Evergreen Wealth Solutions, LLC (“EWS”) has been in business as an independently registered
investment adviser since January, 2019. EWS is principally owned by Andrew Harris. EWS provides
personalized asset management services to individuals, families, trusts, charitable organizations and
foundations, pensions and corporations. Our mission is to improve our clients’ financial well-being
and lives. We strive to know more about each client and their situation than anyone else, so that we
can make a meaningful impact on their lives.
Financial Planning
EWS’s focus is on assisting clients as they prepare for and ultimately experience the major transitions
in their lives. For many clients, the only life transition that merits preparation is retirement, however,
EWS believes that not only are there other major transitions, but preparing for those as well can assist
clients in their planning for retirement. For example, preparation in advance for a child with special
needs can mean increased cash flow which in turn can help save for retirement. Other examples of
transitions include marriage, divorce, death of a spouse, receipt of an inheritance, career changes, sale
of a business, and retirement.
The first step in working with EWS is to gather information about the client, their goals and their
current circumstances. EWS will request clients to provide documents regarding their income, tax
status, savings, and investments, among other requests. Clients will engage with EWS in a series of
conversations and meetings where the client learns about EWS’s thought process and methods, and
EWS gathers information needed to develop a proposed plan for moving forward. After this initial
series of meetings, EWS will begin to review, research, and prepare a financial plan for the client for
an agreed upon fee. This financial plan is presented at a separate meeting, where the client reviews
the plan and considers whether to engage EWS in other services such as management of the client’s
portfolio. Ultimately the financial plan forms the map from which both the client and EWS take
direction throughout the engagement.
Asset Management
When we perform asset management services, we will generally do so on a discretionary basis. This
means that while we will continue an ongoing relationship with each client, being involved in various
stages of their lives and decisions to be made, we will not seek specific approval of changes to the
securities in client accounts. Clients can always make deposits or withdrawals in their accounts at any
time. Because we take discretion when managing accounts, clients engaging us will be asked to execute
a Limited Power of Attorney (granting us the discretionary authority over the client accounts) through
an Investment Management Agreement that outlines the responsibilities of both the client and EWS.
This Limited Power of Attorney does not grant EWS the authority to make any withdrawals or transfers
in or out of a client account beyond the deduction of fees. Such other transfers will only be made at
the specific direction of the client. Advisory services are tailored to the specific needs of an individual
client. Clients may place reasonable restrictions on the management of assets, including specific
securities or types of securities. However, clients should understand that significant restrictions may
decrease the ability of EWS to meet the client’s goals. In very limited cases, EWS provides investment
management services on a non-discretionary basis, which means we will manage the clients’ accounts
as we do for our discretionary clients, except we will receive approval from the client prior to
implementing any investment recommendation. Clients should be aware that some recommendations
may be time-sensitive, and, as such, their performance may be affected if EWS is unable to reach them
on a timely basis.
Each client’s portfolio will be invested according to that client’s investment objectives. EWS
determines these objectives with the client by reviewing client-provided documents, client interviews
and/or asking the client to put these objectives in writing. Once we ascertain your objectives for each
account, we will develop a portfolio we believe will best fit your needs. Asset management services
for clients will be conducted on a household and not account basis. This means that EWS will consider
all of a client’s accounts and the impact an investment will have on each before making an investment
decision within an account.
To facilitate our portfolio management services, EWS has entered into an agreement with
Commonwealth Financial Network, an SEC-registered investment adviser (“Commonwealth”), to
offer clients of EWS access to Commonwealth’s PPS Custom Account Program, PPS Select Account
Program, and PPS Direct Account Program. In the case of the PPS Custom Account Program, EWS
will assist clients in the development of personalized asset allocation programs. In the case of the PPS
Select Account Program, EWS will collect financial data from clients, help clients determine the
suitability of the account, and help clients identify the appropriate investment objectives and strategies
to be used. Portfolio management is provided by Commonwealth’s Asset Management team. In the
case of the PPS Direct Account Program, EWS offers the services of approved money management
firms referred to as “Sub-advisors” to assist in managing Client portfolios. Clients of EWS who
participate in one or more of Commonwealth’s PPS Programs will receive Commonwealth’s Form
ADV Part 2 in addition to the Form ADV Part 2 for EWS. Clients should refer to Commonwealth’s
Form ADV Part 2 for detailed information about Commonwealth and Commonwealth’s PPS
Programs. More information about EWS’ relationship with Commonwealth is provided in Item 10 of
this Brochure.
