Overview
- Headquarters
- Santa Barbara, CA
- Total Firm Assets
- $205 million
- Average High-Net-Worth Client Portfolio Size
- $2.7 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (BLUE MARBLE INVESTMENTS, FORM ADV PART 2A AND PART 2B)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.10% |
| $500,001 | $1,000,000 | 0.65% |
| $1,000,001 | $2,000,000 | 0.55% |
| $2,000,001 | $5,000,000 | 0.50% |
| $5,000,001 | $10,000,000 | 0.35% |
| $10,000,001 | and above | 0.20% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $8,750 | 0.88% |
| $5 million | $29,250 | 0.58% |
| $10 million | $46,750 | 0.47% |
| $50 million | $126,750 | 0.25% |
| $100 million | $226,750 | 0.23% |
Clients
- High-Net-Worth Share of Firm Assets
- 66.35%
- Number of High-Net-Worth Clients
- 50
- Total Client Accounts
- 411
- Discretionary Accounts
- 411
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 141354
Primary Brochure: BLUE MARBLE INVESTMENTS, FORM ADV PART 2A AND PART 2B (2026-05-07)
View Document Text
Blue Marble Investments, LLC
CRD #141354
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
www.bluemarble.com
www.earthfolio.net
Form ADV, Part 2A Brochure
May 6, 2026
This brochure provides information about the qualifications and business practices of Blue Marble
Investments, LLC. If you have any questions about the contents of this brochure, please contact us at
805.595.1820. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state securities authority.
Any reference to or use of the terms "registered investment adviser'' or "registered," does not imply
that Blue Marble Investments, LLC or any person associated with Blue Marble Investments, LLC has
achieved a certain level of skill or training.
Additional information about Blue Marble Investments, LLC is available on the SEC's website at
www.adviserinfo.sec.gov.
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ITEM 2 - MATERIAL CHANGES
Billing Method Update:
Blue Marble Investments, LLC has updated its fee billing practices to provide that advisory fees
are billed quarterly in advance instead of quarterly in arrears. Corresponding revisions have been
made to this brochure to reflect the change, including disclosure regarding the proration and
refund of unearned fees upon termination of the advisory relationship.
Custody Disclosure Update:
The brochure has also been revised to clarify disclosures related to the deduction of advisory fees
and the firm’s limited custody status.
Assets Under Management Update:
Blue Marble Investments, LLC has updated the assets under management information disclosed
in this brochure to reflect current regulatory assets under management as of the date of this
amendment.
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ITEM 3 - TABLE OF CONTENTS
BLUE MARBLE INVESTMENTS, LLC CRD #141354 ................................................................................................................. 1
FORM ADV, PART 2A BROCHURE .............................................................................................................................................. 1
ITEM 2 - MATERIAL CHANGES .................................................................................................................................................... 2
ITEM 3 - TABLE OF CONTENTS ................................................................................................................................................... 3
ITEM 4 -ADVISORY BUSINESS ..................................................................................................................................................... 5
ITEM 5- FEES AND COMPENSATION ......................................................................................................................................... 6
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................... 9
ITEM 7 - TYPES OF CLIENTS ........................................................................................................................................................ 9
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .................................................... 9
ITEM 9- DISCIPLINARY INFORMATION ..................................................................................................................................... 15
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................................... 15
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ......................................................................................................................................................................................... 16
ITEM 12 - BROKERAGE PRACTICES ....................................................................................................................................... 17
ITEM 13 - REVIEW OF ACCOUNTS ........................................................................................................................................... 18
ITEM 14-CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................................... 19
ITEM 15-CUSTODY ........................................................................................................................................................................ 19
ITEM 16 - INVESTMENT DISCRETION ....................................................................................................................................... 19
ITEM 17 - VOTING CLIENT SECURITIES .................................................................................................................................. 20
ITEM 18 - FINANCIAL INFORMATION ....................................................................................................................................... 20
FORM ADV, PART 2B BROCHURE SUPPLEMENT ................................................................................................................. 21
ARTURO A. TABUENCA CRD # 2134379 ................................................................................................................................. 22
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................................ 22
ITEM 3 - DISCIPLINARY INFORMATION ......................................................................................................................... 22
ITEM 4 - OTHER BUSINESS ACTIVITIES ........................................................................................................................ 22
ITEM 5 - ADDITIONAL COMPENSATION ......................................................................................................................... 22
ITEM 6- SUPERVISION ........................................................................................................................................................ 23
FORM ADV, PART 2B BROCHURE SUPPLEMENT ................................................................................................................. 24
LINDA SMITH SHELBY CRD# 1286574 ..................................................................................................................................... 25
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ................................................................ 25
ITEM 3 - DISCIPLINARY INFORMATION ......................................................................................................................... 25
ITEM 4 - OTHER BUSINESS ACTIVITIES ........................................................................................................................ 25
ITEM 5 - ADDITIONAL COMPENSATION ......................................................................................................................... 25
ITEM 6- SUPERVISION ........................................................................................................................................................ 25
FORM ADV, PART 2B BROCHURE SUPPLEMENT ................................................................................................................. 26
SIERRA KATHRYN SMITH CRD# 7373331 .............................................................................................................................. 27
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE ...................................................................... 27
ITEM 3- DISCIPLINARY INFORMATION ................................................................................................................................. 27
ITEM 4 - OTHER BUSINESS ACTIVITIES .............................................................................................................................. 27
ITEM 5 - ADDITIONAL COMPENSATION .............................................................................................................................. 27
ITEM 6- SUPERVISION ............................................................................................................................................................. 27
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ITEM 4 - ADVISORY BUSINESS
Description of Advisory Firm
Blue Marble Investments, LLC ("Blue Marble," "BMI", "we," "our," or "us") is a privately owned
limited liability company headquartered in Santa Barbara, California, and is an SEC registered
investment adviser.
Blue Marble is a socially active investment firm that offers managed portfolios that promote social
progress and environmental sustainability. Blue Marble registered as an independent investment
adviser in 2007. From 2000 to 2007, Blue Marble's manager provided socially responsible
investment advice through another registered investment advisory firm. Arturo Tabuenca is Blue
Marble's Managing Member and principal owner. Linda Shelby is Chief Compliance Officer/Chief
Administrative Officer and 5% Owner. Robert Shelby is an LLC member and 5% owner. Mr. Shelby
is not currently registered as an investment adviser representative, will not provide investment
advice to clients, and is not actively engaged in managing Blue Marble Investments, LLC. Sierra
Smith, Investment Adviser Representative, holds the CERTIFIED FINANCIAL PLANNER™
(CFP®) designation, awarded by the Certified Financial Planner Board of Standards, Inc.
Additional information regarding Ms. Smith's educational background, business experience, and
professional qualifications is provided in her Form ADV Part 2B Brochure Supplement.
Advisory Services Offered
EarthFolio® Accounts
In 2007, Blue Marble launched the EarthFolio portfolio series. EarthFolio is a collection of online
professionally managed portfolios that feature ESG screened (environmental, social, governance)
funds. EarthFolio is offered through a wrap fee program. The EarthFolio model portfolios are
designed to diversify the client's assets and are available in a range of asset allocation strategies to
address various investment objectives. These services are provided on a discretionary basis only.
Prior to opening an account, a client will complete a questionnaire on the website, which once
completed will suggest the most appropriate model based on the answers provided by the client
that pertained to the client's investment objectives, risk tolerance, and investment time horizon. If
the client decides to open an account with Blue Marble, the client will complete an application and
receive new account forms online, including an investment advisory agreement and Blue Marble's
Form ADV Part 2 brochure.
