St. John & Associates, Inc. is a federally -registered investment adviser with its principal place of business located in Georgia. St. John & Associates, Inc. began conducting business in 1992. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company).
• Richard St John, Owner St. John & Associates, Inc. offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") MODEL PORTFOLIO MANAGEMENT Our firm provides portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. Which model a client enters is determined by that client's individual financial plan and/or risk profile. Our models range from Conservative to Aggressive. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. St. John & Associates, Inc. is a Financial Advisory firm and a Registered Investment Advisor, domiciled in the state of Georgia. The firm provides personal financial planning, portfolio management, and a wide range of financial services. These consulting services may include consulting on cash management, debt financing, personal lines of insurance, property and casualty insurance, college funding, tax planning, and estate planning, as well as other specific services. Subject to client’s consent, Fidelity Investments serves as the primary broker/dealer and custodian for clients’ accounts. For some legacy clients with smaller accounts and portfolio balances, and subject to their consent, TD Ameritrade through Orion serves as the broker/dealer and custodian for client’s accounts. Going forward, all new clients, regardless of the amount of assets under management, will be served by Fidelity Investments as custodian, subject to the client’s consent. Clients engage Advisor for either Full Financial Services, which includes personal financial planning, various financial services and portfolio management; portfolio management plus, which includes portfolio management and limited financial services; or portfolio management only, and have the right to change from one type of engagement to another after their initial year of Financial Services (detailed later). Financial Service clients tend to be clients who have a variety of financial service needs, may be close to retirement, and/or in need of developing and maintaining a personal financial plan. Since accounts and portfolios are managed on a discretionary basis, all clients are required to delegate this authority to St. John & Associates and its sub-advisors. Financial planning can include identification of and modeling of their financial goals, cash flow and budgeting, tax planning, risk exposure review, mortgage financing, educational financing, retirement planning, estate planning, charitable gifting, small business planning issues, insurance needs and more specialized financial services. As part of the personal financial planning process, a written personal financial plan and report of the client’s current financial condition and probable statistical likelihood of meeting their goals is periodically provided to the financial service clients. This plan includes goals, assumptions, recommendations for implementation, ongoing communication of changes, and updating of the personal financial plan to reflect said changes. All client accounts except some employer based 401(k), 403(b) and/or 457 type plans, annuities, variable life insurance policies, 529 accounts or minor children’s accounts are managed on a household basis as one portfolio. The others are managed separately, based on the same Risk Profile, Portfolio Design and Target Asset Allocation as approved by the Clients. Portfolios are developed for each client based on the client’s personal financial plan requirements and/or risk assessment, and only after the completion of a written set of investment documents. These documents include a statement of investment objectives, time frame, policy constraints, and risk tolerance. The documents also include an investment strategy, a portfolio design, a target asset allocation, and if applicable, a client’s personal financial plan. Portfolios may include other investment accounts held elsewhere, such as variable life insurance and annuities, 401(k) plan accounts, etc. Portfolios are tailored to clients’ needs by determining the rate of return range needed from their portfolio to support clients’ personal financial plan and/or based on their risk profile. Each client’s portfolio is assigned to a model portfolio ranging from conservative to aggressive. Each portfolio based on client’s signed documents may have a different planned range of returns and risk factor as deemed appropriate to the client and advisor based on their financial plan and/or risk profile. All such portfolio models tend to be widely diversified and established for long-term investing only. Portfolios include an actively and or passively managed, broadly diversified equity strategy of domestic and international individual stocks, mutual funds and/or ETFs. In some portfolios, a 2nd part of the portfolio is known as alternative investments, an actively managed, broadly diversified strategy of other investments through Exchange Traded Funds (ETFs) in a broad array of investment markets. Such tactical allocations could include equities, fixed income, real estate, and commodities as well as cash and currencies. The portfolio strategy is focused to provide higher returns with lower volatility (risk) than only bonds or fixed income investments. Other portfolio designs may have a 2nd part of a variety of fixed income options mainly through mutual funds or ETFs. In addition, Advisor will also maintain separate cash accounts for clients to service their cash withdrawal needs based on either their personal financial plan or from client information. The source of this cash is provided from dividend income from client’s portfolios. Until distributed such cash is invested in money market accounts and is not otherwise invested. As the client’s investment advisor, we determine the advisability of using sub-advisors as a portfolio strategist. Models are selected individually for them for each client. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. Schedule to meet with each client periodically, virtually, by phone, or in person as the client chooses and at such time the client advises us of any changes in the client's financial situation or investment objectives. If client fails to meet with us, we will request such information in the client annual year-end report. For Financial Service clients, we will also review these details whenever their plan is being updated. 2. Be reasonably available to consult with the client; and 3. Maintain client suitability information in each client's file. SELECTION AND MONITORING OF THIRD-PARTY MONEY MANAGERS We offer advisory management services to our clients through our Selection and Monitoring of Third-Party Money Managers programs (hereinafter, "Programs"). Our firm provides the client with an asset allocation model based on personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation model is drafted into the client's Personal Investment Policy Statement ("PIPS"). Once we determine the most suitable investment asset allocation for the client, we implement the policy by allocating the assets of the portfolio among designated sub-advisors, mutual funds and/or ETFs.

