Stokes Family Office LLC (“Adviser,” the “Firm,” “Stokes Family Office.” or “SFO”) is an investment adviser
founded in 2019, registered with the U.S. Securities and Exchange Commission (“SEC”), and is principally
owned by Gregory Stokes and Douglas Stokes through their respective holding companies.
The Firm offers a range of services, which include Wealth Management Services, Retirement Plan
Consulting Services, and Family Office Services. Prior to Stokes Family Office rendering any of the
foregoing services, clients are required to enter into one or more written agreements with Stokes Family
Office setting forth the relevant terms and conditions of the relationship (the “Advisory Agreement”).
While this brochure generally describes the business of Stokes Family Office, certain sections also discuss
the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other
persons occupying a similar status or performing similar functions), employees or any other person who
provides investment advice on Stokes Family Office’s behalf and is subject to the Firm’s supervision or
control.
Wealth Management Services
As part of its Wealth Management Services, Stokes Family Office manages client investment portfolios on a
discretionary or non-discretionary basis.
Stokes Family Office primarily allocates client assets among various mutual funds, exchange- traded funds
(“ETFs”), exchange-traded notes (“ETNs”), and individual debt and equity securities and options in
accordance with each client’s stated investment objectives. These services include, but are not limited to,
the creation of investment and/or asset allocation strategies that are customized by the Firm for the client
and/or the creation of customized portfolio allocations to Model Portfolios managed by SFO. The Firm also
offers Wealth Management services regarding private placements to Qualified Clients (as defined in Rule
205- 3 of the Investment Advisers Act of 1940) and Accredited Investors (as defined in rule 501 of the
Securities Act of 1933). A private placement (non-public offering) is an illiquid security sold to Qualified
Clients and is not publicly traded nor registered with the Securities and Exchange Commission. Private
placements generally carry a higher degree of risk due to illiquidity, lack of diversification, and leverage.
Most securities that are acquired in a private placement will be restricted securities and must be held for an
extended amount of time and therefore cannot be sold easily. The range of risks are dependent on the
nature of the Private Placement and are disclosed in the offering documents.
When appropriate, the Firm will allocate a portion of a portfolio to an independent third-party investment
adviser (“separate account manager”) for separate account management based upon individual client
circumstances and objectives, including, but not limited to, client account size, investment strategy and tax
circumstances. SFO reserves the discretion to engage and disengage separate account managers, sub-
advisers, or other third-party managers to manage client assets without prior consultation with the client, In
these situations, the Firm will enter into a tri-party agreement with the client and separate account manager
for the management of those securities. The Firm will monitor the performance of the selected separate
account manager(s).
When appropriate, the Firm may also provide advice about any type of legacy position or other investment
held in client portfolios. Clients can engage Stokes Family Office to manage and/or advise on certain
investment products that are not maintained at its primary custodian, such as variable life insurance and
annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e.,
529 plans). In these situations, Stokes Family Office directs or recommends the allocation of client assets
among the various investment options available with the relevant provider. These assets are generally
maintained at the underwriting insurance company or the custodian designated by the product’s provider.
SFO uses a variety of held away account aggregation services such as ByAllAccounts to link client’s held
away assets. ByAllAccounts allows clients to link held away accounts including those not managed by the
adviser for reporting only services. SFO does not have investment discretion over accounts linked through
ByAllAccounts. SFO avoids taking custody of client funds since we do not have direct access to client log-in
credentials. The platform(s) do not allow us to change a client address, request distributions, update
beneficiaries, open new accounts, etc. We are not affiliated with the ByAllAccounts platforms in any way and
receive no compensation from them for using their platforms.
A link will be provided to the client allowing them to connect an account(s) to the platforms using their online
login credentials. These online credentials are never made available to, held, or stored by Stokes Family
Office. The client will further need to agree to the vendor’s Terms and Conditions and Privacy Policies.
Clients using these services agree to promptly update their usernames and passwords directly through the
systems themselves as necessary to ensure their accounts remain continuously linked. Client also agrees to
promptly address any requests to update its login credentials when requested by the system.
In the event of any delay by the client to update their login credentials, client acknowledges that the adviser
will not have access to view or advise on the client’s held away account, which could result in investment
losses or inadvertently incorrect valuations being used in the billing process under this agreement. Client
acknowledges and agrees that adviser is not responsible for any losses arising from the client’s delays in
updating their login credentials and agrees that the adviser is under no obligation to credit any fees for
valuations made in good faith during periods when adviser did not have access to any held away account in
calculating its fees under this agreement.
Stokes Family Office tailors its Wealth Management services to meet the needs of its individual clients and
seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those
needs and objectives. Stokes Family Office consults with clients on an initial and ongoing basis to assess
their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the
management of their portfolios. Clients are advised to promptly notify Stokes Family Office if there are
changes in their financial situation or if they wish to place any limitations on the management of their
portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if
Stokes Family Office determines, in its sole discretion, the conditions would not materially impact the
performance of a management strategy or prove overly burdensome
to the Firm’s management efforts.