Other Client Relationships
Before Blue Marble registered as an investment adviser, Blue Marble's manager Arturo Tabuenca
provided investment advice to clients through Commonwealth Financial Network ("CFN"), a
registered investment adviser. In 2007, Arturo Tabuenca terminated his working relationship with
CFN, and Blue Marble became registered as an investment adviser. Blue Marble manages
accounts according to each client's individual investment objectives and in the same style and
same manner as they were managed at CFN. The management of these accounts may differ in
part in terms of the asset allocation, security selection, and timing of transactions from the
management of Blue Marble's EarthFolio accounts that are managed according to the range of
portfolio styles available. Blue Marble also accepts new clients that want a more customized
portfolio and do not want an EarthFolio account. These services are provided on a discretionary
basis only.
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Services Limited to Specific Types of Investments
In these accounts, we primarily invest in mutual funds and ETFs, but may also utilize additional
types of investments if they are appropriate to address the individual needs, goals, and objectives
of the client or in response to client request. We describe the material investment risks for the
primary securities that we utilize under the heading Specific Security Risks in Item 8 below. Blue
Marble may offer investment advice on any investment held by the client at the start of the
advisory relationship including, but not limited to, common and preferred stocks, warrants or rights
of domestic or foreign corporations, bonds, notes, and debentures. While these products are not
part of our typical advisory strategies, in certain instances they may be incorporated into a client's
actively managed portfolio rather than liquidated.
We discuss our discretionary authority below under Item 16 - Investment Discretion. For more
information about the restrictions clients can put on their accounts, see Tailored Services and Client
Imposed Restrictions in this Item below.
We describe the fees charged for the EarthFolio model portfolios and other client relationships
under Item 5 - Fees and Compensation, below.
Tailored Services and Client Imposed Restrictions
Clients investing in EarthFolio accounts will complete a web-based interactive questionnaire which
contains questions about the investor's time horizon and risk tolerance. The questionnaire is
designed to help the investor determine his/her appropriate investment profile based on the
answers he/she provides and to recommend the EarthFolio portfolio that appears to best match
his/her appropriate profile. Clients are restricted to the designated model positions and allocations
and may not tailor it to their preferences. Blue Marble manages the EarthFolio portfolios based on
the investment strategy discussed below under - Methods of Analysis, Investment Strategies, and
Risk of Loss.
For clients seeking a more tailored approach outside of EarthFolio, specific investment needs and
goals are determined via client interviews and a written investor profile. Tailored services typically
include tax- free bonds, individual equities, and institutional-class shares. Our investment advice
may not be suitable if the client does not provide us with accurate and complete information. It is
the client's responsibility to keep Blue Marble informed of any changes to their investment
objectives or restrictions.
Outside of the EarthFolio accounts, clients may request other restrictions on the account, such as
when a client needs to keep a minimum level of cash in the account or does not want Blue Marble
to buy or sell certain specific securities or security types in the account. Blue Marble reserves the
right to not accept and/or terminate management of a client's account if we feel that the client-
imposed restrictions would limit or prevent us from meeting or maintaining the client's investment
strategy.
Wrap Fee Programs
Blue Marble sponsors and acts as Portfolio Manager in our own wrap fee program, featuring
EarthFolio portfolios. The wrap fee program is described in our Form ADV Part 2A Appendix 1 wrap
fee program brochure.
Assets Under Management
As of May 6, 2026, Blue Marble's assets under management totaled $205,057,533.
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ITEM 5 - FEES AND COMPENSATION
Investment Management Services
EarthFolio Accounts
Clients' EarthFolio accounts are charged an annual management fee of 0.50% of assets under
management. EarthFolio fees are charged quarterly in advance. The advisory fee is determined by
the account's market value as of the last business day of the prior quarter. Clients do not pay
transaction fees for transactions in EarthFolio accounts, but may pay other fees charged by the
custodian, as noted below. Blue Marble does not negotiate fees on its EarthFolio Wrap Accounts.
Investment Advisory Accounts
Client accounts managed outside of the EarthFolio models are charged an annual management fee
based on the value of assets under management according to the following fee schedule:
Account Fee Schedule
Assets Under Management
Annual Management Fee
First $500,000 or portion
Next $500,000 or portion
Next $1,000,000 or portion
Next $3,000,000 or portion
Next $5,000,000 or portion
Over $10,000,000
1.10%
.65%
.55%
.50%
.35%
.20%
Management fees are charged quarterly in advance. Blue Marble may negotiate fees in certain
instances, particularly for charitable institutions or corporate clients. Multiple portfolios owned by
one household may be considered as one account to qualify for lower overall fees (except
business accounts). Lower fees for comparable services may be available from other sources.
Aggregated account information will be included on Schedule A of Client Agreement.
Additional Client Relationships
Arturo Tabuenca is a licensed insurance agent and registered securities representative of Purshe
Kaplan Sterling Investments ("PKS"), a non-affiliated registered broker-dealer and a member of the
Financial Industry Regulation Authority ("FINRA"). Mr. Tabuenca's activity with PKS represents a
minority of his time and is generally only conducted upon client request or for products outside the
scope of Blue Marble's socially responsible objective. A conflict of interest exists to the extent that
Mr. Tabuenca receives commissions and/or trailing service fees (12b-1 fees) related to the sale of
commissionable products and this practice gives him an incentive to recommend products based
on the compensation received, rather than on the client's needs. Therefore, clients are advised that
the client is under no obligation to act on these recommendations or purchase commissionable
products through Mr. Tabuenca as a registered representative. In all cases, insurance commissions
will be fully disclosed to the client.
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Commissions from these products are separate from any fees that Blue Marble receives for
advisory services. Clients have the right to utilize or decline to utilize the services of any
representative of Blue Marble in their outside capacity and have the right to purchase services or
products recommended by Blue Marble through another provider.
Billing Method
All management fees are billed quarterly in advance based on the market value of assets under
management as of the last business day of the prior billing period and are not adjusted for
changes in account value during the current billing period. Because advisory fees are based on
the amount of assets under management, Blue Marble has an incentive to encourage clients to
increase the assets in their accounts. In addition, because fees are billed in advance, the firm
has an incentive to retain clients throughout the billing period.
For new accounts, the initial fee will be prorated based on the number of days remaining in the
billing period. Upon termination of the advisory agreement, any unearned fees will be promptly
refunded to the client, and any earned but unpaid fees will be due and payable.
Clients authorize Blue Marble, in writing, to deduct advisory fees directly from their accounts held
with the qualified custodian. Such authorization is included in the advisory agreement. Each time
a fee is deducted, the qualified custodian will reflect the advisory fee on the client’s account
statement. Clients are encouraged to review these statements carefully and compare the fees
charged with the fee schedule described in this brochure and their advisory agreement. Clients
may contact Blue Marble with any questions on fee calculations.
Termination
Clients may terminate the advisory agreement without penalty within five (5) business days of signing
the agreement. Thereafter, either party may terminate the advisory relationship at any time upon
written notice. Advisory fees are billed quarterly in advance. Upon termination of the advisory
agreement, Blue Marble will calculate the unearned portion of any prepaid advisory fees based on the
number of days remaining in the billing period. Any unearned fees will be promptly refunded to the
client. If any earned but unpaid fees remain due at the time of termination, Blue Marble will invoice
the client for such amounts, and payment will be due upon receipt.
In the event of a client's death or cognitive impairment, Blue Marble will continue management of the
account until an authorized party notifies us of the client's death or cognitive impairment and gives us
alternative instructions.
