A. Description of the Types of Advisory Services
Greenbelt Investment Advisors, LLC (“GIA”) was formed on November 4, 2010, and is based in
Round Rock, Texas located at 100 E. Main Street, Suite 101. GIA is an investment adviser registered
with the SEC.
Principal Owners
Matthew Wells
Matthew Wells is President and a Managing Member of GIA. After graduating from the University
of Texas at Austin with a degree in Economics in 2001, he started his career at Morgan Stanley.
Since that time has been a financial planner and investment advisor serving the needs of high-
net-worth families and institutions not only in Central Texas, but across the United States, working
for Wells Fargo Private Bank and WAMU, before finally going independent in 2005. He holds a
Series 66 and Texas Life and Health Insurance license.
Amanda M. Christians
Amanda M. Christians is Chief Compliance Officer, Chief Operations Officer, and Managing
Member of GIA. Ms. Christians served as Chief Compliance Officer and Chief Operations Officer
of Evolve Investment Advisors, as a Trust Officer for Evolve Bank & Trust, as a member of the
Evolve Bank & Trust Investment Advisory Committee, and was registered with Evolve Securities,
Inc., providing various compliance and operations functions for the firm. She has over 20 years of
experience in the financial services industry. From January 1998 through January 2000, Amanda
worked in Retirement Services at The American Funds Group. From March 2000 to January 2004,
Amanda held various positions at Morgan Stanley including Registered Representative. Amanda
earned a Bachelor of Business Administration in Management from the University of Texas at San
Antonio in 1997. She holds a Series 66 and Group 1/Life and Health Insurance License.
GIA offers its advisory services through the GIA Wrap Fee Program (“Program”) where it serves as
the Program’s sponsor and sole Portfolio Manager. GIA will offer Clients ongoing asset
management services through determining individual investment goals, time horizons, objectives,
and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio
monitoring and the overall investment program will be based on the above factors.
GIA charges an annual investment advisory fee based on the total assets under management as
follows:
Selection 1 – Asset Specific Fee
Asset Level
Equity
Mutual
Funds
Fixed
Income
Cash/Money
Mkt.
Up to % Up to % Up to % Up to %
First $99,999.99 2.50 1.75 1.65 1.65
Next $150,000 2.50 1.75 1.50 1.50
Next $250,000 2.25 1.50 1.50 1.50
Next $250,000 2.25 1.50 1.25 1.25
Next $250,000 2.00 1.25 1.25 1.25
Next $1,000,000 2.00 1.25 1.00 1.00
Next $1,000,000 1.75 1.25 1.00 1.00
Next $2,000,000 1.00 1.00 1.00 1.00
Next $5,000,000 1.00 1.00 1.00 1.00
Over $10,000,000 1.00 1.00 1.00 1.00
Selection 2 – Non-Asset Specific Fee
All Asset Levels Maximum 2.50%
Selection 1-Asset Specific Fee is a blended fee schedule, meaning different asset levels are
assessed different fees, as shown above.
The annual fee is negotiable based upon certain criteria (e.g., historical relationship, type of assets,
anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets
to be managed, related accounts, account composition, negotiations with Clients, etc.). Fees are
billed quarterly in advance. Lastly, please note that GIA may group certain related Client accounts,
often known as “householding”, for the purposes of achieving the minimum account size and
determining the annualized fee. In addition to compensating GIA for advisory services, the wrap
fee you pay GIA allows us to pay for brokerage and execution services provided by your Custodian.
New accounts will be billed in the month after assets arrive in the account and billing will be based
off of the previous month end value. GIA reserves the right to prorate the initial quarter after
inception if there are less than 30 days between inception and the next quarters billing cycle using
the initial quarter end account balance. After the initial billing, fees will be billed on or about the
15th of the month after the end of each calendar quarter.
Ongoing fees (separate from the trading costs) are calculated by determining the average daily
balances for the three previous months for each asset class. The value of assets will not be reduced
by the amount of margin indebtedness or increased by the amount of any margin credit.
Fees include: Trading costs, reporting services, and custodian account fees.
Fees do not include: Fees and costs listed below. The fees and costs may apply to transactions in
your account. The fees and costs not included in the wrap fee that you will pay include:
Commissions and other fees charged by broker-dealers other than your Custodian for
transactions in your account if GIA uses Prime Brokerage or Trade Away Services. Because
you will pay our wrap fee in addition to any charges paid to broker-dealers other than
your Custodian, we have an incentive to execute transactions for your account through
your Custodian. [However, as discussed in more detail, we consider various factors in our
best execution analysis and may trade at another broker-dealer if we believe we can obtain
better execution.]
Fees charged by mutual fund companies, closed-end funds, electronically traded funds,
and other collective investment vehicles, including, but not limited to, sales loads and/or
charges and short-term redemption fees.
Markups and markdowns, bid-ask spreads and selling concessions in connection your
Custodian executes as principal. Principal transactions contrast with transactions in which
your Custodian acts as your agent in effecting trades. Markups and markdowns and bid-
ask spreads are not separate fees but are reflected in the net price at which a trade order
is executed.