When providing advice related to alternative investments, we may rely on information provided to us by third-
party sources such as CAIS, iCapital Network, and Conway Investment Research. We receive no fee for the
use of these sources. However, these sources may charge a basis point fee or receive a revenue share from
the alternative asset manager. Stokes Family Office receives non-economic benefits from the use of these
services, which include but are not limited to curated lists of alternative investments with due diligence
completed and access to software that enables streamlined completion of relevant subscription documents.
These non-economic benefits provide incentives to use such services and recommend alternatives listed by
these sources. However, our Code of Ethics requires our representatives do what is in your best interest at
all times. We monitor our transactions to ensure that representatives put their clients first, not any economic
or non-economic benefits they may receive.
Retirement Rollovers-Potential for Conflict of Interest
A client or prospective client leaving an employer typically has four options regarding an existing retirement
plan (and could engage in a combination of these options):
i. Leave the money in the former employer’s plan, if permitted;
ii. Rollover the assets to the new employer’s plan, if one is available and rollovers are
permitted;
iii. Rollover to an Individual Retirement Account (“IRA”); or
iv. Cash out the account value (which could, depending upon the client’s age, result in
adverse tax consequences).
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way
we make money creates some conflicts with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours.
Under this special rule’s provisions, we must:
● Meet a professional standard of care when making investment recommendations (give prudent
advice);
● Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
● Avoid misleading statements about conflicts of interest, fees, and investments;
● Follow policies and procedures designed to ensure that we give advice that is in your best interest;
● Charge no more than is reasonable for our services; and
● Give you basic information about conflicts of interest.
If Stokes Family Office recommends that a client rollover his/her retirement plan assets into an account to be
managed by the Firm, such a recommendation creates a conflict of interest. Stokes Family Office will in most
cases earn new (or increase its current) compensation as a result of the rollover. No client is under any
obligation to rollover retirement plan assets into an account managed by Stokes Family Office. The Firm’s
Chief Compliance Officer, Charles Tiblier II, remains available to address any questions that a client or
prospective client has regarding the potential for conflicts of interest presented by such rollover
recommendation.
Adviser does not participate in any wrap fee programs.
As of December 31, 2023, Adviser manages or advises on a total of approximately
$2,096,972,275 of client assets. This includes total discretionary regulatory assets under management of
approximately $1,873,797,661 and non-discretionary assets under advisement of approximately
$223,174,614.
Retirement Plan Consulting Services
Stokes Family Office, through its Stokes Institutional division, provides various consulting services to
qualified employee benefit plans and their fiduciaries. This suite of institutional services is designed to assist
plan sponsors in structuring, managing and optimizing their corporate retirement plans. Each engagement is
individually negotiated and customized and may include any or all of the following services:
● Plan Design and Strategy
● Plan Review and Evaluation
● Executive Planning & Benefits
● Investment Selection and Monitoring
● Investment Management
● Plan Fee and Cost Analysis
● Plan Committee Consultation
● Fiduciary and Compliance
● Participant Education
As disclosed in the advisory agreement signed by the plan sponsor, certain of the foregoing services are
provided by Stokes Family Office, through its Stokes Institutional division, as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section
408(b)(2), each plan sponsor is provided with a written description of Stokes Family Office’s fiduciary status,
the specific services to be rendered and all direct and indirect compensation the Firm reasonably expects
under the engagement.
Family Office Services
Stokes Family Office offers clients a broad range of Family Office Services -- as further described below -- to
families, individuals, and institutions.
These Family Office Services include advice pertaining to: asset allocation, portfolio construction, financial
planning, family governance and succession planning, investment manager selection, estate planning,
insurance (life, health, disability) consulting, cash flow forecasting, and charitable gifting strategies.
Additionally, the Firm provides its clients with consolidated asset and investment portfolio reporting.
Stokes Family Office provides counsel to clients in tax and estate planning decisions – primarily related to
our clients achieving their investment planning objectives in the most tax-efficient manner possible. In doing
so, the Firm does not act as a CPA or attorney in the implementation or oversight of a tax or estate plan or
strategy.
Each of our clients is served by the entire Stokes Family Office team and is supported by our in-house
financial analysts and operations team. If a Family Office client retains Stokes Family Office to manage
his/her investment portfolio on a discretionary or non-discretionary basis, such client will need to separately
elect to receive Wealth Management Services in the Advisory Agreement.
While each of these services is available on a stand-alone basis, certain Family Office Services may also be
rendered in conjunction with investment portfolio management as part of a comprehensive wealth
management engagement.
In performing these services, Stokes Family Office is not required to verify any information received from the
client or from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized
to rely on such information. Clients are advised that it remains their responsibility to promptly notify the Firm
of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or
revising Stokes Family Office’s recommendations and/or services.