Other Fees and Expenses
This brochure describes Blue Marble's non-wrap fee advisory services; clients utilizing Blue Marble's
wrap fee portfolio management should see the separate Wrap Fee Program Brochure for additional
details regarding third party fees. Client accounts not participating in the wrap fee program are
responsible for the payment of all third-party fees (i.e., custodian fees, commissions, brokerage fees,
mutual fund fees, transaction fees, etc.). Clients pay all transaction charges for institutional shares,
individual stocks and bonds, account transfer fees, and/or other similar charges incurred in connection
with transactions in accounts, from the assets in the account. These charges are in addition to the
fees clients pay to Blue Marble. In addition, all fees paid to Blue Marble for investment management
services are separate and distinct from the fees and expenses charged within mutual funds or
exchange traded funds held in a client's account. Mutual funds and ETFs charge internal management
fees and operational costs, including 12b-1 fees. These fees are indirectly charged to all holders of
the fund shares. Blue Marble investment adviser representatives do not receive 12b-1 fees for
investment advisory assets for which they are receiving a management fee. (Advisors may receive
12b-1 fees for client brokerage accounts in their capacity of registered representatives with PKS.)
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Clients with mutual funds or ETFs in their portfolios are effectively paying both Blue Marble and
the fund manager for the management of their assets. A client could invest in a mutual fund or
ETF directly, without using our services. In that case, the client would not receive the benefit of
services we provide, which includes analyzing and selecting funds, reviewing that the funds follow
ESG practices, determining a proper allocation mix, systematic rebalancing, and tax management.
Accordingly, the client should review both the internal fees charged by the funds and the advisory
fees we charge to understand the total amount of fees the client will pay and evaluate the advisory
services we provide accordingly.
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Blue Marble does not charge performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client and therefore does not engage in side-by-
side management.
ITEM 7 - TYPES OF CLIENTS
Blue Marble primarily provides investment advisory services to individuals (including high net
worth individuals, trusts and estates, and individual participants of retirement plans). In addition,
we offer advisory services to charitable organizations and businesses.
Account Requirements
The minimum investment required by an individual client is generally $500,000. The minimum
account size for accounts invested according to the EarthFolio models is $25,000. Accounts
below these minimums may be accepted on an individual basis at Blue Marble's discretion.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
EarthFolio Model Portfolios
The EarthFolio models are socially and environmentally screened portfolios designed to provide
a diversified asset allocation to clients based on the client's investment objectives
and risk tolerance.
EarthFolio comes in a range of portfolio styles, each designed to help match the needs of varying
investors based on their individual goals, risk tolerances, and time horizons.
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The EarthFolio Investment Process
Blue Marble follows a multi-step process in determining the securities to include in the model
portfolios:
Step 1 - Fund Universe: EarthFolio invests exclusively in funds categorized as Sustainable or
Socially Responsible, which are screened for environmental, social, and corporate
governance (ESG) factors.
Step 2 - Asset Allocation: EarthFolio models are strategically allocated across a range of
portfolio objectives designed to maximize long-term returns and lower risk.
Step 3 - Fund Selection: Final fund selections are made based on relative quality and
performance in areas such as capitalization, style consistency, operating expenses, and
passive management.
Step 4 - Portfolio Construction: Portfolios are implemented based on client's responses to the
investment questionnaire identifying their investment goals and risk tolerances.
Step 5 - Management and Monitoring: Individual asset allocations are periodically rebalanced
to their original portfolio objectives and underlying funds are monitored relative to peer
performance and benchmarks.
Blue Marble monitors the performance of each holding against a stated benchmark. Additionally,
active rebalancing is employed by Blue Marble in an effort to maintain the portfolio's integrity and
enhance its ability to pursue long-term growth.
EarthFolio's Integration of ESG Criteria
EarthFolio models are globally diversified and invest in a broad range of equity funds,
fixed-income funds, and money market funds. Funds selected for EarthFolio must pass rigorous
financial screens, and just as importantly, invest in companies committed to ethical practices.
Ethical practices fall into three broad categories: the environment, social progress, and corporate
governance.
This type of investing is classified as Socially Responsible Investing, Sustainable Investing or
Environmental, Social, and Governance (ESG) Investing, and is the hallmark of EarthFolio. Some
of the most common ESG screens employed include:
Conservation
Clean Tech
Equality and Diversity
Human Rights
Fair Labor
Animal Welfare
Non-Violence
Corporate Governance
Healthy Living
Community Development
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Investment Advisory Accounts
For clients seeking a more tailored approach outside of EarthFolio, specific investment needs and
goals are determined via client interviews and a written investor profile. Tailored services may
include tax-free bonds, individual equities, and institutional-class shares.
Blue Marble uses strategic portfolio management and carefully selects funds based on key metrics
such as category integrity, verifiable ESG criteria, adherence to index performance, low operating
expenses, etc.
We gather our information from a variety of sources, including financial newsletters and websites,
third party research, corporate ratings services, and company filings and releases.
Investing Involves Risk
Investing in securities always involves the risk that you will lose money. Before investing in the
securities markets, clients should be prepared to bear that risk. Over time, a client's account value
will fluctuate. At any time, your assets may be worth more or less than the amount you invested.
Blue Marble makes no guarantees or promises that our market analysis will be accurate or the
investment strategies we use will be successful.
Clients investing in an EarthFolio account will have a model portfolio recommended to them based
on their investment profile as determined by an interactive web-based questionnaire. Clients may
decide to invest in portfolio different than the one recommended; however, clients should
understand that if they choose a model that was not recommended, the model may not be as
appropriate for the client (may have higher risk or lower return potential) as the model
recommended, based on the client's time horizon and risk tolerance.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly involving
the issuers of securities held as underlying assets of funds in a client's account, conditions affecting
the general economy, and overall market changes. Other contributing factors include local, regional,
or global political, social, or economic instability and governmental or governmental agency
responses to economic conditions. Finally, currency, interest rate, and commodity price fluctuations
may also affect security prices and income.
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Mutual Funds (Open-End Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in
stocks, bonds, short-term money-market instruments, other securities or assets, or some
combination of these investments. The portfolio of the fund consists of the combined holdings it
owns. Each share represents an investor's proportionate ownership of the fund's holdings and the
income those holdings generate. The price that investors pay for mutual fund shares is the fund's
per share net asset value (NAV) plus any shareholder fees that the fund imposes at the time of
purchase (such as sales loads). All mutual funds within EarthFolio accounts are purchased at
NAV, with sales loads waived.
Mutual funds have benefits such as professional management, diversification, affordability, and
liquidity. However, they also have features that some investors might view as disadvantages:
Costs Despite Negative Returns
Investors must pay management costs and internal fund expenses regardless of how the
fund performs. Depending on the timing of their investment, investors may also have to pay
taxes on any capital gains distribution they receive. This includes instances where the fund
went on to perform poorly after purchasing shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund's portfolio at any given time,
nor can they directly influence which securities the fund manager buys and sells or the
timing of those trades.
Price Uncertainty
With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or your
investment adviser. Investors can also monitor how a stock's price changes from hour to
hour-or even second to second. By contrast, with a mutual fund, the price at which an
investor purchases or redeems shares will typically depend on the fund's NAV, which the
fund might not calculate until many hours after the investor placed the order. In general,
mutual funds must calculate their NAV at least once every business day, typically after the
major U.S. exchanges close.
Different Types of Funds
When it comes to investing in mutual funds, investors have literally thousands of choices. Most
mutual funds fall into one of three main categories; money market funds, bond funds (also called
"fixed income" funds), and stock funds (also called "equity" funds). Each type has different features
and different risks and rewards. Generally, the higher the potential return, the higher the risk of loss.
Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and most other
investments). By law, they can invest in only certain high quality, short-term investments issued by
the U.S. Government, U.S. and foreign corporations, state and local governments, and bank issued
certificates of deposit. Money market funds try to keep their net asset value (NAV), which
represents the value of one share in a fund, at a stable $1.00 per share. However, the NAV may fall
below $1.00 if the fund’s investments perform poorly. Investor losses have been rare, but they are
possible. Money market funds pay dividends that generally reflect short-term interest rates, and
historically the returns for money market funds have been lower than for either bond or stock funds.
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That is why “inflation risk,” the risk that inflation will outpace and erode investment returns over time,
can be a potential concern for investors in money market funds.
