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Item 1 – Cover Page
Form ADV Part 2A. Disclosure Brochure
Steward Advisors, LLC
625 West Adams Street, Floor 19,
Chicago, IL 60661
(630) 537-0111
www.stewardadvisors.com
March 7, 2025
This Brochure provides information about the qualifications and business practices of Steward Advisors, LLC
(“STEWARD” or “firm”). If you have any questions about the contents of this Brochure, please contact us at
(630) 537-0111 or tim@stewardadvisors.com.
Steward Advisors, LLC is a registered investment advisor. Registration of an Investment Advisor does not imply
any level of skill or training. The oral and written communications of an Advisor provide you with information
about which you determine to hire or retain an Advisor.
Additional information about Steward Advisors, LLC also is available on the SEC’s website at
www.adviserinfo.sec.gov.
Form ADV Part 2A
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Item 2 – Material Changes
This brochure contains information about STEWARD.
The firm has the following material changes to report since the last annual update dated February 22, 2024:
• The fee schedule in Item 5A has been revised for new clients after February 10, 2025.
Pursuant to SEC Rules, STEWARD will ensure that you receive a summary of any material changes to this and
subsequent Brochures within 120 days of the close of the firm’s fiscal year. STEWARD may further provide other
ongoing disclosure information about material changes as necessary.
STEWARD will further provide you with a new Brochure as necessary based on changes or new information, at
any time, without charge.
Currently, STEWARD’s Brochure is available on the firm website at
https://www.stewardadvisors.com/compliance, or it may be requested by contacting Timothy J. Obendorf at
(630) 537-0111 or tim@stewardadvisors.com.
Additional information about Steward Advisors, LLC is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with
Steward Advisors, LLC who are registered, or are required to be registered, as investment advisor
representatives of STEWARD.
Form ADV Part 2A
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Item 3 -Table of Contents
Item 1 – Cover Page .............................................................................................................................................. i
Item 2 – Material Changes .................................................................................................................................... i
Item 3 -Table of Contents .................................................................................................................................... ii
Item 4 – Advisory Business................................................................................................................................... 1
A.
Description of Advisory Firm ........................................................................................................... 1
B.
Description of Advisory Services Offered ......................................................................................... 1
C.
Client Tailored Services and Client Imposed Restrictions ................................................................. 2
D. Wrap Fee Programs ........................................................................................................................ 2
E.
Client Assets Under Management ................................................................................................... 2
Item 5 – Fees and Compensation ......................................................................................................................... 2
A. Method of Compensation and Fee Schedule ................................................................................... 2
B.
Client Payment of Fees ................................................................................................................... 3
C.
Additional Client Fees Charged........................................................................................................ 3
D.
Prepayment of Client Fees .............................................................................................................. 3
E.
External Compensation for the Sale of Securities to Clients ............................................................. 3
Item 6 – Performance-Based Fees and Side-By-Side Management ....................................................................... 3
Item 7 – Types of Clients ...................................................................................................................................... 3
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .................................................................. 3
A. Methods of Analysis and Investment Strategies .............................................................................. 3
B.
Investment Strategy and Method of Analysis of Material Risks........................................................ 4
C.
Security Specific Material Risks ....................................................................................................... 6
Item 9 – Disciplinary Information ......................................................................................................................... 6
A.
Criminal or Civil Actions .................................................................................................................. 6
B.
Administrative Enforcement Proceedings........................................................................................ 6
C.
Self-Regulatory Organization Enforcement Proceedings .................................................................. 6
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................ 6
A.
Broker-Dealer or Representative Registration ................................................................................. 6
B.
Futures or Commodity Registration................................................................................................. 6
C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest .................... 6
D.
Recommendation or Selection of Other Investment Advisors and Conflicts of Interest .................... 6
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................ 6
A.
Code of Ethics Description .............................................................................................................. 6
B.
Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest ...... 7
Form ADV Part 2A
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C.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest........ 7
D.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions
and Conflicts of Interest ............................................................................................................................ 7
Item 12 – Brokerage Practices.............................................................................................................................. 7
A.
