Firm Description
Stephenson and Company, Inc. hereinafter ("the Adviser") is a registered investment adviser based in
San Clemente, California. We are organized as a corporation under the laws of the State of
California. We were founded and have been providing investment advisory services since 1991. We
are primarily owned by the Bradley and Teresa Ann Stephenson Trust DTD 7/27/1998.
The Adviser is a fee-only investment management and financial planning firm. The firm does not sell
securities on a commission basis.
Types of Advisory Services
The Adviser provides investment advisory services, also known as asset management services and
furnishes investment advice through consultations, which may include: determination of financial
objectives, identification of financial problems, cash flow management, tax planning, insurance review,
education funding, retirement planning, and estate planning. The Adviser furnishes advice to clients on
matters not involving securities. The Adviser provides several types of advisory services including
comprehensive financial planning, custom-designed modular financial planning, fee-only financial
planning, investment management and retirement plan consulting.
We offer discretionary and non-discretionary asset management services. Our investment advice is
tailored to meet our clients' needs and investment objectives. If you participate in our discretionary
portfolio management services, we require you to grant our firm discretionary authority to manage your
account. Discretionary authorization will allow us to determine the specific securities, and the amount
of securities, to be purchased or sold for your account without your approval prior to each transaction.
Discretionary authority is typically granted by the investment advisory agreement you sign with our firm
and an account application, which includes the appropriate trading authorization. You may limit our
discretionary authority (for example, limiting the types of securities that can be purchased or sold for
your account) by providing our firm with your restrictions and guidelines in writing.
If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to
executing any transactions on behalf of your account. You have an unrestricted right to decline to
implement any advice provided by our firm on a non-discretionary basis.
Comprehensive Financial Planning
This service includes the gathering of complete financial information regarding the client's current and
historical status in the areas of net worth, income, expenses, taxes, investments, retirement plans, life
insurance, health and medical insurance, business arrangements and divorce agreements, as well as
future goals and objectives.
A personalized plan is then developed which may include specific recommendations in all applicable
areas. The financial plan may include, but is not limited to: a net worth statement; a cash flow
statement; projections of future net worth and cash flow; discussion of probability of success in
meeting financial goals and objectives, a review of investment accounts, including reviewing asset
allocation and providing repositioning recommendations; strategic tax planning; a review of retirement
accounts and plans including recommendations; a review of insurance policies and recommendations
for changes, if necessary; one or more retirement scenarios; estate planning review and
recommendations; and education planning with funding recommendations.
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Custom Designed Modular Financial Planning
This service consists of performing the financial planning services described above, but is limited to
only those areas of the client's financial situation specified by the client. The scope of the areas to be
included and the extent and nature of the service to be provided will be determined and agreed upon
by the client and the planner in advance.
Hourly Consultations
The services of Stephenson and Company, Inc. may be arranged for consultation regarding a specific,
specialized look at a particular aspect of the client's financial situation, without engaging in any of the
planning arrangements listed above.
Investment Management and Consulting Services
The Adviser provides a variety of investment management, consulting and monitoring services in
addition to the financial planning services listed above.
Investment advisory services include assisting the client with the formulation of an investment policy,
assessment of risk tolerance and selection of an asset allocation that is appropriate given the client's
financial goals and objectives and risk tolerance.
As part of the investment advisory service, all aspects of the client's financial affairs are reviewed and
realistic, measurable goals are set and objectives to reach those goals are defined. As goals and
objectives change over time, suggestions are made and implemented on an ongoing basis. The
Adviser periodically reviews a client's financial situation and portfolio through regular contact with the
client which often includes an annual meeting with the client.
The scope of work and fee for an Investment Advisory Agreement is provided to the client in writing
prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for
the service and the agreement may be terminated by either party in writing at any time.
Adviser may invest your assets according to one or more model portfolios developed by an unaffiliated
investment manager on a discretionary or non-discretionary basis as described below. These models
are designed for investors with varying degrees of risk tolerance ranging from a more aggressive
investment strategy to a more conservative investment approach. Clients whose assets are invested in
model portfolios may not set restrictions on the specific holdings or allocations within the model, nor
the types of securities that can be purchased in the model. Nonetheless, clients may impose
restrictions on investing in certain securities or types of securities in their account. In such cases, this
may prevent a client from investing in certain models that are managed by our firm.
Advisor also provides investment management services in which investment portfolios are actively
managed and monitored. For this type of service, Advisor may assist client in establishing a custodial
clearing account with Charles Schwab & Co., Inc. ("Schwab"). The assets included in this service may
include no-load mutual funds, exchange-traded funds ("ETFs") and individual stocks. Each portfolio will
be constructed to suit the client's needs and risk tolerances, as best as those can be determined by the
Advisor. Each portfolio will be diversified using a variety of investment vehicles of differing assets
classes and management styles.
Schwab accounts invested in our model portfolios are rebalanced when funds are added or distributed
from the account, or when advisor thinks a rebalancing of the account is warranted due to other factors
such as market fluctuation.