In most cases, we partner with Greenrock Research as an added resource for finding sub advisors and building allocations. Greenrock Research, Inc. is an economic and investment research company. They have worked with investment advisors on similar programs for the past 20 years. Through Greenrock Research, Advisor engages separate sub-account managers to manage specific parts of clients’ portfolios under Greenrock's and our supervision. This portfolio management structure provides more portfolio diversification with expertise in specific market areas, and more depth of knowledge in those areas than would be available in-house. We monitor the performance of the selected registered investment sub-adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management performance to the client, or is not managing the client's portfolio in a manner consistent with the sub-advisor Investment Policy statement, we will take action with Greenrock for the sub-advisor to be replaced. Notwithstanding this, sub-advisors may be added or replaced from time to time for other reasons. However, any move to a new registered investment sub-advisor will be communicated to and confirmed with the client. In addition, we monitor the performance of all mutual fund and ETF investments and flag any investment for changes in management, investment style or not meeting long term expectations for review and possible replacement. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation determining the client's current and future financial needs by using currently known variables to predict future cash requirements, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients engaging this service receive a written report of the client’s detailed personal financial plan designed to assist the client in tracking and achieving their financial goals and objectives. Prior to any portfolio management, a client is required to sign off on their personal financial plan In general, the financial plan can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client's income tax, as well as spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INSURANCE: We review existing policies to ensure adequate and proper coverage for life, health, disability, long-term care, home and automobile liability.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client's cash needs, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, health care directives, Medicaid and elder law.
• INVESTMENT MANAGEMENT: We determine based on the client’s financial plan how to best invest their funds in accordance with their goals and risk profile. We gather required information through in-depth personal interviews and online onboarding. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, and insurance agent. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning, business planning, mortgage financing and education funding. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. Revisions may be necessary. Advisor will review all of the content making up the plan and provide information for implementing any suggested changes. Upon completion and review of the plan, client signs a Plan Development Acknowledgement (PDA) and portfolio management begins. PUBLICATION OF PERIODICALS St. John & Associates, Inc. publishes a Quarterly Commentary on market conditions, market performance, and market outlook. It may also include financial topics of general interest to clients. No specific investment recommendations are provided in this newsletter and the information provided does not purport to meet the objectives or needs of any individual clients. St John & Associates, Inc also publishes a periodic newsletter providing general information on various financial topics including, but not limited to, estate and retirement planning, market trends, etc. No specific investment recommendations are provided in this newsletter and the information provided does not purport to meet the objectives or needs of any individual. This newsletter and Quarterly Commentary are distributed free of charge to our individual clients. PENSION CONSULTING SERVICES We also provide several advisory services separately or in combination. While the primary clients for these services will be pension, profit sharing and 401(k) plans, we offer these services, where appropriate, to trusts, estates and charitable organizations. Pension Consulting Services are comprised of the following services: Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): We will meet with the employers to determine an appropriate investment strategy that reflects the plan sponsor's stated investment objectives for management of the overall plan. Our firm then prepares a written investment policy statement detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The investment policy statement also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance. Selection of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models. We will then review any mutual funds (both index and managed) or other investment vehicles in the plan to determine which investments are appropriate to implement the client's investment policy statement. The number of investments to be recommended will be determined by the client, based on the investment policy statement. Monitoring of Investment Performance: We monitor employee investments options regularly, based on the procedures and timing intervals delineated in the Investment Policy Statement. Although our firm is not involved in any way in the purchase or sale of these investments, we supervise the investment performance and will make recommendations of investment option changes to the plan sponsor. CONSULTING SERVICES Clients can also receive financial advice on a more focused basis. This may include advice in isolated area(s) of concern such as college planning, estate planning, retirement planning, or any other specific topic. We also provide specific consultation and administrative services regarding the investment and financial concerns of the client. AMOUNT OF MANAGED ASSETS As of 12/31/2023, we were actively managing $103,969,679.40 of clients' assets on a discretionary basis excluding cash accounts.