Firm History
Steward Partners Investment Solutions, LLC (“Adviser,”, “Firm”, “we,” or “SPIS”), a limited liability
company organized under the laws of the State of Delaware, is a registered investment adviser primarily
based in Portland, OR. We became registered with the Securities and Exchange Commission (the “SEC”)
on September 28, 2006, as a registered investment adviser and are principally owned by Steward
Partners Management Holdings, LLC (“SPMH”). Our affiliates, Steward Partners Investment Advisory, LLC
(“SPIA”), Monaco Capital management, LLC (“MCM”), and Elan Wealth Management, LLC (“EWM”)
(hereinafter collectively referred to as "Affiliated Advisers”) are separate SEC-registered investment
advisers. SPIS, its Affiliated Advisers and Steward Partners Global Advisory, LLC (“SPGA”), also a wholly
owned subsidiary of SPMH, are affiliates and separately operated. SPGA provides corporate and related
services to SPIS and its Affiliated Advisers. Registration of an investment adviser with the SEC does not
imply any level of skill or training.
Investment Advisory Services
The Firm is both a registered investment adviser and a registered broker-dealer. In our combined role as
a broker/dealer and a registered investment adviser, we may provide comprehensive financial planning
advice to our clients as well as standard broker-dealer services for traditional brokerage accounts. This
advice can include cash management, risk management (insurance planning/sales), investment
planning (including investment advice, supervisory services and/or portfolio checkups), retirement
planning (for employees and employers), and/or estate planning strategies.
Steward Partner’s registration as a broker-dealer is material to our advisory business because advisory
accounts are custodied with Pershing, a third-party custodian, where we act in our capacity as an
introducing broker-dealer. This results in additional forms of compensation to Steward Partners which
are discussed in this brochure. See Item 12 – Brokerage Practices – Pershing Clearing Relationship.
Some investment advisor representatives are licensed as insurance agents for an affiliate of SPIS. The
conflicts of interest associated with the above arrangements and how these conflicts are addressed are
described in Section 5. Please also see Item 15 of the ADV Part 2A Firm Brochure– Custody, regarding
our custody and clearing firm Pershing, LLC (“Pershing”). SPIS has no banking division.
SPIS provides investment management services to individuals and businesses including investment
advice, portfolio checkups, retirement planning (for individuals, employees, and employers), and/or
estate planning strategies. We help clients coordinate and prioritize their financial lives with all aspects
of their life goals. Client input and involvement are critical parts of the planning process and
implementation of investment decisions. After Client assets are invested in an advisory account, on an
ongoing basis the IAR will monitor the investments and provide advice related to financial and
investment needs.
SPIS has a fiduciary duty to provide services consistent with the Client's best interest. We offer
discretionary and non- discretionary portfolio management services generally exercised within the
auspices of the managed account program. Regardless of the program(s) selected, when you engage
for portfolio management services, we will consult with you to discuss your financial circumstances and
objectives and to assist you in determining (a) an appropriate set of financial goals,
(b) a time horizon for your investments, and (c) your level of risk tolerance. Based on our evaluation of
your financial situation, we will provide you with recommendations as to which investment program is
the most appropriate for management of your assets and as to which particular investments, asset
allocation models, and/or underlying third-party managed investment program(s) is suited for your
investment profile. Our investment advice is tailored to meet our Clients' needs and investment
objectives.
As part of its investment advisory services, SPIS will review Client portfolios on an ongoing basis to
determine whether changes are necessary based upon a change in the Client's investment objective,
risk tolerance or other factors. Based upon this, there will be extended periods of time when we
determine that changes to a Client's portfolio or the investment program are not necessary, nor
prudent. Clients remain subject to the fees described in Item 5 during periods of account inactivity. As
indicated below, there can be no assurance that investment recommendations and decisions made by
SPIS will be profitable or equal any specific performance level(s).
We offer advice on a broad range of securities including, but no limited to, mutual funds, exchange-
traded funds, exchange- listed equity securities, alternative investments, municipal securities, corporate
bonds, U.S. government securities and money market funds. We do not primarily recommend one
particular type of security over another since each Client has different needs and a different tolerance
for risk. Clients may impose reasonable restrictions on investing in certain securities or types of
securities.
Client funds are managed with either discretionary or non-discretionary authority. For non-
discretionary clients in Client Direct Programs, we must first obtain your approval prior to executing any
transactions in your Account(s). For discretionary clients in both Investment Adviser Representative
(“IAR”) Directed Programs and Third Party Manager Directed Programs, investment recommendations
are executed on their behalf without prior approval of each specific transaction.
