts are disclosed to the client. The implementation of any or all recommendations is
solely at the discretion of the client.
Real Estate Agent
Jon Greer is also a licensed real estate agent. He may provide services to clients and receive
normal and customary real estate commissions. He may also share commissions with a real
estate agent or broker to whom he introduces a client. All conflicts, if any, are disclosed to the
client.
Sage Ventures LLC (Sage)
Jon Greer is a manager of Sage Ventures LLC, a limited liability company that engages in real
estate and other venture investment transactions. At times, Sage may act as a general partner of
another partnership or limited liability company that invests in real estate ventures or other
investment vehicles. Clients of GSG may be offered the opportunity to invest in such
investment partnerships (where Sage is a general partner) and the managers of GSG may earn
fees associated with such investment partnerships. The receipt of such fees related to GSG's
advisory recommendations creates a conflict of interest. All conflicts, if any, are disclosed to
the client.
Investment Entities
Sage Ventures LLC (the Members of GSG Advisors are also members of or work with Sage) is the
manager of FHGA Investment LLC (FHGA), SWR Investment LLC (SWR), PSS Investment LLC
(PSS) and WBC Investment LLC (WBC) which are real estate investment entities. GSG does not
provide investment advice to these entities. GSG may recommend these entities to its advisory clients,
however, GSG does not itself receive a fee from such entities. Sage and/or such entities, however, do
charge their own management fee(s), of which the members of GSG Advisors have an interest. The
recommendation of investing in such entities, therefore has an inherent conflict of interest. While GSG
could recommend other investments and charge a management fee, the fees that the members may
ultimately receive from a client's investment in these entities may be higher or lower than those fees
depending on the ultimate performance of these entities. All clients must evaluate such investments
themselves based on each entity’s private offering memoranda and GSG will have no authority to
direct the investment of a client's assets into such entities. All conflicts are disclosed to the client.
Greer, Scocca & Lau LLC (GSL)
Jon Greer is a partner in the law firm of Greer Scocca & Lau LLC. The firm focuses on estate
planning, real estate and general corporate matters. The implementation of advisory
recommendations by GSG may require legal services, particularly including the preparation of
legal documents (including will and trusts). The receipt of fees related to GSG's advisory
recommendations creates a conflict of interest, however, clients are not under any obligation to
engage GSL when considering implementation of advisory recommendations. All conflicts are
disclosed to the client.
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A. Jon Michael Greer does not receive commissions, bonuses or other compensation on
the sale of securities or other investment products.
B. Non-Investment Related Activities – Jon Greer is engaged in other businesses that
provide substantial compensation or involves a substantial amount of his time.
Item 5 Additional Compensation
Jon Michael Greer does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
Item 6 Supervision
Supervisor: Joseph Scocca
Title: Partner
Phone Number: 856-396-6194
Each of the three principals of GSG Advisors supervises each other through a series of meetings
and review functions. They meet on a regular basis regarding client and company matters and to
discuss the actions taken and to be taken by each of them. All of the principals are involved in
quarterly and annual reviews of the firm’s policies and procedures, including without limitation,
quarterly investment reviews, annual reviews of the firm’s ethics policies and at least annual reviews of
every firm policy and procedure.
29
Part 2B of Form ADV: Brochure Supplement
Joseph Edward Scocca
GSG Advisors LLC
East Gate Corporate Center
307 Fellowship Road, Suite 210
Mt. Laurel, NJ 08054
856-396-6194
March 2025
This brochure supplement provides information about Joseph Edward Scocca that
supplements the GSG Advisors LLC brochure. You should have received a copy of that
brochure. Please contact Jon Greer if you did not receive GSG Advisors LLC's brochure
or if you have any questions about the contents of this supplement.