Factors Used to Select Broker-Dealers for Client Transactions ......................................................... 7
B.
Aggregating Securities Transactions for Client Accounts .................................................................. 8
Item 13 – Review of Accounts .............................................................................................................................. 8
A.
Schedule for Periodic Review of Client Accounts or Financial Plans ................................................. 8
B.
Review of Client Accounts on Non-Periodic Basis ............................................................................ 8
C.
Content of Client Provided Reports and Frequency ......................................................................... 9
Item 14 – Client Referrals and Other Compensation............................................................................................. 9
A.
Economic Benefits Provided to the Advisory Firm From External Sources and Conflicts of Interest .. 9
B.
Advisory Firm Payments for Client Referrals .................................................................................... 9
Item 15 – Custody ................................................................................................................................................ 9
Item 16 – Investment Discretion .......................................................................................................................... 9
Item 17 – Voting Client Securities ........................................................................................................................ 9
Item 18 – Financial Information ........................................................................................................................... 9
A.
Balance Sheet ................................................................................................................................. 9
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to
B.
Clients ...................................................................................................................................................... 9
C.
Bankruptcy Petitions During the Past Ten Years ............................................................................ 10
Form ADV Part 2A
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Item 4 – Advisory Business
A. Description of Advisory Firm
Steward Advisors, LLC is a fee based financial planning and investment management firm offering advice
to individuals, businesses, trusts, estates, charitable organizations, retirement plans, corporations,
family offices and other business entities. Founded in 2011, the firm provides planning and advisory
services in the areas of securities investments, risk management, budgeting, estate planning, trust
planning, retirement planning, college funding and tax counseling. Although the majority of the firm’s
business is centered on investment management, financial planning is an integral part of the services
provided. It is estimated that 15-20% of the firm’s time is spent on financial planning.
The firm is owned 42% by Timothy J. Obendorf, 33% by Michael H. Kwon and 25% by Dale R. Branda.
B. Description of Advisory Services Offered
The company offers two primary services: 1) Financial Planning and 2) Private Portfolio Management.
Financial Planning is offered which covers one or more of the following areas:
1) Goal planning. In an initial meeting with clients, identify and clarify primary financial goals and
objectives.
2) Net Worth Statement. Based on data provided by the client, create a statement of assets and
liabilities and identify titling.
3) Cash Flow Review. Identify sources of income and current expenses.
4) Tax Planning. Review past tax returns and current cash flow to identify tax planning
opportunities.
5) Risk Tolerance Assessment. Using a questionnaire, identify client’s emotional risk tolerance and
capacity for volatility of investment returns.
6) Investment Advice. Based on the client’s goals and risk tolerance assessment, determine an
asset allocation that provides appropriate return and risk.
7) Risk Management Review. Review client’s existing life, health, long term care and property and
casualty insurance to determine adequacy of coverage.
8) Estate Plan Review. Review and diagram existing estate plan (wills & trusts) and identify
potential opportunities to reduce estate taxes or streamline the client’s estate distribution.
9) Retirement Planning & Monte Carlo Analysis. Develop a cash flow projection for the client
based on their resources and projected expenses. Using Monte Carlo statistical analysis,
determine probability of not running out of money in retirement and recommend adjustments
to the retirement plan if necessary.
10) College Planning. Identify the amount of college savings needed, if any, and recommend a plan
for achieving amount necessary.
Private Portfolio Management is offered to clients with a minimum of $250,000 in investible assets. The
minimum portfolio size may be waived by the firm in its sole discretion. The portfolios are generally
constructed using exchange traded funds (ETF’s), mutual funds, stocks, and bonds based on asset
allocation models. In addition, STEWARD may also recommend that certain eligible clients invest in
privately placed securities, which may include debt, equity and/or interests in pooled investment
vehicles (e.g., hedge funds). Portfolios are constructed for each client based on these models and taking
into account the client’s appetite, financial capacity and need for risk. An investment policy is created
for each client, which outlines the target allocation for that client’s portfolio, any client-specific
Form ADV Part 2A
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restrictions, and the benchmark returns against which their portfolio will be compared. On a periodic
basis the portfolios are rebalanced to ensure that each client’s assets are allocated according to their
investment policy. Each client receives a quarterly performance report in addition to their monthly
statements from the custodian.