Stock Funds
Although a stock fund's value can rise and fall quickly (and dramatically) over the short term,
historically stocks have performed better over the long term than other types of investments. This is
true for corporate bonds, government bonds, and treasury securities. Overall "market risk" poses
the greatest potential danger for investors in stock funds. Stock prices can fluctuate for a broad
range of reasons- such as the overall strength of the economy or demand for particular products or
services. Not all stock funds are the same. For example:
Growth Funds
Growth funds focus on stocks that may or may not pay a regular dividend but have the
potential for large capital gains. These funds favor companies expected to grow earnings,
which could result in stock prices rising faster than the economy and may be smaller and
less seasoned companies. The smaller and less seasoned companies that may be in a
growth fund have a greater risk of price volatility. Growth stocks, which can be priced on
future expectations rather than current results, may decline substantially when expectations
are not met or general market conditions weaken.
Equity Income Funds
Equity income funds stress current income over growth and may invest in stocks that pay
regular dividends. These funds are subject to dividend payout risk, which is the possibility
that a number of the companies in which the fund invests will reduce or eliminate the
dividend on the securities held by the fund.
Small Cap Funds
Funds that invest in stocks of small companies involve additional risks. Smaller companies
typically have higher risk of failure and are not as established as larger blue-chip companies.
Historically, smaller- company stocks have experienced a greater degree of market volatility
than the overall market average.
Mid Cap Funds
Funds that invest in companies with mid-range market capitalizations involve additional
risks. The securities of these companies may be more volatile and less liquid than the
securities of larger companies.
Index Funds
Index funds aim to achieve the same return as a particular market index, such as the S&P
500 Composite Stock Price Index or the Calvert U.S. Large Cap Core Index, by investing in
all-or perhaps a representative sample-of the companies included in an index.
International Funds
International investments are subject to additional risks, including currency fluctuation,
political instability, and potential illiquid markets.
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Emerging Market Funds
Funds that invest in foreign securities of smaller, less-developed countries involve special
additional risks. These risks include, but are not limited to currency risk, political risk and risk
associated with varying accounting standards. Investing in emerging markets may
accentuate these risks.
Sector Funds
Sector funds may specialize in a particular industry segment, such as technology or
consumer products stocks. Funds that invest exclusively in one sector or industry involve
additional risks. The lack of industry diversification subjects the investor to increased
industry-specific risk.
Bond Funds
Bond funds generally have higher risks than money market funds, largely because they typically
pursue strategies aimed at producing higher yields. Unlike money market funds, the SEC's rules do
not restrict bond funds to high quality or short-term investments. Because there are many different
types of bonds, bond funds can vary dramatically in their risks and rewards. Some of the risks
associated with bond funds include:
Credit Risk
There is a possibility that companies or other issuers may fail to pay their debts (including
the debt owed to holders of their bonds). Consequently, this affects mutual funds that hold
these bonds. Credit risk is less of a factor for bond funds that invest in insured bonds or
U.S. Treasury Bonds. By contrast, those that invest in the bonds of companies with poor
credit ratings generally will be subject to higher risk.
Interest Rate Risk
There is a risk that the market value of the bonds will go down when interest rates go up.
Because of this, investors can lose money in any bond fund, including those that invest only
in insured bonds or U.S. Treasury Bonds. Funds that invest in longer-term bonds tend to
have higher interest rate risk.
Prepayment Risk
Issuers may choose to pay off debt earlier than the stated maturity date on a bond. For
example, if interest rates fall, a bond issuer may decide to "retire" its debt and issue new
bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the
proceeds in an investment with as high a return or yield.
TIPS Funds
Treasury Inflation Protected Securities (TIPS) are inflation-indexed securities structured to remove
inflation risk. TIPS are indexed to an inflationary gauge to protect investors from the decline in the
purchasing power of their money. The value of TIPS will increase with inflation but will decrease
with deflation.
Exchange-Traded Funds (ETFs)
ETF is a type of Investment Company (usually, an open-end fund or unit investment trust) containing
a basket of stocks. Typically, the objective of an indexed ETF is to achieve returns similar to a
particular market index, including sector indexes.
13
An ETF is similar to an index fund in that it will primarily invest in securities of companies that are
included in a selected market. Unlike traditional mutual funds, which can only be redeemed at the
end of a trading day, ETFs trade throughout the day on an exchange. Like stock mutual funds, the
prices of the underlying securities and the overall market may affect ETF prices.
Similarly, factors affecting a particular industry segment may affect ETF prices that track that
particular sector. An ETF is an investment fund traded on stock exchanges, similar to stocks.
Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a
stock holding bankruptcy). Areas of concern include the lack of transparency in products and
increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance.
Because ETFs use "authorized participants" (APs) as agents to facilitate creations or redemptions
(primary market), there is a risk that an AP decides to no longer participate for a particular ETF;
however, that risk is mitigated by the fact that other APs can step in to fill the vacancy of the
withdrawing AP [an ETF typically has multiple APs] and ETF transactions predominantly take
place in the secondary market without need for an AP. Like other liquid securities, ETF pricing
changes throughout the trading day and there can be no guarantee that an ETF is purchased at
the optimal time in terms of market movements. Moreover, due to market fluctuations, ETF
brokerage costs, differing demand and characteristics of underlying securities, and other factors,
the price of an ETF can be lower than the aggregate market price of its cash and component
individual securities (net asset value - NAV). An ETF is subject to the same market risks as those
of its underlying individual securities, and also has internal expenses that can lower investment
returns.
Tax Consequences of Mutual Funds
When investors buy and hold an individual stock or bond, the investor must pay income tax each
year on the dividends or interest the investor receives. However, the investor will not have to pay
any capital gains tax until the investor actually sells and makes a profit. Mutual funds are different.
When an investor buys and holds mutual fund shares, the investor will owe income tax on any
ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund's capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit that cannot be offset by a
loss.
Brokered CDs
CDs brokered by Schwab offer some of the same benefits as bank CDs. They are steady and
predictable, offer FDIC insurance, have a broad selection of maturity dates, and can be held in a
variety of investment accounts. Brokered CDs can also make it easier to build CD ladders. Risks
associated with brokered CDs:
Market risk
The most common risk is that you'll need your funds before the CD matures. Although there
are no early redemption fees (like there are for bank-issued CDs), you may receive less than
your original purchase price.
Call risk
Brokered CDs may have call features that give the issuing bank the right, after a set period of
time, to redeem or “call” the brokered CD before its maturity date. The risk is that the issuer
will exercise a call option at an unfavorable time for the holder, such as when interest rates
decline.
14
Cash and Cash Equivalents
Cash and cash equivalents are the most liquid of investments. Cash and cash equivalents are
considered very low-risk investments meaning, there is little risk of losing the principal investment.
Typically, low risk also means low return and the interest an investor can earn on this type of
investment is low relative to other types of investing vehicles.
ITEM 9 - DISCIPLINARY INFORMATION
Blue Marble and our personnel seek to maintain the highest level of business professionalism,
integrity, and ethics. Blue Marble does not have any disciplinary information to disclose.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Arturo Tabuenca, Blue Marble's Portfolio Manager, is also a licensed insurance agent and a
registered securities representative of Purshe Kaplan Sterling Investments ("PKS"), a non-
affiliated registered broker- dealer and a member of the Financial Industry Regulation Authority
("FINRA"). Mr. Tabuenca's activities with PKS represent less than 5% of his time and are
generally only conducted upon client request or for products outside the scope of Blue Marble's
socially responsible objective. A conflict of interest exists to the extent that Mr. Tabuenca receives
commissions and/or trailing service fees related to the sale of commissionable products, as this
practice gives him an incentive to recommend products based on the compensation received,
rather than on the client's needs. Therefore, clients are advised that the client is under no
obligation to act on these recommendations or purchase commissionable products through Mr.