Additional information about Joseph Edward Scocca is available on the SEC’s website
at www.adviserinfo.sec.gov
30
Item 2 Educational, Background and Business Experience
Full Legal Name: Joseph Edward Scocca Born: 1970
Education
• Rutgers University - School of Business; BS, Accounting; 1993
• Rutgers University - School of Law; JD, Law; 1998
• Villanova University - School of Law; LL.M., Taxation; 1998
Business Experience
• GSG Advisors LLC; Principal; from 07/2002 to Present
• Greer Scocca & Lau LLC; Partner; from 05/2003 to Present
• Valens Group LLC; Partner; from 06/2004 to Present
• Sage Ventures LLC; Manager; from 10/2004 to Present
• SVRE GP, LLC; Manager; from 1/2006 to Present
• Keystone Equities Group; Registered Representative; from 07/2006 to 05/2009
• Horner, Townsend & Kent, Inc.; Registered Representative and IAR; from 04/2003 to
07/2004
• Northwestern Mutual Investment Services; Registered Representative; from 11/2001 to
04/2003
• Blank, Rome, Comisky & McCauley LLP; Associate; from 08/1998 to 11/2001
• Deloitte & Touche LLP; Associate; from 8/1994 to 09/1995
Item 3 Disciplinary Information
Joseph Edward Scocca has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Joseph Edward Scocca is also engaged in the following investment-related
activities:
Valens Group LLC (VG)
GSG owns 100% of Valens Group. Joe Scocca is an officer of Valens Group LLC, an
insurance agency, and individually licensed in several different states to sell life, health,
disability and long term care insurance products and annuity products through numerous
insurance carriers. Insurance products may be recommended to advisory clients of GSG as part
31
of a financial plan, or to other advisory clients on a case-by-case basis, including product
recommendations to qualified and/or nonqualified benefit plans. These individuals may receive
separate, yet customary commission compensation resulting from implementing product
transactions on behalf of advisory clients. The receipt of commissions related to GSG's advisory
recommendations creates a conflict of interest, however, clients are not under any obligation to
engage these individuals when considering implementation of advisory recommendations. All
conflicts are disclosed to the client. The implementation of any or all recommendations is
solely at the discretion of the client.
Sage Ventures LLC (Sage)
Joe Scocca is a manager of Sage Ventures LLC, a limited liability company that engages in real
estate and other venture investment transactions. At times, Sage may act as a general partner of
another partnership or limited liability company that invests in real estate ventures or other
investment vehicles. Clients of GSG may be offered the opportunity to invest in such
investment partnerships (where Sage is a general partner) and the managers of GSG may earn
fees associated with such investment partnerships. The receipt of such fees related to GSG's
advisory recommendations creates a conflict of interest. All conflicts, if any, are disclosed to
the client.
Investment Entities
Sage Ventures LLC (the Members of GSG Advisors are also members of or work with Sage) is the
manager of FHGA Investment LLC (FHGA), SWR Investment LLC (SWR), PSS Investment LLC
(PSS) and WBC Investment LLC (WBC) which are real estate investment entities. GSG does not
provide investment advice to these entities. GSG may recommend these entities to its advisory clients,
however, GSG does not itself receive a fee from such entities. Sage and/or such entities, however, do
charge their own management fee(s), of which the members of GSG Advisors have an interest. The
recommendation of investing in such entities, therefore has an inherent conflict of interest. While GSG
could recommend other investments and charge a management fee, the fees that the members may
ultimately receive from a client's investment in these entities may be higher or lower than those fees
depending on the ultimate performance of these entities. All clients must evaluate such investments
themselves based on each entity’s private offering memoranda and GSG will have no authority to
direct the investment of a client's assets into such entities. All conflicts are disclosed to the client.
Greer, Scocca & Lau LLC (GSL)
Joe Scocca is a partner in the law firm of Greer Scocca & Lau LLC. The firm focuses on estate
planning, real estate and general corporate matters. The implementation of advisory
recommendations by GSG may require legal services, particularly including the preparation of
legal documents (including will and trusts). The receipt of fees related to GSG's advisory
recommendations creates a conflict of interest, however, clients are not under any obligation to
engage GSL when considering implementation of advisory recommendations. All conflicts are
disclosed to the client.
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A. Joseph Edward Scocca does not receive commissions, bonuses or other
compensation on the sale of securities or other investment products.
B. Non Investment-Related Activities – Joe Scocca is engaged in other businesses that
provide substantial compensation or involves a substantial amount of his time.
Item 5 Additional Compensation
Joseph Edward Scocca does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
Item 6 Supervision
Supervisor: Chris Greer
Title: Principal
Phone Number: 856-396-6195
Each of the three principals of GSG Advisors supervises each other through a series of meetings
and review functions. They meet on a regular basis regarding client and company matters and to
discuss the actions taken and to be taken by each of them. All of the principals are involved in
quarterly and annual reviews of the firm’s policies and procedures, including without limitation,
quarterly investment reviews, annual reviews of the firm’s ethics policies and at least annual reviews of
every firm policy and procedure.
33
Part 2B of Form ADV: Brochure Supplement
Christopher Matthew Greer
GSG Advisors LLC
East Gate Corporate Center
307 Fellowship Road, Suite 210
Mt. Laurel, NJ 08054
856-396-6195
March 2025
This brochure supplement provides information about Christopher Matthew Greer that
supplements the GSG Advisors LLC brochure. You should have received a copy of that
brochure. Please contact Jon Greer if you did not receive GSG Advisors LLC's brochure
or if you have any questions about the contents of this supplement.
