A. Firm Information
Sunbeam Capital Management, LLC (“Sunbeam Capital” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under
the laws of the State of Georgia. Sunbeam Capital was founded in 2017 and is owned and operated by Ellis A. Carson
II (Managing Member and Chief Compliance Officer). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Sunbeam Capital.
B. Advisory Services Offered
Sunbeam Capital offers investment advisory services to high net worth individuals, trusts and estates (each referred
to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. Sunbeam Capital's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
Sunbeam Capital provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and related
advisory services. Sunbeam Capital works closely with each Client to identify their investment goals and objectives
as well as risk tolerance and financial situation in order to create a portfolio strategy. Sunbeam Capital will then
construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds, and/or
alternative investments to meet the needs of its Clients. The Advisor may retain certain types of investments based
on a Client’s legacy investments based on portfolio fit and/or tax considerations.
Sunbeam Capital’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market conditions.
Sunbeam Capital will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Sunbeam Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Sunbeam Capital may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Sunbeam Capital may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement.
Sunbeam Capital may recommend
selling positions for reasons that include but are not limited to, harvesting capital
gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client
needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Sunbeam Capital accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the
Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
Page 5
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
C. Client Account Management
Prior to engaging Sunbeam Capital to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that defines the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Sunbeam Capital, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Sunbeam Capital will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Sunbeam Capital will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Sunbeam Capital will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Sunbeam Capital does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Sunbeam Capital.
E. Assets Under Management
As of December 31, 2023, Sunbeam Capital manages $152,650,459 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.