Tabuenca as a registered representative. In all cases, insurance commissions will be fully
disclosed to the client. Commissions from these products are separate from any fees that Blue
Marble receives for advisory services. Clients have the right to utilize or decline to utilize the
services of any representative of Blue Marble in their outside capacity and have the right to
purchase services or products recommended by Blue Marble through another provider.
Clients should be aware that these services pay a commission and involve a possible conflict of
interest, as commissionable products can conflict with the fiduciary duties of a registered
investment adviser. Blue Marble always acts in the best interest of the client, including in the sale
of commissionable products to advisory clients. Clients are in no way required to utilize the
services of any representative of Blue Marble in such individual's outside capacity.
Sierra Smith is a licensed insurance agent and registered representative with Purshe Kaplan
Sterling Investments (PKS). From time to time, she will offer clients advice or products from this
activity. Clients should be aware that these services pay a commission and involve a possible
conflict of interest, as commissionable products can conflict with the fiduciary duties of a
registered investment adviser. Blue Marble always acts in the best interest of the client, including in
the sale of commissionable products to advisory clients. Clients are in no way required to utilize the
services of any representative of Blue Marble in such individual's outside capacity.
industry. Please see
for a description of other business activities
they engage
in,
Blue Marble's other portfolio managers may also be associated with unaffiliated firms in the
the Form ADV Part 2B Brochure Supplement of each
financial
portfolio manager
the
compensation they receive, and any related conflicts of interest.
15
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
Blue Marble believes that we owe clients the highest level of trust and fair dealing. As part of our
fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our
personnel. Blue Marble and its personnel do not have a material financial interest in
recommendations made to client accounts. We have adopted a Code of Ethics that emphasizes the
high standards of conduct that Blue Marble seeks to observe. Blue Marble's personnel are required
to conduct themselves with integrity at all times and follow the principles and policies detailed in our
Code of Ethics.
Blue Marble's Code of Ethics attempts to address specific conflicts of interest that either we have
identified or that could likely arise. Our personnel are required to follow clear guidelines from the
Code of Ethics in areas such as gifts and entertainment, other business activities, prohibitions of
insider trading, and adherence to applicable state and federal securities laws. Blue Marble will
provide a complete copy of the Code of Ethics to any client or prospective client upon request.
Personal Trading Practices
Individuals who formulate investment advice for clients, or who have access to nonpublic
information regarding any clients' purchase or sale of securities, are subject to Blue Marble's
personal trading policies. Blue Marble and our personnel may purchase or sell securities for
ourselves that we also recommend to clients. This includes related securities (e.g., warrants,
options, or futures). This presents a conflict of interest as we have an incentive to favor our personal
trades over client transactions or use the information about the transactions we intend to make for
clients to our personal benefit. Our policies to address these conflicts include the following:
1. As a fiduciary to our clients, we have a duty to put our clients' interests first. Our fiduciary duty
includes, but is not limited to, a duty of care, loyalty, obedience, and utmost good faith.
2. Clients receive the opportunity to act on investment recommendations prior to and in
preference to accounts of Blue Marble and our personnel.
3. Blue Marble prohibits trading in a manner that takes personal advantage of our knowledge of
client transactions or price movements caused by client transactions.
4. At times, we might wish to trade in the same security that we plan to trade for a client. For
non-exchange-traded mutual funds, if we traded on the same day as clients, we would receive
the same price, since mutual funds are issued and redeemed once daily at the fund's net
asset value ("NAV'). For stocks or other securities where the prices fluctuate during the day,
we will place our own transactions after we place client trades. Since prices fluctuate, this
does not guarantee that clients will get better prices than our personnel. The personal trading
of our affiliates will not be permitted to front run or disadvantage trading for clients.
5. Blue Marble maintains required personal securities transaction records
ITEM 12 - BROKERAGE PRACTICES
All Blue Marble client accounts are held at an independent qualified custodian. Blue Marble requires
clients to open an account with Charles Schwab & Co., Inc. Advisor Services. The client will enter
into a separate agreement with Charles Schwab & Co. to custody the assets. Blue Marble is
independently owned and operated and is not affiliated with Charles Schwab & Co. By requiring
clients to use Charles Schwab & Co., Blue Marble believes we may be able to manage the client’s
portfolio, achieve favorable execution of client transactions, and overall lower the costs to the
16
portfolio more effectively. Clients may not direct Blue Marble to place trades through any outside
brokers. Not all investment advisers require their clients to trade through specific brokerage firms.
Factors Considered in Selecting Broker-Dealers for Client Transactions
Research and Other Benefits
Charles Schwab & Co., Inc. Advisor Services (Schwab) provides Blue Marble with access to
Schwab’s institutional trading and custody services, which are typically not available to Schwab’s
retail investors. Schwab includes brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and
access to mutual funds and other investments that are otherwise generally available only to
investors or would require a significantly higher minimum initial investment. For Blue Marble
client accounts maintained in its custody, Schwab generally does not charge separately for
custody services but is compensated by account holders through commissions or other
transaction-related or asset-based fees for securities trades that are executed through Schwab or
that settle into Schwab accounts.
Schwab also makes available to Blue Marble other products and services that benefit Blue Marble
but may not benefit its clients' accounts. These benefits may include national, regional or Blue
Marble specific educational events organized and/or sponsored by Schwab. Other potential benefits
may include occasional business entertainment of personnel of Blue Marble by Schwab personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms of
entertainment, some of which may accompany educational opportunities. Other of these products
and services assist Blue Marble in managing and administering clients' accounts. These include
software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts, if applicable), provide research,
pricing information and other market data, facilitate payment of Blue Marble's fees from its clients'
accounts (if applicable), and assist with back-office training and support functions, recordkeeping,
and client reporting. Many of these services generally may be used to service all or some
substantial number of Blue Marble's accounts.
Schwab also makes available to Blue Marble other services intended to help Blue Marble manage
and further develop its business enterprise. These services may include professional compliance,
legal and business consulting, publications and conferences on practice management, information
technology, business succession, regulatory compliance, employee benefits providers, and human
capital consultants, insurance, and marketing. In addition, Schwab may make available, arrange
and/or pay vendors for these types of services rendered to Blue Marble by independent third
parties. Schwab may discount or waive fees it would otherwise charge for some of these services or
pay all or a part of the fees of a third-party providing these services to Blue Marble. Blue Marble is
independently owned and operated and not affiliated with Schwab.
Aggregation and Allocation of Transactions
In most cases, Blue Marble primarily buys and sells open-end mutual funds. However, in certain
cases, Blue Marble may purchase individual stocks that are particularly strong in addressing an
environmental or social issue, or in cases when a client prefers to be an individual equity
shareholder. It is important to note that in most of these cases, the individual stock positions are
modest relative to the overall client portfolio and are intended as long-term investments. In those
cases, we may aggregate the orders for clients that are in the same securities if we believe that
aggregation is in the best interests of our clients.
17
Blue Marble has adopted certain policies and procedures that we follow when aggregating trades,
in an effort to provide an objective and equitable method of trade allocation so that all clients are
treated fairly. The basic objectives of our policies and procedures are as follows:
1. Blue Marble will not aggregate trades unless we believe that aggregation is consistent with our
duty to seek best execution for clients.
2. Blue Marble does not aggregate trades of our personnel with those of client accounts.
3. No client account will be favored over any other client account.
4. Each account that participates in an aggregated transaction will participate at the average of the
executed share price for that transaction.
5. Blue Marble will allocate each transaction in writing prior to the time an order is transmitted to a
6.
broker for execution.
If the aggregated transaction is filled in its entirety, it will be allocated among the accounts listed
on the pre-allocation order. If an allocation is only partially filled, it will be allocated on a pro rata
basis. However, if a pro rata allocation results in a de minimis amount to one or more of the
accounts, Blue Marble may deviate from the pro rata allocation and document the reasons for
the deviation.