Costs imposed by third parties, such as transfer taxes, odd-lot differentials, certificate
delivery fees, reorganization fees, fees for alternative investments, and any other fees
required by law. Schwab may also charge for additional services such as wire transfer fees.
Please note that if over 60 trades are done in a twelve-month period, the account may be subject
to additional fees as charged by the custodian to GIA and normal ticket charges may apply.
For
accounts held at Schwab Brokerage Services
In addition to the advisory services, the wrap fee program includes certain brokerage services of
Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange
Commission and a member of FINRA and SIPC. We are independently owned and operated and
not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment
advisor to you. It will have no discretion over your account and will act solely on instructions it
receives from us [or you]. Schwab has no responsibility for our services and undertakes no duty
to you to monitor our management of your account or other services we provide to you. Schwab
will hold your assets in a brokerage account and buy and sell securities and execute other
transactions when we [or you] instruct them to. We do not open the account for you.
GIA pays Schwab a single asset-based fee in lieu of transactions based commissions. The fees GIA
pays Schwab are assessed on certain assets on your account(s) with Schwab. GIA has a conflict of
interest because GIA has a financial incentive to maximize our compensation by seeking to reduce
or minimize the total costs occurred in your account(s) subject to our wrap fee.
Schwab and other custodians have eliminated commissions [or transaction fees] for online trades
of U.S. equities, ETFs and options (subject to $0.65 per contract fee). This means that, in most
cases, when we buy and sell these types of securities, we will not have to pay any commissions to
Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into
a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap
fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and
advisory services separately. To see what you would pay for transactions in a non-wrap account
please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide.
Wrap Fee Program Disclosures
The benefits under a wrap fee program depend, in part, upon the size of the account, the costs
associated with managing the account, and the frequency or type of securities transactions
executed in the account.
For example, a wrap fee program may not be suitable for all accounts, including but not limited
to accounts holding primarily, and for any substantial period of time, cash or cash equivalent
investments, fixed income securities or no-transaction-fee mutual funds, or any other type of
security that can be traded without commissions or other transaction fees.
In order to evaluate whether a wrap [or bundled] fee arrangement is appropriate for you, you
should compare the agreed-upon Wrap Program Fee and any other costs associated with
participating in our Wrap Fee Program with the amounts that would be charged by other advisers,
broker-dealers, and custodians, for advisory fees, brokerage and execution costs, and custodial
services comparable to those provided under the Wrap Fee Program.
Conflict of Interest
When managing a client's account on a wrap fee basis, we receive as compensation for our
investment advisory services, the balance of the total wrap [or program] fee you pay after
custodial, trading and other management costs (including execution and transaction fees) have
been deducted. Accordingly, we have a conflict of interest because we have a financial incentive
to maximize our compensation by seeking to reduce or minimize the total costs incurred in your
account(s) subject to a wrap fee.
For some accounts, different asset classes are charged different annual fees. For example, the
time and risk associated with analyzing equity investments could account for a higher fee than a
fixed income position. This approach can potentially create a conflict of interest whereas GIA
might be incentivized to invest more funds into asset classes with higher fees. However, this
conflict is mitigated by our Fiduciary duty to put the Client’s interests first, and to ensure that any
management style and holdings are suitable for the Client.
Clients may terminate their engagement with GIA within five (5) business days of signing an
Agreement with no obligation and without penalty. After the initial (5) business days, the
Agreement may be terminated by GIA with thirty (30) days written notice to Client and by the
Client at any time with written notice to GIA. For accounts opened or closed mid-billing period,
fees will be prorated based on the days services are provided during the given period.
All unpaid earned fees will be due to GIA. Additionally, all unearned fees will be refunded to the
Client. Any increase in fees will be acknowledged in writing by both parties before any increase in
said fees occurs.
B. Fee Comparison
Clients may be able to purchase services similar to those offered under the Program from other
service providers either separately or as part of a similar wrap fee program. These services or
programs may cost more or less than our Program, depending on the fees charged by such
other service providers. For example, the Program Fee, which is fixed regardless of the number
of transactions occurring in the account, may be more or less than paying for execution on a
per-transaction basis.
A wrap fee is not based directly on the number of transactions in your account. Various factors
influence the relative cost of our wrap fee program to you, including the cost of our investment
advice, custody and brokerage services if you purchased them separately, the types of
investments held in your account, and the frequency, type and size of trades in your account.
The program could cost you more or less than purchasing our investment advice and
custody/brokerage services separately.
C. Additional Fees
GIA pays all custodian fees and transaction fees for all accounts under this Program. However,
custodians may charge other related costs on the purchases or sales of mutual funds, equities,
bonds, options, margin interest, and exchange-traded funds. Mutual funds, money market funds,
and exchange-traded funds may also charge internal management fees, which are disclosed in
the fund’s prospectus. GIA does not receive any compensation from these fees.
D. Additional Compensation
GIA nor its employees receive compensation, other than the portfolio management fee, for the
recommendation to the Client or the Client’s participation in the Program.