Additional information about Chris Matthew Greer is available on the SEC’s website at
www.adviserinfo.sec.gov
34
Item 2 Educational, Background and Business Experience
Full Legal Name: Christopher Matthew Greer Born: 1969
Education
• Lehigh University; BS, Business and Economics; 1991
Business Experience
• GSG Advisors LLC; Principal; from 07/2002 to Present
• Valens Group LLC; Manager; from 06/2004 to Present
• Sage Ventures LLC; Member; from 10/2004 to Present
• SVRE GP, LLC; Member; from 1/2006 to Present
• Keystone Equities Group; Registered Representative; from 07/2006 to 05/2009
• Horner, Townsend & Kent, Inc.; Registered Representative and IAR; from 04/2003 to
07/2004
• SEI Investments; Regional Director; from 06/1992 to 04/2003
Item 3 Disciplinary Information
Chris Greer has no reportable disciplinary history.
Item 4 Other Business Activities
A. Investment-Related Activities
1. Chris Greer is also engaged in the following investment-related activities:
Valens Group LLC (VG)
GSG owns 100% of Valens Group. Chris Greer is an officer of Valens Group LLC, an
insurance agency, and individually licensed in several different states to sell life, health,
disability and long term care insurance products and annuity products through numerous
insurance carriers. Insurance products may be recommended to advisory clients of GSG as part
of a financial plan, or to other advisory clients on a case-by-case basis, including product
recommendations to qualified and/or nonqualified benefit plans. These individuals may receive
separate, yet customary commission compensation resulting from implementing product
transactions on behalf of advisory clients. The receipt of commissions related to GSG's advisory
recommendations creates a conflict of interest, however, clients are not under any obligation to
engage these individuals when considering implementation of advisory recommendations. The
implementation of any or all recommendations is solely at the discretion of the client.
35
Sage Ventures LLC (Sage)
Chris Greer works with Sage Ventures LLC, a limited liability company that engages in real
estate and other venture investment transactions. At times, Sage may act as a general partner of
another partnership or limited liability company that invests in real estate ventures or other
investment vehicles. Clients of GSG may be offered the opportunity to invest in such
investment partnerships (where Sage is a general partner) and the managers of GSG may earn
fees associated with such investment partnerships. The receipt of such fees related to GSG's
advisory recommendations creates a conflict of interest. All conflicts, if any, are disclosed to
the client.
HEEL Ventures LLC (HEEL)
The Managers of GSG are also managers of or work with HEEL Ventures LLC, a limited liability
company that engages in Private Equity (PE) and other venture investment (VI) transactions. At times,
HEEL may act as a general partner of another partnership or limited liability company that invests in
PE ventures or other investment vehicles. Clients of GSG may be offered the opportunity to invest in
such investment partnerships (where HEEL is a general partner) and the managers of GSG may earn
fees associated with such investment partnerships. The receipt of such fees related to GSG's advisory
recommendations creates a conflict of interest. All conflicts, if any, are disclosed to the client.
Investment Entities
Sage Ventures LLC (the Members of GSG Advisors are also members of or work with Sage) is the
manager of FHGA Investment LLC (FHGA), SWR Investment LLC (SWR), PSS Investment LLC
(PSS) and WBC Investment LLC (WBC) which are real estate investment entities. Also, HEEL
Ventures LLC (HEEL) is the manager of Ocean Opportunity Investment LLC (Ocean) and CADI
Investment LLC (CADI), which are Private Equity investment entities. GSG does not provide
investment advice to these entities. GSG may recommend these entities to its advisory clients,
however, GSG does not itself receive a fee from such entities. Sage and/or such entities, however, do
charge their own management fee(s), of which the members of GSG Advisors have an interest. The
recommendation of investing in such entities, therefore has an inherent conflict of interest. While GSG
could recommend other investments and charge a management fee, the fees that the members may
ultimately receive from a client's investment in these entities may be higher or lower than those fees
depending on the ultimate performance of these entities. All clients must evaluate such investments
themselves based on each entity’s private offering memoranda and GSG will have no authority to
direct the investment of a client's assets into such entities. All conflicts are disclosed to the client.
A. Chris Matthew Greer does not receive commissions, bonuses or other compensation
on the sale of securities or other investment products.
B. Non Investment-Related Activities
Chris Matthew Greer is not engaged in any other business or occupation that provides
substantial compensation or involves a substantial amount of his time.
Item 5 Additional Compensation
Chris Matthew Greer does not receive any economic benefit from a non-advisory client for the
provision of advisory services.
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Item 6 Supervision
Supervisor: Jon Greer
Title: Principal
Phone Number: 856-396-6196
Each of the three principals of GSG Advisors supervises each other through a series of meetings
and review functions. They meet on a regular basis regarding client and company matters and to
discuss the actions taken and to be taken by each of them. All of the principals are involved in
quarterly and annual reviews of the firm’s policies and procedures, including without limitation,
quarterly investment reviews, annual reviews of the firm’s ethics policies and at least annual reviews of
every firm policy and procedure.
37