Blue Marble believes that by combining orders in this way it will be advantageous to all participants.
However, the average price could be less advantageous to a particular client than if that client had
been the only account executing the transaction or had completed its transaction before the other
participants.
ITEM 13 - REVIEW OF ACCOUNTS
Managed Account Reviews
Accounts are reviewed at least quarterly by the portfolio manager to determine their conformity with
client investment objectives, guidelines, and Blue Marble's investment strategy. The review process
is based on a variety of factors, which include but are not limited to: each model's investment
strategy, a client's stated investment objectives, the economic environment, outlook for the
securities markets and the merits of the securities and/or mutual funds in which the accounts are
invested. Each client account will be reviewed at least annually with the client. In addition, a
special review of an account may be triggered by one or more of the following: 1) a change in the
client's investment objectives, guidelines and/or financial situation communicated by the client, 2)
change in diversification, 3) tax considerations, 4) cash added or withdrawn from account, and 5)
purchase or sale of a security or mutual fund in the account.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Support Products and Services
We receive an economic benefit from Charles Schwab & Co. in the form of the support products and
services they make available to us and other independent investment advisers whose clients
maintain their accounts at Charles Schwab & Co. These products and services, how they benefit
us, and the related conflicts of interest are described above (see Item 12 - Brokerage Practices).
We do not base particular investment advice, such as buying particular securities for our clients, on
the availability of Charles Schwab & Co.'s products and services to us. Other than the benefits
from Charles Schwab & Co. discussed immediately above, we do not receive any compensation
from third parties for advisory services we provide to clients, and we do not pay any third party for
referrals.
18
ITEM 15 - CUSTODY
Blue Marble does not accept or maintain physical custody of client funds or securities. Blue
Marble does not permit arrangements that authorize it to withdraw client funds or securities
maintained with a qualified custodian under a standing letter of authorization (“SLOA”), nor does
Blue Marble permit first-person transfers between a client’s own accounts without client
authorization.
Clients’ funds and securities are held by Charles Schwab, an independent qualified custodian. For
the convenience of the client, Blue Marble is authorized to deduct advisory fees directly from
client accounts held at the qualified custodian. In such cases, Blue Marble is deemed to have
limited custody of client assets.
Blue Marble is not required to undergo an annual surprise custody examination provided that all of
the following conditions are met:
1. Client assets are maintained with a qualified custodian;
2. The qualified custodian sends account statements directly to clients at least quarterly,
which reflect all transactions, including the deduction of advisory fees;
3. Clients provide written authorization permitting the deduction of advisory fees in
accordance with the advisory agreement; and
4. Advisory fees are calculated in accordance with the fee schedule described in Item 5,
and clients are able to verify the fees charged by reviewing custodian statements, the
advisory agreement, and the fee schedule and calculation methodology described in
Item 5.
Clients are encouraged to carefully review statements received from the qualified custodian and
to contact Blue Marble with any questions regarding advisory fees or account activity.
ITEM 16 - INVESTMENT DISCRETION
Blue Marble requires full discretion to decide the specific security to trade and to determine the
quantity and the timing of transactions for client accounts. Blue Marble is not required to contact
clients before placing trades in their account, but clients will receive confirmations directly from the
broker for any trades placed. Clients grant us discretionary authority in the contracts they sign with
us. Clients also give us trading authority within their accounts when they sign the custodian
paperwork.
Certain client-imposed conditions may limit our discretionary authority, such as where the client
prohibits transactions in specific security types. See also Tailored Services and Client Imposed
Restrictions under Item 4, above.
ITEM 17 - VOTING CLIENT SECURITIES
Proxy Voting
Blue Marble does not accept or have the authority to vote client securities. In the rare event that a
proxy is issued, clients may call us if they have questions about a particular solicitation. Blue Marble
will not be deemed to have proxy voting authority solely as a result of providing advice or
information about a particular proxy vote to a client. Clients will receive their proxies or other
solicitations directly from their custodian or a transfer agent.
19
Class Actions
Blue Marble does not instruct or give advice to clients on whether to participate as a member of
class action lawsuits and will not automatically file claims on the client's behalf. However, if a client
notifies us that they wish to participate in a class action, we will provide the client with transaction
information pertaining to the client's account needed for the client to file a proof of claim in a class
action.
ITEM 18 - FINANCIAL INFORMATION
Registered investment advisers are required in this item to provide clients with certain financial
information or disclosures about the firm's financial condition. Blue Marble does not foresee any
financial condition that is reasonably likely to impair our ability to meet contractual commitments to
clients. Blue Marble Investments has never had a bankruptcy petition.
20
Form ADV, Part 2B Brochure Supplement
Arturo Tabuenca
CRD # 2134379
Blue Marble Investments, LLC
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
May 6, 2026
This brochure supplement provides information about Arturo Tabuenca that supplements the Blue Marble
Investments, LLC brochure. You should have already received a copy of that brochure. Please contact us at
805.595.1820 if you did not receive our brochure or if you have any questions about the contents of this
supplement.
Additional information about Arturo Tabuenca is available on the SEC's website at
www.adviserinfo.sec.gov.
21
ARTURO A. TABUENCA
CRD # 2134379
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Arturo A. Tabuenca, Managing Member and Portfolio Manager, b. 1968
Education:
B.A. in Business Administration; Loma Linda University, Riverside, CA; 1991
Business Background:
2000 to present
Blue Marble Investments, LLC ("Blue Marble")
Managing Member and Investment adviser
Representative (from 2000-2007 Blue Marble
held IAR registration with the SEC through
Commonwealth Financial Network)
2015 to present
Purshe Kaplan Sterling Investments;
Registered Representative
2007 to 2014
Sorrento Pacific Financial, LLC, formerly
Partnervest Advisory Services, LLC;
Registered Representative
Commonwealth Financial Network;
Registered Representative
2000 to 2007
1993 to 2000
Banc of America Investment Services (AKA
BA Investment Services, Inc.); Vice President;
Financial Advisor
1991 to 1993
Great American Securities; Registered
Representative
ITEM 3 - DISCIPLINARY INFORMATION
Arturo Tabuenca has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
In addition to the investment advisory services he provides through Blue Marble, Arturo Tabuenca,
Blue Marble's Portfolio Manager, is also a licensed insurance agent and a registered securities
representative of Purshe Kaplan Sterling Investments ("PKS"), a non-affiliated registered
broker-dealer and a member of the Financial Industry Regulation Authority ("FINRA"). Mr.
Tabuenca's activities with PKS represent less than 5% of his time and are generally only conducted
upon client request or for products outside the scope of Blue Marble's socially responsible objective.
A conflict of interest exists to the extent that Mr. Tabuenca receives commissions and/or trailing
service fees related to the sale of commissionable products, as this practice gives him an incentive
to recommend products based on the compensation received, rather than on the client's needs.
Therefore, clients are advised that the client is under no obligation to act on these
recommendations or purchase commissionable products through Mr. Tabuenca as a registered
representative. In all cases, insurance commissions will be fully disclosed to the client.
Commissions from these products are separate from any fees that Blue Marble receives for
22
advisory services. Clients have the right to utilize or decline to utilize the services of any
representative of Blue Marble in their outside capacity and have the right to purchase services or
products recommended by Blue Marble through another provider.
ITEM 5 - ADDITIONAL COMPENSATION
Arturo Tabuenca's compensation comes from his regular income and ownership of Blue Marble
and from his other business activities described in Item 4 above.
ITEM 6 - SUPERVISION
Arturo Tabuenca is the Managing Member of Blue Marble and is supervised by Linda Shelby, the
firm's Chief Compliance Officer. Linda Shelby is responsible for ensuring that Arturo Tabuenca
adheres to all required regulations regarding the activities of an investment adviser representative,
as well as all policies and procedures outlined in the firm's Code of Ethics and compliance manual.
