A. Description of the Advisory Firm
Greenwood Capital Associates, LLC is a limited liability company organized under the state laws of South Carolina. Established in 1983
as Greenwood Capital Associates, Inc., an independent registered investment adviser, it was reorganized and registered with the Securities
and Exchange Commission (SEC) in 2001. Today, Greenwood Capital is principally owned by TCB Corporation (“TCB”), which acquired its
ownership interest on July 31, 2008. While TCB is the majority owner of Greenwood Capital, it is not its operator; and as an owner with a
long-term horizon, TCB is committed to ensuring we continue as an independent adviser. There are six active employee owners in the Firm.
As of March 1, 2024, Greenwood Capital manages more than $1.6 billion in investment assets. Our Wealth team of Private Client
Advisors provides (B.1) financial planning and (B.2) investment advisory services for individuals, families, foundations, endowments, and
trusts. Our team of Investment Managers develops and provides (B.3) investment management for institutional clients, including
municipalities, healthcare providers, charitable foundations, and higher education institutions, as well as our Wealth clients. In addition to
direct retirement advice and investment management, we also provide (B.4) group qualified retirement planning consulting services and
optional group retirement plan investment management through a third-party administrator.
B. Types of Advisory Services
1. Financial Planning
Comprehensive financial planning is an evaluation of an individual’s/family’s current and future financial state by using known variables
(such as how long you plan to work) to model your future overall financial picture. This typically includes, but is not limited to, investment
planning, life insurance, tax concerns, retirement planning, college planning, and debt/credit planning. We primarily offer these services to
clients with aggregate assets under management exceeding $1 million. We may also offer financial planning services for a fee (see Item 5),
as outlined in our Financial Planning Engagement Letter.
To provide informed recommendations, we conduct in-depth interviews and review personal and financial documents. Following careful
analysis, we tailor recommendations to align with your personal goals and objectives. If you choose to implement our recommendations, we
prefer collaborating with your attorney, accountant, insurance agent, or other professional advisers. If you do not have established
relationships with professionals, we can suggest suitable professionals, which may include entities or divisions affiliated with TCB Corporation
(including Countybank, Countybank Trust Services, Countybank Mortgage, Countybanc Insurance Services, Inc., and/or Countybanc
Investment Services, Inc.) It is important to note the conflict of interest arising from our ownership relationship with TCB, but we prioritize
our clients’ interests in any recommendations involving affiliated services. Clients are not obligated to purchase any recommended services.
2. Investment Advisory Services
Our Private Client Advisors offer investment advice tailored to your individual needs, based on information provided through client
profile questions. This includes assessing your financial situation, risk tolerance, investment horizon, liquidity needs, tax considerations,
investment objectives, estate considerations, and any other relevant issues. You should promptly inform us of any changes in your financial
situation, investment objectives, or needs.
Additionally, based on the nature of our relationship with you and your specific needs, a Private Client Advisor can also provide additional
advisory services, such as Financial Planning (as described above) and Retirement Advice:
Retirement Advice: In advising on your overall investment outlook, we may offer guidance regarding rollovers and distributions from
retirement accounts. We disclose that recommending an increase in assets under management at Greenwood Capital poses a conflict of
interest, but we prioritize our clients’ interests in such recommendations. However, we do not provide tax advice regarding required
minimum distributions (RMDs), and we recommend consulting a tax professional for accurate calculations.
2. Institutional Investment Management
Investment Management: Our Investment Managers provide discretionary investment management tailored to individual and
institutional investors through various strategies, including Separately Managed Accounts (SMA) and Unified Managed Accounts (UMA).
Depending on client direction and objectives, we develop either a single investment strategy or a diversified asset allocation portfolio.
Accounts are monitored and rebalanced accordingly.
Sub-Advisory Services: We engage in sub-advisory
relationships to provide discretionary investment advisory services to clients of other
Registered Investment Advisers, Broker-Dealers, or Custodians. As the sub-adviser, we manage these accounts in accordance with the
investment direction provided by the client’s investment adviser.
Dual Contract: We act as a portfolio manager for dual contract programs in which the advisory client has hired both their financial
adviser and us to manage their investment assets (as indicated by our Managed Account Program Agreement). Under this Agreement, we
typically meet with the client’s financial adviser and not the advisory client. As the investment manager, we manage these accounts in
accordance with the investment direction provided by the client’s investment adviser of record.
Consulting Services: We provide investment advice to other Financial Advisers and/or their clients, employee benefit plans, foundations,
endowments, corporate funds, and insurance companies on a contractual basis. If we provide consulting services only, this is on a non-
managed, non-discretionary basis where we do not manage the individual assets, but instead provide advice in regard to economic, market
and investment outlook and investment strategy. We do not manage, and therefore will not execute brokerage (trades) for consulting
relationships.
Selection of Other Advisers: In some instances, in order to further diversify a client’s investment portfolio in accordance with a client’s
investment policy statement, we will recommend a client utilize additional money manager(s) via a sub-advisory or direct relationship.
3. Group Retirement Plans Utilizing a Third-Party Administrator
Greenwood Capital, in collaboration with a third-party administrator (TPA), provides two types of services to qualified group retirement
plans: investment education consulting and discretionary investment management. Consulting includes education on fiduciary
responsibilities for plan sponsors, and general investment education about diversification, risk/return, time horizon, etc. for participants.
Discretionary investment management includes investment educational consulting services, as well as providing investment allocation
models and security recommendations for inclusion in the plan to the TPA (used by participants during the investment selection process).
As a discretionary investment manager, as defined by section 3(38) of ERISA, Greenwood Capital would be a named fiduciary to the
retirement plan, developing and monitoring the investment policy statement (IPS), with the authority to make changes to the IPS and
investment options on behalf of plan participants and beneficiaries. Plan sponsors would maintain fiduciary responsibility for the oversight
of Greenwood Capital’s services, as well as other plan providers.
Class Action Services
Beginning 2Q 2024, our firm will use Broadridge's Global Securities Class Action Services to monitor class action shareholder lawsuits
and file claims on behalf of its clients to participate in cases where they may be eligible to receive proceeds due to legal settlements.
Processing of class action claims is subject to a contingency fee assessed directly by Broadridge; in the event a recovery is made. Broadridge
pays class action recovery funds directly to our clients, less the contingency fee. Clients may opt out of this service by advising us in writing.
Services Limited to Specific Types of Investments
Greenwood Capital generally limits its Investment Advisory services and Institutional Investment Management to public equities,
public interest-bearing securities, ETFs, REITs (real estate investment trusts), and mutual funds. In some instances, we might use other
security types – including alternatives such as private equity, private debt, private real estate, hedge funds, and direct placement – to help
diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions
Greenwood Capital structures investment portfolio(s) based upon client Investment Advisory (B.1) and Investment Management (B.2)
needs, utilizing SMAs or UMAs to customize investment portfolios for each client. Clients can request restrictions in investing in certain
securities or types of securities following their values or beliefs. However, if the restrictions prevent us from properly servicing the client
account, or if the restrictions would require us to deviate from our standard suite of services, Greenwood Capital reserves the right to end
the relationship.
D. Wrap Fee Programs
Greenwood Capital does not currently take part in any wrap fee programs.
E. Amounts Under Management
Greenwood Capital Associates, LLC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$1.519 billion $0 February 29,2024