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The Advisor may assist the client in establishing a custodial clearing account with SEI Investments or
affiliates of SEI. Based upon the client's current financial situation, risk tolerance, time horizon and
asset class preference, the Advisor and client may select from one of many mutual fund asset
allocation model portfolios developed by SEI and comprised of SEI's no-load mutual funds as
described below.
Advisor also provides investment management services for SEI accounts in which a separate
investment portfolio is actively managed and monitored within the client's existing SEI account. A
separate Advisor-Guided portfolio is established within the client's existing SEI account, which may
include no-load mutual funds, exchange-traded funds ("ETFs") and individual stocks. Each Advisor-
Guided portfolio will be constructed to suit the client's needs and risk tolerances, as best as those can
be determined by the Advisor. Each Advisor-Guided portfolio will be diversified using a variety of
investment vehicles of differing assets classes and management styles.
The Advisor-Guided portfolio within an SEI account may be rebalanced when funds are added or
distributed from the account, or when advisor thinks a rebalancing
of the account is warranted due to
other factors such as market fluctuation.
The SEI Mutual Fund Models part of the account is managed as outlined below under Mutual Fund
Models Program.
Mutual Fund Models Program: Under this program, we act as the sole adviser to your account. SEI
makes available to us a selection of asset allocation models, the underlying investments of which are
generally comprised entirely of mutual funds that are managed by SEI (the "Mutual Fund Allocation
Models"). The Mutual Fund Allocation Models are designed (and periodically updated) by SEI to meet
with a stated investment objective or goal (i.e., defensive, short-term, moderate, market growth, core,
aggressive, etc.) and are not designed to meet any particular investor's specific investment needs or
circumstances. When you participate in this program, we select an initial Mutual Fund Allocation Model
(or Models) in which to invest your assets based upon our evaluation of your particular investment
needs and circumstances. SEI will advise us of any changes to the selected Mutual Fund Allocation
Model(s) used in your account. We will contact you prior to reallocating your assets to different Mutual
Fund Allocation Models, in accordance with the terms of our written non-discretionary advisory
agreement with you.
Investment Consulting for Retirement Plan Participants
Stephenson and Company, Inc. provides investment advisory services for individual plan participants
in 401(k) and deferred compensation plans. Advisory services include: Review and evaluation of
investment objectives; selection of an asset allocation model which is appropriate for the client; review
of all investment options offered by the plan; recommendation and selection of plan investment
options; monitoring of investments selected and any new investment options added; and notification to
client when changes or repositioning are appropriate.
Retirement Plan Consulting Services
We offer retirement plan consulting services to employee benefit plans and their fiduciaries based
upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In
general, these services may include an existing plan review and analysis, plan-level advice regarding
fund selection and investment options, education services to plan participants, investment performance
monitoring, and/or ongoing consulting. These retirement plan consulting services will generally be non-
discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain
with the plan sponsor or other named fiduciary.
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We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of retirement plan consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Either party to the retirement plan advisory agreement may terminate the agreement upon written
notice to the other party in accordance with the terms of the agreement for services. The retirement
plan advisory fees will be prorated for the quarter in which the termination notice is given and any
unearned fees will be refunded to the client.
Imposed Restrictions
Clients may request restrictions on an investment account, such as when a client needs to keep a
minimum level of cash in the account or does not want to invest in certain securities or types of
securities in the account. The Adviser reserves the right to not accept and/or terminate management of
a client's account if Adviser feels that the client-imposed restrictions would limit or prevent Adviser from
meeting or maintaining the client's investment strategy.
Wrap Fee Programs
We are not a wrap fee sponsor nor a portfolio manager to a wrap fee program. However, we may
recommend that you invest in a wrap fee program sponsored by a third-party sponsor and is managed
by a third-party portfolio manager. Wrap fee accounts are typically more appropriate for active
accounts and are managed accordingly. If you participate in a wrap fee program, you will be provided
with a separate Wrap Fee Program Brochure explaining the program and costs associated with the
program. You should also review this Part 2A thoroughly to evaluate any differences between the
services we offer as non-wrap versus a wrap fee program.
Types of Investments
We offer advice on equity securities, mutual fund shares, exchange traded funds, corporate debt
securities, certificates of deposit, municipal securities, United States government securities, real estate
investment trusts ("REITs"), and money market funds. When offering advice on equity securities, our
recommendations for purchasing stocks have been primarily limited to one specific stock in recent
years (Berkshire Hathaway B shares). Otherwise, with respect to offering advice on equity securities,
we generally advise clients on the timing of possible liquidations of existing positions in individual
stocks that were previously chosen or held by clients, as opposed to purchasing more of these
securities or purchasing other equity securities. Initial public offerings (IPOs) are not available through
the Adviser.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
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Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. 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.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $197,973,835 in client
assets on a discretionary basis, and $68,399,389 in client assets on a non-discretionary basis. The
Adviser also oversees on a non-continuous basis approximately $95,933,725 in client assets, some of
which are managed by third-party managers.