Cash Positions. STEWARD may maintain cash and cash equivalent positions (such as money market
funds or certificates of deposit) for defensive, strategic, or liquidity purposes. Unless otherwise agreed in
writing, all cash and cash equivalent positions are included as part of assets under management for
purposes of calculating the firm’s investment advisory fee.
C. Client Tailored Services and Client Imposed Restrictions
STEWARD provides both discretionary and non-discretionary management of client accounts.
Investment advice is tailored to each client’s situation, and for discretionary accounts, investment
management is exercised in a manner consistent with the stated investment objectives for the particular
client account. As discussed above, an investment policy is created for each client, which outlines the
target allocation for that client’s portfolio and any client specific restrictions.
D. Wrap Fee Programs
STEWARD does not offer any wrap fee programs.
E. Client Assets Under Management
STEWARD’s Assets Under Management are listed below as of December 31, 2024:
Assets Under Management: $ 136,866,225
Discretionary: $129,075,817
Non-Discretionary: $7,790,408
Item 5 – Fees and Compensation
A. Method of Compensation and Fee Schedule
The specific manner in which fees are charged by STEWARD is established in a client’s written
agreement with STEWARD.
Portfolio management fees are prorated for each capital contribution and withdrawal made during the
applicable calendar month (with the exception of de minimis contributions and withdrawals). Accounts
initiated or terminated during a calendar month are charged a prorated fee. Upon termination of any
account, any prepaid, unearned fees are promptly refunded, and any earned, unpaid fees are due and
payable.
The annual fee for portfolio management services will vary depending upon the market value of the
assets under management as follows:
Portfolio Value
Up to $1,100,000
Over $1,100,000 up to $2,200,000
Over $2,200,000 up to $5,500,000
Over $5,500,000 up to $11,000,000
Over $11,000,000
Annual Fee
1.0%
0.75%
0.50%
0.35%
0.25%
Portfolio management fees are payable monthly in arrears, charged as 1/12th of the annual amount.
For clients with assets under management above $600,000, the financial planning described in 4B is
included in the above fee. Clients with less than $600,000 in assets under management are charged on
an hourly basis for planning at the rate of $350 per hour or on a retainer basis at a negotiated quarterly
rate.
Form ADV Part 2A
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For clients without assets under management, a comprehensive financial plan covering the 10 topics in
4B is offered as a standalone service for a fixed fee of $3,500. It is estimated that a comprehensive
financial plan will take 12-15 hours to prepare, including an initial consultation and presentation of the
planning report.
Limited scope financial planning may be offered at a negotiated hourly or retainer rate based on the
scope of the project.
All fees are subject to negotiation.
B. Client Payment of Fees
STEWARD will generally bill its fees in arrears on a monthly basis. Clients authorize STEWARD to directly
debit fees from client accounts as outlined in the client agreement. Other means of payment may be
negotiated on a case-by-case basis.
C. Additional Client Fees Charged
STEWARD’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which are incurred by the client. Clients may incur certain charges imposed by custodians,
brokers, third party investment and other third parties such as fees charged by managers, custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and
other fees and taxes on brokerage accounts and securities transactions. Mutual funds, exchange traded
funds, and private funds also charge internal management fees, which are disclosed in a fund’s
prospectus. These fees may include fund management fees, performance fees, initial or deferred sales
charges, mutual fund sales loads, 12b-1 fees, surrender charges, and other fund expenses. Such charges,
fees and commissions are exclusive of and in addition to STEWARD’s fees, and STEWARD does not
receive any portion of these commissions, fees, and costs.
Item 12 further describes the factors that STEWARD considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
D. Prepayment of Client Fees
Private Portfolio Management clients are billed in arrears and not required to prepay fees. Financial
Planning clients may be requested to prepay fees. However, STEWARD does not accept prepayment of
fees in excess of $1,250 per client and six or more months in advance.
