Ballentine Capital Advisors, Inc. ("BCA" or "Advisor") is an investment advisor firm registered
with the SEC since February 2021.
The principal owner of Ballentine Capital Advisors, Inc. is James Bryan Keith Ballentine, President.
Advisory Services
BCA's principal service is providing fee-based investment advisory services and financial
planning services. In cases where BCA manages the client portfolio, BCA practices custom
management of portfolios on a discretionary basis according to the client's objectives. BCA's
primary approach is to use a structural allocation strategy aimed at reducing risk and increasing
performance. While BCA can advise on any investment asset, our recommendations are primarily
related to investments in exchange traded funds and mutual funds. BCA measures and selects mutual
funds by using various criteria, such as the fund manager's tenure, and/or overall career
performance. BCA may recommend, on occasion, redistributing investment allocations to
diversify the portfolio in an effort to reduce risk and increase performance. BCA may recommend
specific stocks to increase sector weighting and/or dividend potential. BCA may recommend
employing cash positions as a possible hedge against market movement which may adversely
affect the portfolio. BCA 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 client, or any risk deemed unacceptable for the client's risk tolerance.
BCA offers a cash management service for clients where the firm advises on placement of cash
and cash equivalents and negotiates the price for doing so. All such funds will be maintained at
qualified custodians (TD Ameritrade and Charles Schwab). BCA will charge a fixed fee for this
service and that fee will not exceed 0.50% per annum.
Pension Consulting Services
BCA will offer both fiduciary and non-fiduciary advice to Qualified Plans and its participants. The
Advisor's participant fiduciary advice will be based on information obtained from the plan
participant about goals and investment objectives, time horizon, risk tolerance and the plan
participant's financial situation. BCA will utilize the Investment Policy Statement when providing
standardized asset allocation recommendations for the investment of assets within Qualified Plans.
In cases where BCA provides ERISA Section 3(38) fiduciary investment services, BCA is
responsible for the implementation of recommendations for the Qualified Plans. Where BCA
provides ERISA Section 3(21) fiduciary investment recommendations, the trustee and the
investment committee are responsible for implementation of recommendations and BCA will not
act on the plan participants' behalf to implement these recommendations.
BCA may offer other pension consulting services that include but are not limited to educational
seminars, plan surveys, evaluations of vendor's services or special projects on behalf of the plan
sponsor.
Qualified Retirement Plan Consulting Services
As part of the Advisory Agreement for Pension Planning, BCA may provide services as follows
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for qualified retirement plans:
Fiduciary Services
BCA will perform the following Fiduciary Services:
(i) Provide discretionary and non-discretionary investment advice to the Client about asset
classes and investment alternatives available for the Plan in accordance with the Plan's
investment policies and objectives. Client shall have the final decision-making
authority regarding the initial selection, retention, removal, and addition of investment
options.
(ii) Assist the Client with the selection of a broad range of investment options consistent
with ERISA section 404(c) and the regulations thereunder.
(iii) Assist the Client in the development of an investment policy statement (IPS). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the investment policy statement.
(iv) Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain or remove and
replace investment options.
(v) Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
(vi) Provide discretionary and non-discretionary investment advice to the Plan Sponsor with
respect
to the selection of a qualified default investment alternative ("QDIA") for
participants who are automatically enrolled in the Plan or who otherwise fail to make
an investment election. The Client retains the sole responsibility to provide all notices
to participants required under ERISA section 404(c)(5).
(vii) At the request of Client, provide specific investment advice and recommendations to
Plan participants concerning their investment objectives and portfolio construction.
Non-Fiduciary Services
The Advisor will perform the following Non-Fiduciary services:
(i) Assist in the education of the participants in the Plan about general investment
principles and the investment alternatives available under the Plan. Client
understands that BCA's assistance in participant investment education shall be
consistent with and within the scope of (d) (i.e., the definition of investment
education) of Department of Labor Interpretive Bulletin 96-1.
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(ii) Assist in the group enrollment meetings designed to increase retirement plan
participation among employees and investment and financial understanding by the
employees.
BCA may provide these services or, alternatively, may arrange for the Plan's other providers to
offer these services, as agreed upon between BCA and Client.
The Advisor's roles and actions in fulfilling all responsibilities pertaining to this Agreement shall
not include those of the Plan's Trustee and will be performed solely at the direction of the Plan
Sponsor, its authorized officers, employees and/or agents. At no time will BCA accept, maintain
possession of, or have custodial responsibility for the Plan's assets. BCA will not conduct or effect the
purchase or sale of any assets of the Plan on behalf of the Plan Sponsor or Plan Participants.
Communicational and educational activities in which BCA engages related to Participants in the
Plan shall be solely at the direction of the Plan Sponsor and shall not be represented by BCA or
Plan Sponsor as investment, tax, or legal advice. BCA is not licensed to provide, shall not provide,
nor be construed to provide, the services of an attorney or accountant.
Financial Planning
In addition to investment supervisory services, BCA may provide Financial Planning Services to
some of its clients. BCA's Financial Planning services may include recommendations for portfolio
customization based on their client's investment objectives, goals, and financial situation. The
financial planning services may include but not be limited to: preparing an annual net worth
statement; creating a cash flow statement; reviewing client's current investments, most recent tax
returns, life and disability insurance, and/or estate plan and making recommendations thereon;
completing a retirement analysis; and providing education planning advice. These services are
based on fixed fees or hourly fees and the final fee structure is documented in Exhibit I of the
Financial Planning Agreement.
BCA will tailor its advisory services to its client's individual needs based on meetings and
conversations with the client. If clients wish to impose certain restrictions on investing in certain
securities or types of securities, BCA will address those restrictions with the client to have a clear
understanding of the client's requirements.
Financial Institution Consulting Services
BCA provides investment consulting services to certain broker/dealers’ customers (“Brokerage
Customers”) who provide written consent requesting to receive the firm’s consulting services.
Brokerage Customers have entered into a written advisory agreement with BCA.
Investment Management (Digital Platform)
The Firm utilizes Betterment for digital investment management, wherein an asset allocation
strategy will be provided by BCA and managed by the Sub-Advisor for asset management services
that is consistent with the Client’s investment objectives. The Firm will utilize risk tolerance
and/or data gathering questionnaires to determine the most appropriate asset allocation strategy.
On an ongoing basis, the Firm will monitor the performance of a client’s portfolio and Sub-
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Advisor will rebalance as necessary to conform to the recommended allocation. Clients typically
grant the Firm and Sub-Advisor a limited power of attorney over their brokerage accounts to
determine the amount of securities purchased or sold for their accounts. Adviser and Sub-Advisor
may provide performance reports to clients quarterly, semi-annually or annually.
BCA does not provide portfolio management services to wrap fee programs.
As of December 31, 2022, BCA had $187,874,319 in discretionary client assets under
management.