A) Description of our firm
We provide investment advice and/or manage investment securities for our clients. William Dirk Calvin,
CEO, is the principal owner and a member of our firm (formerly known as Mabry‐Calvin, LLC, which was
founded in 1989). The company has been registered as an investment adviser since 2010. Jackson Calvin
is a minority member of the firm and serves as our Chief Financial Officer and Chief Compliance Officer
(CCO). In addition to managing investment securities, we also monitor the return performance of our
client’s discretionary, non‐discretionary, and “held‐away” assets. Clients decide which of the “held‐
away” accounts they wish to have monitored.
B) Description of our services
We offer ongoing portfolio management, as well as, recommend various mutual funds, index funds,
ETFs, and fixed income securities to our clients. We manage some accounts on a discretionary basis. We
also work with some accounts on a non‐discretionary basis. In addition, we provide investment
performance measurement on any, and all, accounts our clients choose to add to our third‐party
measurement service.
Where appropriate based on the Client’s individual circumstances, we may recommend that the Client
open an account with American Funds to purchase F‐2 Class Shares as all or part of their investment
portfolio held at American Funds whereby American Funds acts as transfer agent. Class F‐2 shares are
designed for investors who choose to compensate their financial professional based on the total assets
in their portfolios, rather than commissions or sales charges. This arrangement is often called an “asset‐
based” or a “fee‐based” program. Class F‐2 shares do not have an up‐front or a contingent deferred
sales charge. Class F‐2 shares also do not carry a 12b‐1 fee but may have slightly higher administrative
expenses than certain other Class shares. These expenses will vary among the funds. Please note that
Class F‐2 shares are not available for purchase in certain employer‐sponsored retirement plans, unless
they are a part of a qualifying fee‐based program.
SIMPLE IRA Retirement Plan Services
Additionally, we offer consulting services to plan sponsors and other named fiduciaries (the "client")
regarding employer sponsored SIMPLE plans. The exact services to be provided will be clearly set forth
in the services agreement between the client and Sage Investment Counsel as mutually agreed upon.
Generally, the client may select one or more of the following services.
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ERISA Non-Fiduciary Services
• Education Services to Plan Committee. This includes general education regarding the SIMPLE
IRA plan’s investment options to the Plan Committee. Sage Investment Counsel will not render
individualized investment advice and will not be held to an ERISA fiduciary standard for
services rendered hereunder.
• Participant Education Services. Sage Investment Counsel will conduct periodic mutually
agreed upon informational meetings with employees and Participants and provide general
investment education, including information about the Plan, general financial and investment
information and information and materials relating to the investment options available
through the Plan.
• Plan Search Support. Sage Investment Counsel will consult with the Plan Sponsor regarding the
selection of the SIMPLE IRA plan, if requested. Sage Investment Counsel will not render
individualized investment advice and will not be held to an ERISA fiduciary standard for services
rendered hereunder.
Additional Non-Fiduciary ERISA Services
Additional services, such as the following, may be agreed upon between the Plan and Sage Investment
Counsel will be set forth in the service agreement.
• Monitoring of Qualified Fiduciary: The client is responsible as a Plan fiduciary for selection of
Sage Investment Counsel, and for monitoring the performance of Sage Investment Counsel. To
facilitate this responsibility, Sage Investment Counsel will provide client (a Plan fiduciary) with a
structure for the annual review and monitoring of Sage Investment Counsel and its
representative.
ERISA Non-Discretionary Fiduciary Services
These services are designed to allow the plan's sponsor and other named fiduciaries (the "client") to
retain full discretionary authority or control over assets of the plan. Recommendations will be made
directly to the client; plan participants will not be provided individualized, personal investment advice
under these services. We will perform these non‐discretionary investment advisory services through our
investment adviser representatives, and we may charge a fee for these fiduciary services, as described in
this Form ADV and the advisory agreement. We will perform these investment advisory services to the
plan as a fiduciary defined under ERISA Section 3(21) and we will act with the degree of diligence, care,
and skill that a prudent person rendering similar services would exercise under similar circumstances.