Clients should be aware that the compensation to EWS will differ according to the specific advisory
programs or services provided. EWS and your advisor have a financial incentive to recommend
advisory programs or services that provide us higher compensation over other comparable programs
or services available from our firm or elsewhere that may cost you less.
Selection of Other Advisers
We may recommend that you use the services of a third party money manager to manage all or a
portion of, your investment portfolio. After gathering information about your financial situation and
objectives, we may recommend that you engage a specific third party manager or investment program.
Factors that we take into consideration when making our recommendation(s) include, but are not
limited to, the following: the managers’ performance, methods of analysis, fees, your financial needs,
investment goals, risk tolerance, and investment objectives. We will monitor the managers'
performance to ensure its management and investment style remains aligned with your investment
goals and objectives. The managers will actively manage a portion of your portfolio as allocated to
them and will assume discretionary investment authority over that portion of your account. In certain
circumstances we will not assume discretionary authority to hire and fire managers depending on the
arrangement with such managers.
Retirement Plan Consulting
EWS offers non-discretionary advisory services to 401k and other qualified retirement plans (“Plans”)
for businesses, which may include, depending on the needs of the Plan client, recommending
investment options for Plans to offer to participants, ongoing monitoring of a Plan’s investment
options, assisting plan fiduciaries in creating and/or updating the Plan’s written investment policy
statements, working with Plan service providers, and providing general investment
education and
advice to Plan participants.
Non-Discretionary Investment Advisory Services: When serving in a non-discretionary investment
advisory capacity for a Plan, EWS is in the status defined by section 3(21) of the Employee Retirement
Income Security Act of 1974. In this capacity, EWS assumes no fiduciary responsibility for the
completion of an investment policy statement or any aspect of the definition, selection, maintenance
or replacement of any Plan investment options. In this non-discretionary role EWS provides
information to the Plan Sponsor/Trustees regarding investment option style parameters and
performance reporting. The Plan Sponsor/Trustees exercise full authority over the selection of Plan
investment options and may, or may not, utilize the information provided by EWS as part of their
decision-making process.
Other Services for Employee Benefit Plans: As part of providing the non-discretionary investment
services to Plans, EWS may provide certain information and services to the Plan and the Plan
Sponsor/Trustees. These other services are designed to assist the Plan Sponsor/Trustees in meeting
their management and fiduciary obligations to the Plan. The other services may consist of the
following:
• Assist with Platform Provider Search and Plan Set-Up;
• Plan Review;
• Quarterly investment monitoring;
• Fiduciary compliance;
• Participant communication and education;
• Plan Fee and Cost Review;
• Acting as Third Party Service Provider Liaison;
• Plan Participant Education and Communication;
• Plan Benchmarking;
• Assist with Plan Conversion to New Vendor Platform; and
• Assistance in Plan Merger
Asset Management – Institutional Intelligent Portfolios™ Program
EWS has recognized certain clients and their younger family members new to the investing space or
with limited assets need an alternative to their traditional asset management methodology and program.