E. External Compensation for the Sale of Securities to Clients
STEWARD does not accept compensation for the sale of securities or other investment products.
Item 6 – Performance-Based Fees and Side-By-Side Management
STEWARD does not charge any performance-based fees (fees based on a share of capital gains on or capital
appreciation of the assets of a client).
Item 7 – Types of Clients
STEWARD provides financial advice and portfolio management services to individuals, businesses, trusts,
estates, charitable organizations, retirement plans, corporations, family offices and other business entities.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis and Investment Strategies
Investment advice is offered in the areas of domestic and foreign exchange-listed and over-the-counter
equity and debt securities, options, warrants, variable life insurance, variable annuities, mutual funds,
Form ADV Part 2A
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U.S. government securities, commercial paper, certificates of deposit, municipal debt, private equity,
hedge funds, other alternative investments and partnerships invested in real estate and oil and gas
interests. Securities analysis is performed by the fundamental, cyclical, and charting methods using
financial data sources (including Internet, newspapers and magazines), third-party research materials,
corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange
Commission, and company press releases. Investment strategies focus on meeting long-term goals and
may include long-term purchases, short-term trading strategies, margin transactions, and options
strategies.
As discussed in 4B, client portfolios are generally constructed using ETF’s and mutual funds based on
asset allocation models. STEWARD may recommend certain eligible clients invest in privately placed
securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge
funds). Portfolios are constructed for each client based on these models taking into account the client’s
risk appetite, financial capacity and need for return. An investment policy is created for each client
which outlines the target allocation for that client’s portfolio, and any client specific restrictions. Asset
classes included in the target allocations will generally include U.S. Equities, International Equities, Real
Estate, Commodities, Fixed Income and Cash. These asset classes are combined in various percentages
to balance risk and return based on the client’s needs and risk appetite. On a periodic basis the
portfolios are rebalanced to ensure that each client’s assets are allocated according to their investment
policy.
Investing in securities involves risk of loss that clients should be prepared to bear.
B. Investment Strategy and Method of Analysis of Material Risks
The value of client portfolios will move with some level of correlation to the broad U.S. equity market,
the international equity market, the global bond market, the global commodities market and the global
real estate market. Securities in all of these markets move up and down in reaction to changes in U.S.
and foreign economic conditions, U.S. and foreign political environments, tax policies, interest rates,
currency exchange rates, investor perceptions, and market liquidity. In addition, there is no guaranty
that investment decisions by STEWARD will produce the desired result and could cause the portfolios to
underperform the relevant market benchmarks.
Options
Options allow investors to buy or sell a security at a contracted “strike” price at or within a specific
period of time. Clients may pay or collect a premium for buying or selling an option. Investors transact
in options to either hedge (i.e., limit) losses in an attempt to reduce risk or to speculate on the
performance of the underlying securities. Options transactions contain a number of inherent risks,
including the partial or total loss of principal in the event that the value of the underlying security or
index does not increase/decrease to the level of the respective strike price. Holders of options contracts
are also subject to default by the option writer which may be unwilling or unable to perform its
contractual obligations.
Market Risk
The value of a portfolio may decrease if the value of an individual company or multiple companies in the
portfolio decreases or if STEWARD’s belief about a company’s intrinsic worth is incorrect. Further,
regardless of how well individual companies perform, the value of a portfolio could also decrease if
there are deteriorating economic or market conditions. It is important to understand that the value of
an investment may fall, sometimes sharply, in response to changes in the market, and an investor could
lose money. Investment risks include price risk as may be observed by a drop in a security’s price due to
company-specific events (e.g., earnings disappointment or downgrade in the rating of a bond) or general
market risk (e.g., such as a “bear” market when stock values fall in general). For fixed-income securities,
Form ADV Part 2A
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a period of rising interest rates could erode the value of a bond since bond values generally fall as bond
yields go up. Past performance is not a guarantee of future returns.
Manager Risk
There is always the possibility that poor security selection will cause investments to underperform
relative to benchmarks or other funds with a similar investment objective.