The client may engage us to perform one or more of the following non‐discretionary investment
advisory services:
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• Investment Policy Statement: Sage Investment Counsel will assist the client in developing a
formal, written Investment Policy Statement (“IPS”) or it will review and may recommend
amendments to the client relating to the existing IPS, if applicable. The IPS may contain the
standards and processes for selecting and monitoring Plan investments, and will set forth the
number of general investment options and asset class categories to be offered to Plan
participants with a goal of providing a menu of investments that will allow for the creation of
well‐diversified portfolios through a mix of equity and fixed income exposures. The IPS is subject
to the final approval of client, and Sage Investment Counsel does not guarantee that client will
achieve the investment objectives in the IPS.
• Investment Recommendations & Performance Monitoring: As mutually agreed upon, Sage
Investment Counsel will review the investment options
available through the Plan and consult
with the client as to what options exist with the goal of assisting the client in selecting the
“core” investments to be offered to Plan participants, including the Plan’s QDIAs if applicable,
that has been approved by the client. As mutually agreed upon, Sage Investment Counsel will
provide reports on a regular basis that are designed to assist the client in monitoring the core
investment options and to assist the client’s decision‐making in removing and replacing
investments that no longer meet the client’s objectives. Sage Investment Counsel has no
discretion with regard to selecting or removing investments for the Plan.
• Selection of Qualified Default Investment Alternative. If applicable, Sage Investment Counsel
will assist client in its selection of an investment fund product meeting the definition of a QDIA
in ERISA Regulation 2550.404c‐5(e)(3). The QDIA shall be reflected in the IPS, if applicable. Client
retains the sole responsibility to provide all required notices to Participants as required under
ERISA section 404(c)(5). Sage Investment Counsel makes no representations that the Plan will
otherwise be compliant with section 404(c).
Rollover Services Disclosure
In conjunction with the advisory services offered, we may provide education or recommendations
related to the rollover of an employer sponsored retirement plan. A plan participant leaving
employment has several options. Each choice offers advantages and disadvantages, depending on
desired investment options and services, fees and expenses, withdrawal options, required minimum
distributions, tax treatment, and the investor's unique financial needs and retirement plans. The
complexity of these choices may lead an investor to seek assistance from us.
When our firm or our Associated Person(s) recommend an investor roll over plan assets into an
Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset‐based fee as
a result. However, no compensation is received if assets are retained in the plan. Thus, we have an
economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, your fees and
expenses will increase because fees will apply to assets rolled over to an IRA and ongoing services will be
extended to these assets.
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Further, you may incur other levels of fees and expenses, including, but not limited to, investment‐
related expenses imposed by other service providers and mutual fund managers not affiliated with us,
as well as other fees and expenses charged by the custodian, third‐party administrator, and/or record‐
keeper. We make no representations or warranties relating to any costs or expenses associated with the
services provided by any third parties, and you understand that these fees are in addition to the fee paid
to us for the rollover advice.
In cases where we provide you with rollover advice as defined by the Department of Labor, which may
also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and
we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential
liabilities in connection with assets not related to the rollover and investments that are not managed by
us.
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. In accordance with
various rules and regulations, we must act in your best interest and we must not put our interests ahead
of your interests. Additionally, 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 any
conflicts of interest.
We rely on all information you provide to us, whether financial or otherwise, without independent
verification. We request that you promptly notify us in writing of any material change in the financial
and other information provided to us, and to promptly provide any such additional information as may
be reasonably requested by us.
Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future
performance, any specific level of performance, the success of any recommendations or strategies that
we may take or recommend for you, or the success of our overall recommendations. Investment
recommendations are subject to various market, currency, economic, political, and business risks, and
that investment decisions will not always be profitable.
C) Tailoring our services to individual needs and restrictions on investing
While clients share many similarities, we manage portfolios with the purpose of reaching investment
goals that are suitable for the individual client. We will not manage accounts if client goals are not
compatible with one of our investment styles. We will, however, monitor any client accounts even if the
goal is not compatible with our philosophy or investment style. Accounts that we manage will be
separate, not pooled, and held at a custodian independent of us.
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Clients may impose restrictions on investing in certain securities or types of securities in some of the
portfolios in which we maintain discretion. We inform clients when, and if, these restrictions are not
possible.
D) Wrap fee programs
We do not manage wrap fee programs.
E) Assets under management
As of January 31, 2024, we managed approximately $129,657,303 in discretionary assets and no non‐
discretionary assets.