The phone number for Linda Shelby is (805) 595-1820.
23
Form ADV, Part 2B Brochure Supplement
Linda Shelby
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
May 6, 2026
This brochure supplement provides information about Linda Shelby that supplements the Blue
Marble Investments, LLC brochure. You should have already received a copy of that brochure.
Please contact us at 805.595.1820 if you did not receive our brochure or if you have any questions
about the contents of this supplement.
Additional information about Linda Shelby is available on the SEC's website at
www.adviserinfo.sec.gov.
24
LINDA SMITH SHELBY
CRD# 1286574
ITEM 2- EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Linda S. Shelby, Chief Administrative Officer and Chief Compliance Officer, b. 1960
Education:
B.S. in Business Administration/Finance; California State University, Fresno, CA; 1983
Business Background:
2017 to present
Blue Marble Investments, LLC; Compliance
Officer; Chief Administrative Officer
1990 to 2016
Bank of America/Merrill Lynch; Senior
Vice President; West Division Executive
Registered Representative and IAR;
(Prior to merger with ML, Bank of
America investment firms operated
under names: Banc of America
Investment Services, Inc., BA
Investment Services, Inc., Investment
Network of America - Great Northern
Annuity
1989 to 1990
First Imperial Investments; Financial
Advisor-Registered Representative
[
1987 to 1989
Merrill Lynch; Financial Advisor-Registered
Representative,
1984 to 1987
Dean Witter Reynolds (Morgan Stanley);
Financial Advisor-Registered Representative
ITEM 3 - DISCIPLINARY INFORMATION
Linda Shelby has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Linda Shelby is not actively engaged in any other business or occupation that creates a material
conflict of interest.
ITEM 5 - ADDITIONAL COMPENSATION
Linda Shelby does not receive additional compensation that creates a material conflict of interest.
25
ITEM 6 - SUPERVISION
Arturo Tabuenca is the Managing Member of Blue Marble and supervises the investment activities
performed by Linda Shelby. Arturo Tabuenca is responsible for ensuring that Linda Shelby adheres
to all required regulations regarding the activities of an investment adviser representative, as well
as all policies and procedures outlined in the firm's Code of Ethics and compliance manual. Arturo
Tabuenca can be reached at 805-595-1820.
26
Form ADV, Part 2B Brochure Supplement
Sierra Smith
CRD# 7373331
Blue Marble Investments, LLC
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
May 6, 2026
This brochure supplement provides information about Sierra Smith that supplements the Blue
Marble Investments, LLC brochure. You should have already received a copy of that brochure.
Please contact us at 805.595.1820 if you did not receive our brochure or if you have any questions
about the contents of this supplement.
Additional information about Sierra Smith is available on the SEC's website at
www.adviserinfo.sec.gov.
27
SIERRA KATHRYN SMITH
CRD# 7373331
ITEM 2- EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Sierra Smith, Investment Adviser Representative, b. 1998
Education:
Bachelor of Arts Sociology; California Polytechnic State University, San Luis Obispo, CA; 2021
Business Background:
10/2021 to Present
Blue Marble Investments, LLC; Investment
Adviser Representative
04/2021 to 10/2021
Blue Marble Investments LLC; Associate
09/2017 to 06/2021
California Polytechnic State University;
Student
Professional Designations:
Certified Financial Planner (CFP®) professional
Sierra Smith is certified for financial planning services in the United States by Certified Financial
Planner Board of Standards, Inc. (“CFP Board”). Therefore, she may refer to herself as a
CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and may use these and CFP
Board’s other certification marks (the “CFP Board Certification Marks”). The CFP® certification is
voluntary. No federal or state law or regulation requires financial planners to hold the CFP®
certification. You may find more information about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience,
and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program.
The coursework covers the financial planning subject areas CFP Board has determined are necessary
for the competent and professional delivery of financial planning services, as well as comprehensive
financial plan development capstone course. A candidate may satisfy some of the coursework
requirement through other qualifying credentials.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed
to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in
the context of real-life financial planning situations. Experience – Complete 6,000 hours of
professional experience related to the personal financial planning process, or 4,000 hours of
apprenticeship experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards
for CFP® professionals.
28
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board Certification
Marks:
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by this
commitment, but CFP Board does not guarantee a CFP® professional’s services. A client
who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
ITEM 3 - DISCIPLINARY INFORMATION
Sierra Smith has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Sierra Smith is a registered representative of Purshe Kaplan Sterling Investments (“PKS”). From
time to time, she will offer clients advice or products from this activity. Clients should be aware
that these services pay a commission and involve a possible conflict of interest, as
commissionable products can conflict with the fiduciary duties of a registered investment adviser.
Blue Marble always acts in the best interest of the client, including in the sale of commissionable
products to advisory clients. Clients are in no way required to utilize the services of any
representative of Blue Marble in such individual's outside capacity.
Sierra Smith is a licensed insurance agent. From time to time, she will offer clients advice or
products from those activities. Clients should be aware that these services pay a commission and
involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a
registered investment adviser. Blue Marble always acts in the best interest of the client, including
the sale of commissionable products to advisory clients. Clients always have the right to decide
whether to utilize the services of any representative of Blue Marble in such individual's outside
capacities.
ITEM 5 - ADDITIONAL COMPENSATION
Sierra Smith does not receive additional compensation that creates a material conflict of interest.
ITEM 6 - SUPERVISION
As a representative of Blue Marble Investments, LLC, Sierra Smith is supervised by Linda Shelby, the firm's
Chief Compliance Officer. Linda Shelby is responsible for ensuring that Sierra Smith adheres to all required
regulations regarding the activities of an investment adviser representative, as well as all policies and
procedures outlined in the firm's Code of Ethics and compliance manual. The phone number for Linda
Shelby is (805) 595-1820.
29
Additional Brochure: WRAP FEE BROCHURE - EARTHFOLIO (2026-05-07)
View Document Text
Blue Marble Investments, LLC
CRD #141354
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
www.bluemarble.com
www.earthfolio.net
Form ADV, Part 2A Appendix 1
Wrap Fee Program Brochure
May 6, 2026
This wrap fee program brochure provides information about the qualifications and business practices
of Blue Marble Investments, LLC. If you have any questions about the contents of this brochure,
please contact us at 805.595.1820. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities
authority.
Any reference or use of the terms “registered investment adviser” or “registered,” does not imply that
Blue Marble Investments, LLC or any person associated with Blue Marble Investments, LLC has
achieved a certain level of skill or training.
Additional information about Blue Marble Investments, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
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ITEM 2 - MATERIAL CHANGES
Billing Method Update:
Blue Marble Investments, LLC has updated its fee billing practices for the wrap fee program to provide
that advisory fees are billed quarterly in advance instead of quarterly in arrears. Corresponding revisions
have been made to this brochure to reflect the change, including disclosure regarding the proration and
refund of unearned fees upon termination of the advisory relationship.
Custody Disclosure Update:
The brochure has also been revised to clarify disclosures related to the deduction of advisory fees and
the firm’s limited custody status.
Assets Under Management Update:
Blue Marble Investments, LLC has updated the assets under management information disclosed in
this brochure to reflect current regulatory assets under management as of the date of this amendment.