Use of Private Investment Vehicles
STEWARD may recommend that certain clients invest in privately placed investment vehicles (e.g.,
hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in
selecting the investments. There are few limitations on the types of securities or other financial
instruments which may be traded, and no requirement to diversify. Hedge funds may trade on margin or
otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because
private investment vehicles are not registered as investment companies, there is an absence of
regulation. There are numerous other risks in investing in these securities. Clients should consult each
fund’s private placement memorandum and/or other documents explaining such risks prior to investing.
Information Security Risk
STEWARD may be susceptible to risks to the confidentiality and security of firm operations and
proprietary and customer information. Information risks, including theft or corruption of electronically
stored data, denial of service attacks on STEWARD’s website or the websites of third-party service
providers, and the unauthorized release of confidential information are a few of the more common risks
STEWARD, and other investment advisers, face. Data security breaches of the firm’s electronic data
infrastructure could have the effect of disrupting operations and compromising customers' confidential
and personally identifiable information. Such breaches could result in STEWARD’s inability to conduct
business, potential losses, including identity theft and theft of investment funds from customers, and
other adverse consequences to customers. STEWARD has taken, and will continue to take, steps to
detect and limit the risks associated with these threats.
Tax Risks
Tax laws and regulations applicable to an account with STEWARD may be subject to change, and
unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition,
customers may experience adverse tax consequences from the early assignment of options purchased
for a customer's account. Customers should consult their own tax advisers and counsel to determine
the potential tax-related consequences of investing.
Advisory Risk
There is no guarantee that STEWARD’s judgment or investment decisions on behalf of any account will
produce the intended results. STEWARD’s judgment may prove to be incorrect, and an account might
not achieve its investment objectives. In addition, it is possible that STEWARD may experience computer
equipment failure, loss of internet access, viruses, or other events that impair access to accounts’
custodians’ software. STEWARD and its representatives are not responsible for such losses unless
caused by STEWARD breaching the firm’s fiduciary duty.
Dependence on Key Employees
An account’s success depends, in part, upon the ability of key professionals to achieve the targeted
investment goals. The loss of any of these key personnel could adversely impact the ability to achieve
such investment goals and objectives of the account.
Form ADV Part 2A
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C. Security Specific Material Risks
A significant portion of the portfolios are invested in mutual funds and exchange traded funds. These
securities are selected based on their investment objectives and their historic track record. There is no
guarantee that the funds will perform based on their historical track record or stated objectives.
Item 9 – Disciplinary Information
A. Criminal or Civil Actions
Neither STEWARD nor its management have been involved any criminal or civil action.
B. Administrative Enforcement Proceedings
Neither STEWARD nor its management have been involved any administrative enforcement proceeding.
C. Self-Regulatory Organization Enforcement Proceedings
Neither STEWARD nor its management have been involved any self-regulatory organization
enforcement proceeding.
Item 10 – Other Financial Industry Activities and Affiliations
A. Broker-Dealer or Representative Registration
Neither STEWARD nor its management are registered or have an application pending to register as a
broker-dealer or a registered representative of a broker-dealer.
B. Futures or Commodity Registration
Neither STEWARD nor its management are registered or have an application pending to register as a
futures commission merchant, commodity pool operator, a commodity trading advisor or an associated
person of the foregoing entities.
C. Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Neither STEWARD nor its management have any relationship or arrangement that is material to its
advisory business.
D. Recommendation or Selection of Other Investment Advisors and Conflicts of Interest
In general, STEWARD does not select or recommend other investment advisors. Where it is in the
client’s best interest, STEWARD may recommend another investment advisor or manager as a sub-
advisor or co-manager of separately managed client funds. In such cases, the client will execute a
separate agreement, and STEWARD will receive no compensation or fees from the other investment
manager.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics Description
STEWARD has adopted a Code of Ethics and Privacy Policy for all supervised persons of the firm
describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics and
Privacy Policy include provisions relating to the confidentiality of client information, a prohibition on
insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and
business entertainment items, and personal securities trading procedures, among other things. All
supervised persons at STEWARD must acknowledge the terms of the Code of Ethics and Privacy Policy
annually and as amended.