For these clients and their families, EWS will provide portfolio management services through an
investment service called Institutional Intelligent Portfolios™, an automated, online investment
management platform for use by independent investment advisors offered by Schwab Performance
Technologies (the “Schwab Program” and “SPT,” respectively). Through the Schwab Program, EWS
will offer clients a range of investment strategies we have constructed and manage, each consisting of
a portfolio of exchange traded funds (“ETFs”), mutual funds and a cash allocation. The client’s
portfolio is held in a brokerage account opened by the client at SPT’s affiliate, Charles Schwab & Co.,
Inc. (“CS&Co”). We are independent of and not owned by, affiliated with, or sponsored or supervised
by SPT, CS&Co or their affiliates (together, “Schwab”). The minimum investment required to open
an account in the Institutional Intelligent Portfolios Program is $5,000, therefore enabling certain
clients to begin a formal investment program. The minimum account balance to enroll in the tax-loss
harvesting feature is $50,000.
We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to
the Schwab Program. We are solely responsible, and Schwab is not responsible, for determining the
appropriateness of the Schwab Program for the client, choosing a suitable investment strategy and
portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis.
We have contracted with SPT to provide us with the technology platform and related trading and
account management services for the Schwab Program. This platform enables us to make the Schwab
Program available to clients online and includes a system that automates certain key parts of our
investment process (the “System”). The System includes an online questionnaire that helps us
determine the client’s investment objectives and risk tolerance and select an appropriate investment
strategy and portfolio. Clients should note that we will recommend a portfolio via the System in
response to the client’s answers to the online questionnaire. The client may then indicate an interest in
a portfolio that is one level less or more conservative or aggressive than the recommended portfolio,
but we then make the final decision and select a portfolio based on all the information we have about
the client. The System also includes an automated investment engine through which we manage the
client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the
client is eligible and elects).
Clients do not pay fees to SPT in connection with the Schwab Program, but EWS charges clients a fee
for our services as described below under Item 5 Fees and Compensation. Our fees are not set or
supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part
of the Schwab Program. Schwab does receive other revenues, including (i) the profit earned by Charles
Schwab Bank, a Schwab affiliate, on the allocation to the Schwab Intelligent Portfolios Sweep
Program described in the Schwab Intelligent Portfolios Sweep Program Disclosure Statement; (ii)
investment advisory and/or administrative service fees (or unitary fees) received by Charles Schwab
Investment Management, Inc., a Schwab affiliate, from Schwab ETFs™ Schwab Funds® and Laudus
Funds® that we select to buy and hold in the client’s brokerage account; (iii) fees received by Schwab
from third-party ETFs that participate in the Schwab ETF OneSource™ program and mutual funds in
the Schwab Mutual Fund Marketplace® (including certain Schwab Funds and Laudus Funds) in the
client’s brokerage account for services Schwab provides; and (iv) remuneration Schwab may receive
from the market centers where it routes ETF trade orders for execution.
Business Exit Planning
EWS provides Business Exit Planning services through the EvergreenExits brand name. This uniquely
focused type of financial planning is reserved for owners of privately held businesses. An exit plan
asks and answers all the business, personal, financial, legal, and tax questions involved in transitioning
a privately owned business. It includes planning contingencies for death, disability, divorce,
disagreement, distress and disease. Its purpose is to maximize the value of the business at the time of
exit, minimize taxes, and ensure the owner is able to accomplish all his or her personal and financial
goals in the process and after transitioning to life after the exit.
Institutional Advisory Services
EWS provides institutional advisory services through the Evergreen Institutional brand name.
Evergreen Institutional provides organizations with a broad range of services Evergreen Institutional
meets with an origination’s trustees or board to understand the desired goals. Upon identification of
the client’s goals Evergreen Institutional works with the client to draft a detailed investment policy
statement to establish the parameters under which the organizations financial assets will be managed.
Upon creation of the investment policy statement, Evergreen Institutional will develop and manage a
portfolio designed to achieve the organizations identified financial goals. Evergreen Institutional will
continuously monitor, review, and managed the plan and portfolio as a fiduciary to the organization.
Evergreen Institutional is a collaborative effort between EWS and Investment Research Partners, LLC,
a third party independent investment advisor who provides institutions with tailored investment
management services.
Assets Under Management
As of December 31, 2023, EWS manages approximately $390,570,332 of which $381,245,220 is
managed on a discretionary basis.