Firm Description
Steward Advisors Group, LLC (“Steward,” the “Firm,” “we,” “us,” “our,” etc.) is an investment
adviser. We provide discretionary investment advisory and financial planning services to our
clients. The Firm was founded in 2022. Donald E. Simmons is the majority owner of the Firm.
Investment Advisory Services
We provide investment advisory services on a discretionary basis based on the individual needs
of our clients as set forth in the executed Investment Advisory Agreement (the “Agreement”)
entered into between the parties. This discretionary authority includes both asset allocation,
security selection, and investment screening to align portfolio holdings with client’s faith-based
and moral values. In large majority, client assets will be invested in readily marketable stocks,
bonds, exchange-traded funds and notes, options, and mutual funds. We may also provide
advice on alternative investments, including private equity, private debt, private notes, REITs
and BDCs, or on any other type of investment that we deem appropriate based on the client’s
stated goals and objectives. Client assets will be held by an independent custodian, which will
employ controls to protect client assets.
We may, upon client request, provide our clients advice on taxes, insurance, and/or estate
matters, but in such matters, we suggest our clients to also consult with their accountants/tax
professionals, insurance professionals, estate attorneys, or other relevant experts.
Financial Planning Services
We engage in broad-based financial planning services for a fee. Financial planning will typically
involve providing a variety of services to clients regarding the management of their financial
resources based upon an analysis of their individual needs and integrated with their faith-based
and moral values. Financial planning services may encompass such areas as income tax
planning, retirement planning, capital needs planning, asset allocation strategies, business
successions transfer, estate planning, insurance/risk management and employee benefits
analysis.
Each client who wishes to receive advice on financial planning will enter into a written Financial
Planning Agreement with the Firm and provide us with their financial status, investment
objectives, risk tolerance and tax status, among other things. This is a one-time engagement
that terminates upon delivery of the Financial Plan to the client. The client may choose what, if
any, advice they will implement from the Financial Plan.
Sub-Advisers
In providing investment advisory services, we may also recommend the portfolio management
services of other unaffiliated independent investment advisers based on the needs of the client.
Factors considered in making this determination include account size, risk tolerance, the opinion
of each client and the investment philosophy of the selected independent manager.
When recommending third-party investment managers on a discretionary basis, we are
responsible for performing due diligence on the third-party investment manager, hiring one or
more third-party investment managers on behalf of the client, monitoring each third-party
investment manager’s performance and adherence to its stated investment strategy and, if
necessary, terminating the third-party investment manager on the client’s behalf. Such third-
party investment managers are hereafter referred to as “Sub-Advisers.”
A complete description of the programs and services (including fees to be charged and other
contractual information) is available through a third-party investment manager will be provided
to clients upon receipt and review of the applicable third-party investment manager’s Form ADV
and/or Brochure; investment advisory contracts; and account opening documents.
Sponsor and Manager of Wrap Program
Steward Advisors Group, LLC is the sponsor and lead portfolio manager of the Steward Advisors
Group, LLC’s Wrap Program (the “Program”), a wrap fee program. In the event the client
participates in the Program, the Firm shall provide its investment management services and
arrange for brokerage transactions under a single annual advisory fee for both advisory services
and execution of transactions (the “Program Fee”). Clients in the Program do not pay brokerage
commissions, markups or transaction charges for execution of transactions by the designated
Program broker(s) in addition to the advisory fee. The advisory fee is negotiable between the
client and the Firm and is set out in the advisory agreement. The advisory fee is a percentage
based on the value of all assets in the account, including cash holdings clients should be aware
that when we recommend the Program to the client, the Firm will receive compensation as a
result of the client’s participation in the Program. The amount of this compensation may be
more or less than what the Firm would receive if the client participated in other broker-dealer
programs, programs of other investment advisors or paid separately for
investment advice,
brokerage and other client services. Therefore, we may have a financial incentive to
recommend a Program account over other programs and services.
The investment products available to be purchased in the Program can be purchased by clients
outside of a Program account, through broker-dealers or other investment firms not affiliated
with Steward.
A complete description of the Program’s terms and conditions (including fees) are contained in
the Program’s wrap fee brochure (See Form ADV Part 2A Appendix 1). There are no material
differences between the managed wrap accounts and other accounts. The wrap relationship
exists primarily because of the preference of some clients to not be subject to separate
transaction charges.
Co-Managed Accounts
Steward Advisors Group, LLC (“Steward”) has entered into a co-management agreement with
Simmons Capital Group (“Simmons Capital”) for certain Steward accounts. Simmons Capital is
generally responsible for the initial account onboarding, as well as day-to-day management of
certain assets directed to it for management by Steward in accordance with asset allocations
models developed and provided by Steward. In such co-managed engagements, Steward is
responsible for overall management of the applicable Clients’ Assets consistent with one or
more of its asset allocation strategy(ies). For a description of Simmons Capital’s duties and
responsibilities, please see Simmons Capital’s Form ADV 2A Brochure. Also see disclosure in
Item 10: Other Financial Industry Activities and Affiliations about the affiliation between
Steward and Simmons Capital.
Tailoring Your Account to Your Objectives
Client accounts will be managed on the basis of the guidelines and restrictions set forth in the
Agreement.
We encourage clients to provide us with their expectations and to consider their overall
financial situations, future financial objectives, risk tolerances, time horizons, and investment
objectives. We also discuss with our clients their financial needs in order for them to develop
the appropriate guidelines and restrictions on their account and for us to ensure the suitability
of each client’s investments in order to honor their investment needs. It is our practice to tailor
our investment advisory services to the individual needs of our clients.
Clients may impose reasonable restrictions on the types of investments for their account and
will maintain ownership of all securities in their account. In order to stay within the parameters
of a client’s guidelines, we advise them to notify us of any changes in their financial situation
that may require a change to their investment objectives.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act,
(“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing
retirement accounts.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Assets Under Management
As of January 2, 2024, we have $35,541,647 in Assets Under Management; all managed on a
discretionary basis.