Form ADV Part 2A
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B. Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest
It is STEWARD’s policy that the firm will not affect any principal or agency cross securities transactions
for client accounts. STEWARD will also not cross trades between client accounts. Principal transactions
are generally defined as transactions where an advisor, acting as principal for its own account or the
account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal
transaction may also be deemed to have occurred if a security is crossed between an affiliated hedge
fund and another client account. An agency cross transaction is defined as a transaction where a person
acts as an investment advisor in relation to a transaction in which the investment advisor, or any person
controlled by or under common control with the investment advisor, acts as broker for both the
advisory client and for another person on the other side of the transaction. Agency cross transactions
may arise where an advisor is dually registered as a broker-dealer or has an affiliated broker-dealer.
C. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
STEWARD anticipates that, in appropriate circumstances, consistent with clients’ investment objectives,
it will cause accounts over which STEWARD has management authority to effect, and will recommend to
investment advisory clients or prospective clients, the purchase or sale of securities in which STEWARD,
its affiliates and/or clients, directly or indirectly, have a position of interest. STEWARD’s employees and
persons associated with STEWARD are required to follow STEWARD’s Code of Ethics. Subject to
satisfying this policy and applicable laws, officers, directors and employees of STEWARD and its affiliates
may trade for their own accounts in securities which are recommended to and/or purchased for
STEWARD’s clients. The Code of Ethics is designed to assure that the personal securities transactions,
activities and interests of the employees of STEWARD will not interfere with (i) making decisions in the
best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts. Under the Code certain classes of securities have been
designated as exempt transactions, based upon a determination that these would materially not
interfere with the best interest of STEWARD’s clients. In addition, the Code requires pre-clearance of
many transactions. Nonetheless, because the Code of Ethics in some circumstances would permit
employees to invest in the same securities as clients, there is a possibility that employees might benefit
from market activity by a client in a security held by an employee. Employee trading is continually
monitored under the Code of Ethics to reasonably prevent conflicts of interest between STEWARD and
its clients.
D. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions
and Conflicts of Interest
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis
when consistent with STEWARD 's obligation of best execution. In such circumstances, the affiliated and
client accounts will receive securities at a total average price. While this practice may result in better
execution prices, it does not change the transaction fee charged by the executing broker. STEWARD will
retain records of the trade order (specifying each participating account) and its allocation, which will be
completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in
the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be
explained on the Order.
STEWARD’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting
Timothy Obendorf.
Item 12 – Brokerage Practices
A. Factors Used to Select Broker-Dealers for Client Transactions
STEWARD may require that clients establish brokerage accounts with a custodian to maintain custody of
clients’ assets and to effect trades for their accounts. STEWARD is independently owned and operated
Form ADV Part 2A
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and not affiliated with any custodian. These firms provide STEWARD with access to institutional trading
and custody services, which are not typically available to retail investors. These services generally are
available to independent investment advisors on an unsolicited basis, at no charge to them so long as a
minimum level of assets are custodied with the firm. They are not otherwise contingent on STEWARD
committing to the broker any specific amount of business (assets in custody or trading).
For STEWARD’s client accounts maintained in custody, the custodial brokers do not charge separately
for custody, but they are compensated by account holders through commissions or other transaction-
related fees for securities trades that are executed or settle into the accounts.
The custodians may also make available to STEWARD other products and services that benefit STEWARD
but may not benefit client accounts. Some of these products and services assist STEWARD in managing
and administering client accounts. These include software and other technology that provide access to
client account data, facilitate trade execution, provide research, pricing information and other market
data, facilitate payment of STEWARD’s fees from client accounts, and assist with back-office functions,
recordkeeping and client reporting. Many of these services generally may be used to service all or a
substantial number of STEWARD’s accounts. The custodians may also make available to STEWARD other
services intended to help manage and further develop the business enterprise. These services may
include consulting, publications and conferences on practice management, information technology,
business succession, regulatory compliance, and marketing. In addition, the custodians may make
available, arrange and/or pay for these types of services rendered to STEWARD by independent third
parties. The custodians may discount or waive fees they 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 STEWARD. While as a
fiduciary, STEWARD endeavors to act in its clients’ best interests, STEWARD’s requirement that clients
maintain their assets in accounts at a certain custodian may be based in part on the benefit to STEWARD
of some of the foregoing products and services and not solely on the nature, cost, or quality of custody
and brokerage services provided.
