A. The Company Steward Capital Management, Inc. is a privately-held Michigan corporation that has been providing investment advisory services as an SEC-registered investment adviser since 1988. Steward Capital Management, Inc. is a fee-based investment adviser. The term “fee-based” indicates that Steward Capital Management, Inc. is compensated only in the form of investment advisory fees. Throughout this disclosure brochure, the company is referred to as “SCM”. The principal owner of SCM is Anmar K. Sarafa, CFA. B. Advisory Services Investment Management Services SCM provides investment management services to institutional clients, individual (including high net worth) clients and private investment funds organized as pooled investment vehicles. For individuals and high net worth clients, SCM's portfolio management approach and investment services are based on the client's information which includes, but may not be limited to, the following:
• Face-to-face meetings;
• Phone discussions; and/or
• E-mail correspondence. Once an appropriate investment strategy is determined, an Investment Guideline Statement and Advisory Agreement are executed by both the client and SCM. These documents provide a written understanding of the investment objectives, risk tolerance, and investment strategy. The Investment Guideline Statements and Advisory Agreements may be revised and updated based on changing financial circumstances of the client, market cycles, and/or changes requested by the client. For institutional clients, SCM's investment strategy is often determined by various factors which may include, but are not limited to, the following:
• Requests for Proposals (RFP);
• Manager searches conducted by investment consultants;
• Legal statutes governing the management of a specific institutional pension plan;
• Meetings with the Board of Trustees/Executive Committees; and/or
• Market factors, etc. For private investment funds organized as pooled investment vehicles, SCM’s investment strategy is determined by the applicable funds’ offering documents. Clients will retain individual ownership of all securities. The following portfolio management strategies are offered to clients: Global Diversified Balanced This investment strategy utilizes a combination of individual stocks, bonds, and mutual funds, including Exchange Traded Funds (ETF), to create a Core/Satellite portfolio. The "Core" portion typically uses major market ETFs and other asset class mutual funds, diversified across multiple economic sectors, to approximate the global capital markets. The "Satellite" portion uses individual stocks, bonds, sector ETFs, and/or other specialty ETFs and mutual funds to enhance returns when opportunities are identified due to dynamic capital market cycles. The security individual selection universe is comprised of companies listed on major and regional U.S. stock exchanges. Overall portfolio risk is further managed by defining various equity allocation ranges for the Global Diversified Balanced portfolios. Clients may select from the following strategies, which feature various equity exposure ranges designed to address differences in risk tolerance:
• Aggressive Balanced (70% - 100% Equities)
• Moderate Balanced (60% - 80% Equities)
• Conservative Balanced (40% - 60% Equities)
• Custom Balanced (e.g., asset class ranges and/or investment criteria may be determined by specific instructions from the client) Investment Advisory Services High Net

Worth Investor Services SCM periodically provides services related to wealth preservation and management to individual high net worth investors. SCM works with various centers of influence (i.e., accountants, attorneys, other advisors) to assist clients in managing their investments and financial affairs. SCM may act as an advisor, facilitator, counter party, and/or investment manager to assist in the administration of various aspects of the client's wealth management strategies and /or transactions. Institutional Investor Services SCM is periodically asked to provide investment advisory services to institutional investors that pertain to strategic and tactical asset allocation decisions, individual private deals, security research, and other advice that is deemed pertinent to the institutional investor's overall management of the portfolio. Real Estate Services SCM periodically provides services related to real estate investment and management, both to individual and corporate clients. SCM may offer advice in order to minimize risk and maximize property values and investment returns, including identifying appropriate assets for purchase, obtaining financing, and sale of the assets. C. Client Tailored Services and Client Imposed Restrictions SCM offers a full range of investment advisory services which can be tailored to meet the specific needs of each client. In order to provide appropriately individualized services, SCM will work with the client to obtain information regarding the client’s financial circumstances, investment objectives, overall financial condition, income and tax status, personal and business assets, risk profile and other information regarding the client’s financial and/or investment needs. SCM will periodically review with clients their financial circumstances, investment objectives and risk profile. In order for SCM to provide effective advisory services, it is critical that clients provide accurate and complete information to SCM and inform SCM anytime such information needs to be updated or anytime there is a change in their financial circumstances, investment objectives and/or risk profile. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds, mutual funds or with respect to certain third-party products or services made available through SCM. In addition, a restriction request may not be honored if it is fundamentally inconsistent with SCM’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent SCM from properly servicing client accounts. D. Wrap Fee Programs SCM does not participate in wrap fee programs. Under a wrap fee program, advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and transaction services (e.g., execution of trades) are provided for one fee. This is different than traditional investment management programs whereby services are provided for a fee, but transaction services are billed separately on a per-transaction basis. E. Assets Under Management As of December 31, 2023, SCM managed approximately $137,717,000 in client assets. Approximately $32,667,000 of those assets are managed on a discretionary basis, and $105,050,000 are managed on a non-discretionary basis.