Investment Advisory Programs (“Programs”) and Products
Custodian - Pershing, LLC (“Pershing”)
• Steward Partners Managed Account Solutions
o Steward Partners Separate Account Solutions - Equity /Balanced
o Steward Partners Separate Account Solutions - Fixed Income
o Steward Partners Separate Account Solutions - Model Equity /Balanced
o Steward Partners Separate Account Solutions - Model Fixed Income
o BNY Mellon Advisors2 Asset Allocation Portfolios
o BNY Mellon Advisors2 WealthStart & American Funds
o Steward Partners Strategy Solutions
• BNY Mellon Advisors2 AdvisorFlex Portfolios
• Steward Partners Unified Managed Accounts
o Steward Partners Unified Managed Accounts
• Steward Partners Personalized Portfolios (previously known as “Steward Partners Advisory Program”)
o Steward Partners Discretionary Portfolios (previously known as “Steward Partners
Advisory Program – Discretionary”)
o Steward Partners Guided Portfolios (previously known as “Steward Partners
Advisory Program – Non- discretionary”)
The following Programs which have been discontinued effective March 28, 2024:
Custodian - Folio Investments, Inc., A Goldman Sachs Company (“Folio”)
• Steward Partners Personalized Portfolios (previously known as “Steward Partners Advisory
Program”)
• Steward Partners UMA Program (Only on Folio)
Custodian - Wells Fargo Clearing Services (“FCC”)
• Custom Choice Program
• Asset Advisor Program
• Private Investment Management (PIM) Program
Recommending Third-Party Money Managers (“Managers”)
We may recommend Managers for the management of your accounts. Managers selection is guided
by your stated objectives (i.e., capital appreciation, growth, income, or growth and income), as well as
tax considerations. Investments are made in conventional categories including stocks, bonds, and
cash. You may impose reasonable restrictions on investing in certain securities, types of securities, or
industry sectors. In managing your investment portfolio, we consider your financial situation, risk
tolerance, investment horizon, liquidity needs, tax considerations, investment objectives, and any
other issues important to your financial affairs. You should notify us promptly if there are any
changes in your financial situation, investment objectives, or restrictions upon the management of
your account.
The Managers recommended by us are chosen for their approach in building portfolios that are
designed to mitigate downside risk, offer consistency over time, and offer values-based options as
well when applicable. Assets may be managed through a model portfolio that is applied universally
to all accounts invested in the model (the “Investment Strategies”). The Manager will oversee the
Investment Strategies on a discretionary basis, which means they will purchase and sell securities
for your account(s) without first consulting with or obtaining specific authorization from you or your
IAR. The Manager manages the Investment Strategies in accordance with its stated investment
objectives, not according to the client’s investment goals. The Manager will monitor the Investment
Strategies on an ongoing basis. Managers may have minimum account balance requirements to
invest in the Investment Strategies.
When working with a Manager, we will be responsible for determining the suitability of the
investment strategies to be provided by the Manager and assisting you in determining which
Manager services are appropriate based on your specific investment goals and objectives, now and
in the future. We will monitor performance and are available to discuss the selected Manager's
strategy and/or performance. Clients recommended for these programs will receive complete
program descriptions, including services, fees, payment structures, and termination features, all of
which are found in the respective disclosure brochures, investment advisory agreements, and
account opening documents, as well as related solicitor disclosure notices.
Advised Retirement Plan Accounts Program
We utilize an unaffiliated third-party platform that can allow an IAR of the Firm to facilitate the
management of held-away assets for certain employer-sponsored retirement plan assets on a
discretionary basis. Through this platform, the Firm does not take custody of your funds and does not have
direct access to your account(s). A link will be provided to the Client, allowing them to connect account(s)
to the platform. Once your account(s) is connected to the third-party platform, your IAR will review the
current account(s) allocations and, when necessary, will make any changes
in the current holdings and/or
future allocations based on their understanding of your goals, objectives, risk tolerance, and any other
circumstances necessary to make investment changes within the account. Account allocations are limited
based on the options made available by the employer-sponsored plan and such limitations may impact
the IARs ability to effectively manage the assets. Please be mindful that should your employer-sponsored
plan make a “brokerage window” available, your IAR will not be able to manage securities through this
feature.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services include an existing plan review and analysis, plan-level advice regarding fund selection and
investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor
or other named fiduciary.
• We also offer assistance with participant enrollment meetings and provide investment-related
educational seminars to plan participants on such topics as: diversification, asset allocation, risk
tolerance, and time horizon.
Our educational seminars include other investment-related topics specific to the particular plan.
We also provide additional types of pension consulting services to plans on an individually negotiated
basis. All services, whether discussed above or customized for the plan based upon requirements from
the plan fiduciaries (which may include additional plan-level or participant-level services) shall be
detailed in a written agreement and be consistent with the parameters set forth in the plan
documents.
We will determine with the Client in advance the scope of services to be performed and the fees for all
requested services. Prior to engaging us to provide consulting services, the Client will be required to
enter into a written agreement with us setting forth the terms and conditions of the engagement,
describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements.
The services outlined above that we provide are explained in more detail in the written agreement. We
will also provide additional disclosures about our services and fees, where required by ERISA. When we
perform the agreed upon services, we will rely on the Client to provide accurate and consistent
information, and we will not be required to verify the accuracy or consistency of any information
provided by the Client. We will serve in a non-discretionary ERISA fiduciary capacity with respect to
some but not all of the services that we provide, which will be further explained in the written
agreement we sign with the Client. The Client is always free to seek independent advice about the
appropriateness of any recommendations made by us.