B. Aggregating Securities Transactions for Client Accounts
In certain situations, client account trades in the same securities may be aggregated when consistent
with STEWARD 's obligation of best execution. In such circumstances, the client accounts will receive
securities at a total average price. While this practice may result in better execution prices, it does not
change the transaction fee charged by the executing broker. STEWARD will retain records of the trade
order (specifying each participating account) and its allocation, which will be completed prior to the
entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order.
Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order.
Item 13 – Review of Accounts
A. Schedule for Periodic Review of Client Accounts or Financial Plans
All investment recommendations are made based on client suitability and may change as deemed
appropriate due to changes in a recommended security’s prospects or if a client’s personal situation
merits alterations to the plan. Portfolios are reviewed quarterly by Tim Obendorf, Michael Kwon,
Nicholas Lovitsch, or Dale Branda based on market conditions and general applicability to any changes in
client goals.
B. Review of Client Accounts on Non-Periodic Basis
In addition, accounts are reviewed at such time(s) as securities are being considered for purchase or sale
from an account, or any time a conversation with a client indicates a change in their personal financial
situation.
Form ADV Part 2A
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C. Content of Client Provided Reports and Frequency
Reports are provided quarterly. The report will provide listings of the portfolio assets, return in the prior
quarter or since purchase (whichever is shorter), and return for the trailing twelve months through
quarter end. In addition, clients receive monthly statements directly from the custodial broker.
Item 14 – Client Referrals and Other Compensation
A. Economic Benefits Provided to the Advisory Firm From External Sources and Conflicts of Interest
STEWARD does not receive any economic benefit from any non-clients for providing investment advice.
B. Advisory Firm Payments for Client Referrals
STEWARD does not directly or indirectly compensate any person for client referrals.
Item 15 – Custody
Clients should receive statements at least quarterly from the broker dealer, bank or other qualified custodian
that holds and maintains the client’s investment assets. STEWARD urges clients to carefully review such
statements and compare such official custodial records to account statements that STEWARD may provide.
STEWARD’s statements may vary from custodial statements based on accounting procedures, reporting dates,
or valuation methodologies of certain securities.
STEWARD may, if authorized, deduct fees from client investment accounts or direct the transfer of funds
according to a standing letter of authorization issued by the client. STEWARD will ensure that any standing
letters of authorization issued by the client to third parties are in accordance with the guidance provided in the
SEC Staff’s February 21, 2017 Investment Adviser Association No-Action Letter.
Item 16 – Investment Discretion
STEWARD usually receives discretionary authority from clients at the outset of an advisory relationship to select
the identity and amount of securities to be bought or sold. In all cases, however, such discretion is exercised in a
manner consistent with the stated investment objectives for the particular client account.
When selecting securities and determining amounts, STEWARD observes the investment policies, limitations and
restrictions of the clients for which it advises.
Investment guidelines and restrictions must be provided to STEWARD in writing.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, STEWARD does not have any authority to and does not vote proxies on
behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all
securities maintained in client portfolios. STEWARD may provide advice to clients regarding the clients’ voting of
proxies.
Item 18 – Financial Information
A. Balance Sheet
STEWARD does not retain client cash or securities or otherwise act as a qualified custodian and does not
accept prepayment of fees in excess of $1,200 per client and six or more months in advance.
B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to
Clients
STEWARD has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients.
Form ADV Part 2A
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C. Bankruptcy Petitions During the Past Ten Years
STEWARD has not been the subject of a bankruptcy proceeding.
Form ADV Part 2A
10