Stewart Capital Advisors LLC (“SCA”) became an SEC registered investment adviser as of May
2005 and is a wholly owned subsidiary of S&T Bank. S&T Bank has established a reputation
amongst its customer base for high quality customer service and banking and investment
products over its more than one hundred year life. SCA’s office location is in Indiana, PA.
SCA currently provides investment advisory services to institutional clients.
Additionally, SCA provides investment subadvisory services to its affiliate S&T Bank. S&T
Bank provides Trust services to its clients including the investment of securities of client
portfolios that are managed on a discretionary basis by SCA in accordance with an Investment
Policy Statement containing the client’s stated investment objectives and risk tolerance.
As of December 31, 2023:
Discretionary Assets Under Management $ 1,094,564,626
Non-Discretionary Assets Under Management $0
Total $1,094,564,626
SCA’s first priority is protecting clients’ money by staying within the spectrum of acceptable
risk based on each client’s specified risk tolerance. As a registered investment adviser subject
to Section 206 of the Advisers Act, SCA acts as a fiduciary related to the conduct of its
investment advisory services. As such, SCA has an obligation to act in the best interest of its
clients guided by the core fiduciary duties of loyalty and care.
Under normal market conditions, SCA will invest primarily in large-cap, mid-cap and small-cap
stocks. A portion of client assets may also be invested in fixed income investments. The
percentage of assets allocated between equity and fixed income securities is flexible rather
than fixed.
SCA uses fundamental research and stock selection processes to identify sectors and
companies positioned to capitalize on certain themes. SCA may use one of several
standardized portfolios (i.e., Mid Cap, All Cap, Large Cap Value, Fixed Income, Short Asset,
Equity Income) in order to adequately address client needs. The portfolios were created to
enable SCA to establish, trim and/or eliminate positions on a pro rata basis across all like
managed accounts. Please refer to Item 8 below for more information about SCA’s investment
strategies.
SCA’s portfolio managers allocate client assets among SCA’s managed portfolios (listed
above), various mutual fund and private fund investments as well as SCA’s model portfolio
strategies and mutual fund asset allocation strategies described in Item 8 below. Additional
information regarding SCA’s managed portfolios is available upon request.
Clients may impose reasonable restrictions on their account and/or place trades as a result of
their own personal research, needs and desires. If, in the opinion of SCA, a restriction or a
client directed trade would subject the client’s portfolio to risks that are contrary to the client’s
Investment Policy Statement, SCA may request additional information from the client and/or
S&T Bank. SCA would not be responsible for any gains or losses incurred by clients as a result
of any restrictions and/or trades directed by them.
Trades on behalf of SCA’s clients are placed through any of the brokers on SCA’s Approved
Brokers List. This list is updated on a semi-annual basis by the Investment Policy and Strategy
Committee. Please refer to Item 12 for more information regarding the Investment Policy and
Strategy Committee and SCA’s brokerage practices.
Retirement Plan Services
SCA may provide certain investment management or investment advisory services to
employer-sponsored retirement plans (“Retirement Plan”). The terms of any such services are
governed by the contract between the Plan Sponsors and SCA and may differ from the
Institutional Clients fee schedules shown below.
SCA acts as a fiduciary of Retirement Plan assets under Section 3(21) of ERISA by providing
Plan level non-discretionary investment advisory services regarding the asset classes and
investment alternatives available within a particular Retirement Plan. SCA will provide
recommendations to the Plan Sponsor who will retain the final decision-making authority
regarding the selection, retention, addition and removal
of investment options. SCA may also
act as a fiduciary of Plan assets under Section 3(38) of ERISA. In this case SCA, through their
agreement with the Plan Sponsor, provides its managed portfolios as options within the Plan
and has full discretionary authority over the investment of Plan assets.
Product Platforms:
SCA may enter into separate agreements with other unaffiliated financial institutions (the
“Platform Sponsors”) enabling them to offer any of SCA’s model portfolios to their clients
(“Platform Clients”) via their product platforms. Pursuant to the terms of the agreements with
the Platform Sponsors, SCA continuously reviews, supervises and administers the portfolios as
well as provides ongoing investment management services with respect to the assets of
Platform Clients. SCA has full discretionary authority over those assets and will execute
transactions on behalf of a Platform Client in accordance with the model portfolio chosen by
them.
Through the Product Platform service described above, no personalized investment advice is
provided by SCA to the Platform Sponsors/Financial Institution or any of their clients. In the
event that a client chooses to invest in one of SCA’s model portfolios, SCA will receive a fee
directly from the Platform Sponsor/Financial Institution. The terms of any such fee
arrangement are governed by the contract between the Platform Sponsor/Financial Institution
and SCA and may differ from the fee schedules shown below.
IRA Rollover
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”)
Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with
the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable,
we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your 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 your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. Under this special
rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give
prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Investors considering rolling over assets from a qualified employer-sponsored retirement plan
(“Employer Plan”) to an Individual Retirement Account (“IRA”) should review and consider the
advantages and disadvantages of an IRA rollover from their Employer Plan. A plan participant
leaving an employer typically has four options (and may engage in a combination of these
options):
(1) Leave the money in the former employer’s plan, if permitted;
(2) Rollover the assets to a new employer’s plan (if available and rollovers are permitted);
(3) Rollover Employer Plan assets to an IRA; or,
(4) Cash out the Employer Plan assets and pay the required taxes on the distribution.
At a minimum, Investors should consider fees and expenses, investment options, services,
penalty-free withdrawals, protection from creditors and legal judgments, required minimum
distributions, and employer stock. We encourage you to discuss your options and review the
above listed considerations with an accountant, third-party administrator, investment advisor
to your Employer Plan (if available), or legal counsel, to the extent you consider necessary.
We have an economic incentive to encourage investors to rollover Employer Plan assets into an
IRA managed by us, as we will earn fees as a result.