The agreement we sign with the Client includes the disclosures required of Advisory Representative
under Section 408(b)(2) of ERISA, in particular, (i) the services to be provided by Advisory Representative,
(ii) the extent to which Advisory Representative is acting as a fiduciary, (iii) the compensation to be
received by Advisory Representative, and the manner of receipt of that compensation, and (iv) any fees
payable on termination of the agreement. Advisory Representative receives no indirect compensation in
respect of the services provided pursuant to the agreement. We retain a portion of the compensation
described in the agreement for our services in connection with the agreement, the amount of which
varies with our arrangement with each Advisory Representative. Pursuant to the agreement, Advisory
Representative neither provides recordkeeping services nor makes available any designated investment
alternative for the plan nor advises any investment contract, fund or entity in which the plan has a direct
equity investment, and no disclosures under Section 408(b)(2) are thus required to be provided in
respect of those matters.
IMPORTANT DISCLOSURES
You may notice differences between the information contained in this brochure and in the individual
Program Agreements. Such differences may arise when, for example, changes to the Program
Agreement were separately negotiated with you or were required by your IAR when offering the
Program to you. Differences may also arise due to changes in our programs or our policies, or because of
intervening events. Where there are differences that may exist, now or later, the terms of the
Investment Advisory Agreement will control (which may also be amended.) We will notify Clients of any
pending changes to their Program Agreement prior to any change implementations.
Differences between how investment advisory accounts are managed versus other commission-
based brokerage accounts.
When you choose to purchase products and services through SPIS you have the option of investing
through a transaction- based account, such as a brokerage account, a fee-based investment advisory
program, or both. It is important for you to understand the services you will receive, the fees, costs, and
expenses you will pay, and SPIS’ and your IAR’s conflicts of interest in connection with each of these
different types of accounts and relationships with SPIS. These services, fees, costs, expenses, and
conflicts of interest are described in this document and in further detail, in SPIS’s Form CRS, Regulation
Best Interest (“Reg BI”) Disclosure Document, and this Forms ADV, Part 2A, which are available on SPIS’s
website under the “Regulatory Information & Disclosures” section.
The Firm’s (and the Representatives’) legal, contractual, and regulatory obligations differ in important
ways, depending on the type of account(s) you have with us (brokerage or investment advisory), and the
products or services we provide. Investment advisory accounts and services are governed by laws and
regulations which are, in many ways, different from those that govern brokerage accounts and services.
When acting as an investment Adviser, we are a fiduciary for our Client. As a fiduciary, the Firm must,
among other duties, act in your best interests, place your interests ahead of our own, and make full and
fair disclosure of all material facts, particularly conflicts of interest.
When acting as a broker-dealer for non-ERISA accounts, we must observe high standards of
commercial honor, just and equitable principles of trade, and must have reasonable grounds for
believing its recommendations are suitable and in the best interest for you, among other duties.
However, our obligation to disclose to brokerage customers information about our business, conflicts of
interest, compensation, and other matters is more limited than our corresponding obligations to our
advisory Clients.
Clients are encouraged to contact their IAR to discuss any questions about which products or services
we provide in each of these capacities, and which are in your best interest as a client. Some factors to
consider when deciding between an investment advisory and brokerage relationship may include, but
are not limited to;
Advisory Relationship clients:
• Seek ongoing advice and monitoring on your account.
• Prefer to pay an ongoing advisory fee, based upon assets under management as opposed to a
commission on a per- transaction basis,
• Seek a fiduciary relationship with an IAR who must act in your best interest.
• Periodic portfolio rebalancing.
Brokerage Relationship clients:
• Seek advice only on individual transactions with no ongoing monitoring of your investments.
• Prefer commission-based compensation paid on a per transaction basis.
• Seek a relationship with a financial professional who must make recommendations in your best
interest.
Even though the firm offers both brokerage and advisory services, some of our IARs are only registered to
offer only advisory relationships.
Fiduciary Responsibility for Retirement Accounts
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 (ERISA) 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 interests, 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.
Transition to Steward Partners Investment Advisory on or about July 1, 2024
SPIS will transition advisory services for advisory accounts to our affiliated entity, Steward Partners
Investment Advisory LLC (“SPIA”), an SEC-registered investment adviser (“SPIA”) (collectively, the
“Transition”) on or about July 1, 2024, (the “Transition Date”). On the Transition Date, unless you
communicate your election to opt out of the Transition, your advisory services for your account(s) will be
provided by SPIA. Unless otherwise communicated, your financial advisor will continue to service your
account(s) at Steward Partners. Your account(s) will be assigned to SPIA on substantially the same terms
and conditions as of the Transition Date, as outlined in your SPIS investment advisory agreement. Upon
assignment, SPIA will assume the role of your investment adviser, and SPIS will remain the broker/dealer.
Assets Under Management
Adviser’s Assets (rounded to the nearest thousand) under Management (“AUM”) on December 31, 2022:
Discretionary Accounts $870,848,599
Non-Discretionary Accounts $120,032,113
Total AUM $990,880,713