A. Description of the Advisory Firm
Quest 10 Wealth Builders, Inc. (hereinafter “Q10WB”) is an SEC-registered investment adviser. This
firm has been in business since July of 2010, and the principal owners are Kenneth D. Stephenson
(50%) and Sandra V. Stephenson (50%).
B. Types of Advisory Services
Q10WB offers the following services to advisory clients:
Investment Supervisory Services
Q10WB offers ongoing portfolio management services based on the individual goals, objectives,
time horizon, and risk tolerance of each client. Following an initial interview, Q10WB creates an
Investment Policy Statement for each client, which outlines the client’s current situation (income,
tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement)
to aid in the selection of a portfolio that matches each client’s specific situation. Investment
Supervisory Services include, but are not limited to, the following:
• Investment strategy
• Asset allocation
• Risk tolerance
• Personal investment policy
• Asset selection
• Regular portfolio monitoring
Q10WB evaluates the current investments of each client with respect to their risk tolerance levels
and time horizon. Q10WB will typically request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is
given to each client.
Selection of Other Advisors
Q10WB may direct clients to various third-party money managers, co-advisers or sub-advisers who
are chosen based on how well their services match the needs and goals of the individual client.
Q10WB typically requests discretionary authority from clients to select other advisers or sub-
advisers to manage client accounts. Before selecting other advisors for clients, Q10WB will always
ensure those other advisors are properly registered as investment advisers.
Recommendation of Co-Advisers
In some situations, Q10WB will recommend that clients enter into agreements by which Q10WB
and another registered investment adviser will serve as co-advisers to the client. Usually, a tri-party
agreement will be signed describing the services to be provided by Q10WB and the co-adviser.
Educational Seminars
Q10WB provides educational seminars/workshops at local community colleges and universities.
These classes are not sponsored or endorsed by the college.
Financial Planning
Financial plans and financial planning may include but are not limited to: investment planning;
costs and risk analysis; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning. These services are based on fixed fees or hourly fees and the final fee
structure is documented in Exhibit II of the Investment Advisory Contract. At Q10WB’s sole
discretion, various financial planning services may be provided at no cost to the client. This is
typically dependent on the services provided to the client by Q10WB or one of its affiliated firms.
Services Limited to Specific Types of Investments
Q10WB limits its investment advice and/or money management to mutual funds, equities, bonds,
fixed income, ETFs, hedge funds, third-party money managers, REITs, insurance products
including annuities, and private placements. Q10WB may use other securities as well to help
diversify a portfolio when applicable.
Retirement Plan Rollovers
When we provide investment advice to clients regarding their 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 our client’s interests, so
we operate under a special rule that requires us to act in our client’s best interest and not put our
interest ahead of our clients.
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is
available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”),
or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If we recommend that a client roll over their retirement plan assets into an
account to be managed by Q10WB, such a recommendation creates a conflict of interest as we will
earn a new (or increase our current) advisory fee as a result of the rollover. We address this conflict
of interest by reviewing any such recommendation to ensure it is in the best interest of the client.
No client is under any obligation to roll over retirement plan assets to an account managed by us.
Retirement Plan Consulting Services
We offer non-discretionary retirement plan consulting services to employer-sponsored retirement
plans subject to the Employee Retirement Income Security Act of 1974 (“ERISA”). Our retirement
plan consulting services include, but are not limited to, the following services:
Fiduciary Consulting Services
• Investment Policy Statement Preparation. Q10WB assists clients in the development or
review of an investment policy statement (“IPS”). The IPS establishes the investment policies
and objectives for the plan. Clients have the ultimate responsibility and
authority to
establish such policies and objectives and to adopt and amend the investment policy
statement.
• Non-Discretionary Investment Advice. Q10WB provides clients with general, non-
discretionary investment advice regarding asset classes and investment alternatives
available for the plan that are consistent with the plan’s IPS. Q10WB assists clients with the
selection of a broad range of investment options consistent with the investment option
selection provisions of ERISA Section 404(c) and the regulations thereunder. Clients have
the final decision-making authority regarding the selection, retention, removal and addition
of any investment options.
• Investment Monitoring and Reports. Q10WB assists clients 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. The Firm
will meet with clients on a periodic basis to discuss the reports and the investment
recommendations.
• Qualified Default Investment Alternative Advice. Q10WB provides clients with non-
discretionary investment advice to assist in developing qualified default investment
alternative(s) (“QDIA”), consistent with ERISA Section 404(c) and the regulations
thereunder, for participants who are automatically enrolled in the plan or who otherwise
fail to make an investment election. Clients retain the ultimate responsibility to comply with
the requirements of Section 404(c), to monitor Section 404(c) compliance, and to follow the
terms of the plan document.
The specific services to be provided will be listed in Q10WB’s agreement with each retirement plan.
Q10WB acknowledges that in performing the retirement plan consulting services listed above it is
acting as a “fiduciary” as such term is defined under ERISA Section 3(21)(A)(ii) for purposes of
providing non-discretionary investment advice only. Q10WB acts in a manner consistent with the
requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services
cause Q10WB to be a fiduciary as a matter of law. All recommendations are submitted to the client
for ultimate approval or rejection. The retirement plan which elects to implement any
recommendations made by Q10WB is solely responsible for implementing all transactions.
Non-Fiduciary Services
• Education Services to Plan Committee. Q10WB assists in the education of the participants in
the plan about general investment principles and the investment alternatives available
under the plan. Such education services may include preparation of education materials
and/or conducting investment education seminars and meetings for participants. Education
services do not take into account the individual circumstances of each participant and do
not refer to the appropriateness of any specific investment alternatives or options for the
participants.
• Participant Enrollment. Q10WB assists clients with group enrollment meetings designed to
increase plan participation among employees and investment and financial understanding
by the employees. These meetings do not include recommendations with respect to any
specific investment alternatives or options available to participants.
• Service Provider/Vendor Services. Q10WB assists clients by arranging for the plan’s other
third-party service providers to offer these services, as agreed upon between Firm and client.
In such cases, Q10WB acts only in accordance with instructions from the client and shall not
exercise any independent judgment or discretion.
Although an investment adviser is considered a fiduciary under the Investment Advisers Act of
1940 (the “Advisers Act”) and is required to meet the fiduciary duties required of an investment
adviser, the services listed above as “Non-Fiduciary” are not considered fiduciary services for the
purposes of ERISA since Q10WB is not acting as a fiduciary to the plan as the term “fiduciary” is
defined in Section 3(21)(A)(ii) of ERISA. The exact services provided to clients are listed and detailed
in the Retirement Plan Consulting Agreement.
C. Client Tailored Services and Client Imposed Restrictions
Q10WB offers the same suite of services to all of its clients. However, specific client financial
plans and their implementation are dependent upon the client Investment Policy Statement
which outlines each client’s current situation (income, tax levels, and risk tolerance levels) and
is used to construct a client specific plan to aid in the selection of a portfolio that matches
restrictions, needs, and targets.
Clients may not impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee is a fee charged to a client that covers both advisory fees and the costs of execution of
transactions. Q10WB clients may participate in one or more wrap fee programs sponsored by other
advisers. Currently, certain Q10WB clients participate in the wrap fee program offered by AE
Wealth Management, LLC (“AE Wealth”). All clients will be provided AE Wealth’s Wrap Fee
Brochure at the beginning of the relationship and are encouraged to review that brochure for
material information regarding the program.
E. Amounts Under Management
Q10WB has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 156,956,122 $0 12/31/2023