General Information
The Adviser, an Arkansas limited liability company, was formed in November 2022.
Advisory Services
The Adviser provides discretionary and non-discretionary portfolio management as well as
financial planning services to individuals, including high net worth individuals, corporations,
foundations, retirement and pension plan participants, and other entities.
At the outset of each client relationship, the Adviser spends time with the client, asking questions,
discussing the client’s investment experience and financial circumstances, tolerance for risk, and
broadly identifying major goals of the client. Based on its reviews, the Adviser generally develops
with each client:
• a financial outline for the client based on the client’s financial circumstances, present needs,
near-term and long-term goals, and the client’s tolerance for risk (the “Financial Profile”);
and
• the client’s investment objectives and guidelines (the “Investment Plan”).
The Financial Profile is a reflection of the client’s current financial picture and a look to the future
goals of the client. The Investment Plan outlines the types of investments the Adviser will make or
recommend on behalf of the client based on the Adviser’s own research and analysis in order to
meet those goals. The Investment Plan generally includes investment management strategies
designed to achieve the client’s near-term and long-term goals while carefully managing the
influence of risk on their success. The elements of the Financial Profile and the Investment Plan are
discussed periodically with each client, but are not necessarily written documents.
Portfolio Management
As described above, the Adviser will develop an Investment Plan with each portfolio management
client. The Investment Plan will be updated from time to time when requested by the client, or
when determined to be necessary or advisable by the Adviser based on updates to the client’s
financial or other circumstances.
To implement the client’s Investment Plan, the Adviser will manage the client’s investment
portfolio on a discretionary or a non-discretionary basis pursuant to an investment advisory
agreement with the client. As a discretionary investment adviser, the Adviser will have the
authority to supervise and direct the portfolio without prior consultation with the client. Clients
who choose a non-discretionary arrangement must be contacted prior to the execution of any trade
in the account(s) under management. This may result in a delay in executing recommended trades,
which could adversely affect the performance of the portfolio. This delay also normally means the
affected account(s) will not be able to participate in block trades, a practice designed to enhance the
execution quality, timing, and/or cost for all accounts included in the block. In a non-discretionary
arrangement, the client retains the responsibility for the final decision on all actions taken with
respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on the Adviser in
the management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. Each client should
note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the
client’s investment portfolio. Each client should also note that his or her investment portfolio is
treated individually by giving consideration to each purchase or sale for the client’s account. For
these and other reasons, performance of client investment portfolios within the same investment
objectives, goals, and/or risk tolerance may differ, and clients should not expect that the
composition or performance of their investment portfolios would necessarily be consistent with
similar clients of the Adviser.
Financial Planning
The Adviser generally provides financial planning services to those clients in need of such services
in conjunction with portfolio management services. The Adviser’s financial planning services
normally address areas such as general cash flow planning, retirement planning, and insurance
analysis. The goal of these services is to assess the financial circumstances of the client in order to
more effectively develop the client’s Investment Plan. Financial planning services are not offered as
stand-alone services or for separate fees but are typically provided to clients in conjunction with
the management of the portfolio.
Sub-Advisers
When appropriate and in accordance with the Investment Plan for a client, the Adviser may utilize
one or more sub-advisers (each, a “Manager”). Having access to various Managers offers a wide
variety of manager styles, and offers clients the opportunity to utilize more than one Manager if
necessary to meet the needs and investment objectives of the client. The Adviser will select the
Manager(s) it deems most appropriate for the client. Factors that the Adviser considers in selecting
Managers generally includes the client’s stated investment objective(s), management style,
performance, risk level, reputation, financial strength, reporting, pricing, and research.
The Manager(s) will generally be granted discretionary trading authority to provide investment
advisory services for the portfolio. Under most circumstances, the Adviser retains the authority to
terminate the Manager’s relationship or to add new Managers without specific client consent.
In any case, with respect to assets managed by a Manager, the Adviser’s role will be to monitor the
overall financial situation of the client, to monitor the investment approach and performance of the
Manager(s), and to assist the client in understanding the investments of the portfolio.
Retirement Plan Consulting Services
The Adviser may provide retirement plan consulting services to employee benefit plans, which
include defined benefit plans, defined contribution plans, 401(k) plans, 403(b) plans, and 457 plans
and their fiduciaries based upon an analysis of the needs of the plans. In general, these services
may include existing plan review, asset allocation advice, money management services,
communication and education services, investment performance monitoring, and/or ongoing
consulting.
Principal Owner
Mr. Matthew Scott Jeter and Mr. Joseph Clayton Gilliland are the principal owners of the Adviser.
Type and Value of Assets Currently Managed
As of December 29, 2024, the Adviser managed approximately $400,480,043 on a discretionary
basis and $54,021,498 on a non-discretionary basis.