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ITEM 3 – TABLE OF CONTENTS
Table of Contents
ITEM 2 - MATERIAL CHANGES
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ITEM 3 – TABLE OF CONTENTS
3
ITEM 4 - SERVICES, FEES AND COMPENSATION
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Blue Marble Wrap Fee Program
4
Fees for the Program
4
Billing Method
5
Termination of Agreements
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ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
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Account Requirements
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ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
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Portfolio Management and Performance Calculation
6
Advisory Business
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Performance-Based Fees and Side-by-Side Management
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Methods of Analysis, Investment Strategies and Risk of Loss
7
Investing Involves Risk
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Specific Security Risks
8
Different Types of Funds
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Voting Client Securities
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ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS
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ITEM 9 - ADDITIONAL INFORMATION
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Disciplinary Information
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Other Financial Industry Activities and Affiliations
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Codes of Ethics, Participation or Interest in Client Transactions and Personal Trading
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Brokerage Practices
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Client Referrals and Other Compensation
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Financial Information
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Form ADV, Part 2B Brochure Supplement
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Arturo Tabuenca
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Linda Shelby
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Sierra Smith
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ITEM 4 - SERVICES, FEES AND COMPENSATION
Blue Marble Investments, LLC (“Blue Marble,” “we,” “our,” or “us”) is a privately
owned limited liability company headquartered in Santa Barbara, California. Blue Marble is an
SEC registered investment adviser.
We are a socially active investment firm that manages portfolios that feature ESG
(environmental, social, and governance) screened funds. Blue Marble registered as an
independent investment adviser in 2007. From 2000 to 2007, Blue Marble’s manager provided
socially responsible investment advice as Blue Marble Investments through another registered
investment advisory firm. Arturo Tabuenca is Blue Marble’s Managing Member and principal
owner. Additional information regarding Blue Marble’s custody practices, brokerage practices,
and other important disclosures is provided in our Form ADV Part 2A brochure.
Blue Marble Wrap Fee Program
Blue Marble offers discretionary account management to clients through a wrap fee
program featuring EarthFolio model portfolios, as described in this brochure. Blue Marble is
both the sponsor and currently the only portfolio manager for our wrap fee program.
In 2007, Blue Marble launched the EarthFolio portfolio series. EarthFolio is a collection of online
professionally managed model portfolios that feature ESG screened (environmental,
social, governance) mutual funds. The EarthFolio model portfolios are designed to diversify the
client’s assets and are available in a range of asset allocation strategies to address various
investment objectives. Our current eight portfolios are: Conservative; Balanced; Growth; High
Growth; Fossil Free Conservative; Fossil Free Balanced; Fossil Free Growth; and Fossil Free
High Growth.
Prior to opening an account, a client will complete a questionnaire on the website, which
once completed will suggest the most appropriate model based on the answers provided by the
client that pertained to the client’s investment objectives, risk tolerance, and investment time
horizon. If the client decides to open an account with EarthFolio, the client will complete an
application and receive new account forms online, including an investment advisory agreement
and Blue Marble’s Form ADV Part 2 brochure.
Fees for the Program
Clients participating in our wrap fee program pay a single bundled fee to Blue Marble for our
advisory services and commissions on transactions instead of paying these fees separately.
Clients’ EarthFolio accounts are charged an annual management fee of 0.50% of assets under
management. Blue Marble does not negotiate fees on EarthFolio portfolios.
The fees described include transaction costs for securities transactions, but do not include other
fees charged by the custodian, such as wire transfer and electronic fund fees, handling, or
transfer fees. In addition, if a client transfers assets in kind to an EarthFolio account, the client
will pay the initial transaction costs to liquidate the portfolio. Clients in the program ultimately bear
these costs in addition to the wrap fees charged directly to the client.
Participating in the wrap fee program may cost a client more or less than purchasing investment
management and trading services separately. Factors that may affect the cost of a wrap fee
program relative to other compensation arrangements include: the advisory fees the client would
pay for Blue Marble’s investment management services if the fees were un-bundled; the
transaction and execution fees the custodian would charge to the client under a non-wrap fee
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arrangement, and the frequency and volume of trading activity in the client’s account. Under the
terms of this wrap fee program, Blue Marble will pay trading and execution costs imposed by the
custodian for transactions in client accounts. This arrangement may present a potential conflict
of interest for Blue Marble, as Blue Marble has a financial disincentive to engage in active
trading.
Blue Marble generally limits our recommendations to no-load, load waived, and no-transaction fee
mutual funds that incur no brokerage commissions. Due to the breadth of such funds available, we
believe that this does not meaningfully restrict our portfolio management options and mitigates the
conflict.
Billing Method
Advisory fees are billed quarterly in advance based on the market value of assets under
management as of the last business day of the prior billing period and are not adjusted for
performance during the current quarter. For new accounts, the initial fee will be prorated based
on the number of days remaining in the billing period.
When it deducts fees directly from client accounts at the qualified custodian, Blue Marble will
be deemed to have limited custody of client’s assets. Clients provide written authorization
permitting the deduction of advisory fees in accordance with the advisory agreement. Advisory
fees are calculated in accordance with the fee schedule described in this brochure.
Clients will receive account statements directly from the qualified custodian and are able to
verify the fees charged by reviewing their custodian statements and their advisory agreement.
Clients are encouraged to contact Blue Marble with any questions regarding fee calculations.
Termination of Agreements
Clients may terminate the advisory agreement without penalty within five (5) business days of
signing the agreement. Thereafter, either party may terminate the advisory relationship at any
time upon written notice. Advisory fees are billed quarterly in advance. Upon termination of the
advisory agreement, Blue Marble will calculate the unearned portion of any prepaid advisory
fees based on the number of days remaining in the billing period. Any unearned fees will be
promptly refunded to the client. If any earned but unpaid fees remain due at the time of
termination, Blue Marble will invoice the client for such amounts, and payment will be due
upon receipt.
In the event of a client's death or cognitive impairment, Blue Marble will continue management
of the account until an authorized party notifies us of the client's death or disability and gives
us alternative instructions.
ITEM 5 - ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Clients in Blue Marble’s wrap fee program include individuals (including high net worth individuals,
trusts and estates, and individual participants of retirement plans). In addition, we offer advisory
services to charitable organizations and businesses.
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Account Requirements
The minimum account size for accounts invested according to the EarthFolio models is $25,000.
Accounts below this minimum may be accepted on an individual basis at Blue Marble’s discretion.
ITEM 6 - PORTFOLIO MANAGER SELECTION AND EVALUATION
Portfolio Management and Performance Calculation
Blue Marble is the sponsor and currently the only portfolio manager of our wrap fee program. This
may be a conflict of interest in that we do not review or recommend outside portfolio managers who
may charge the same or lower fees than our firm for similar services. However, Blue Marble
addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as
sponsor and portfolio manager of the wrap fee program.
Model performance for the EarthFolio model portfolios is calculated by a third-party service
provider, Longs Peak Advisory Services, LLC (“Longs Peak”) . Longs Peak obtains trade information
from Blue Marble when changes are made to the models. Each month, prices and dividends are
downloaded from a public source for each holding within the models.
New portfolio values are determined each month based on this updated price and dividend
information. Time- weighted returns are calculated using these updated market values. Once the
monthly time-weighted returns are calculated, the monthly returns are geometrically linked to
calculate quarterly and annual returns. Three- year, five-year, ten- year, and since inception
annualized returns are also calculated and graphs are created demonstrating the since inception
growth of $50,000.
Advisory Business
This wrap fee program brochure describes the services we provide to clients of the Blue Marble
wrap fee program and our investment and trading policies as they relate to wrap fee program
clients. In addition to accounts managed according to the EarthFolio model portfolios, Blue Marble
accepts new clients that want a more customized portfolio. The other services Blue Marble offers
are described in more detail in our Form ADV Part 2A brochure.
Performance-Based Fees and Side-by-Side Management
Blue Marble does not charge performance-based fees or other fees based on a share of capital
gains on or capital appreciation of the assets of a client.
Assets Under Management
As of May 6, 2026, Blue Marble’s assets under management totaled $205,057,533.
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Methods of Analysis, Investment Strategies and Risk of Loss
EarthFolio Model Portfolios
The EarthFolio models are socially and environmentally screened portfolios designed to provide a
diversified asset allocation based on the client’s investment objectives and risk tolerance.
EarthFolio comes in a range of portfolio styles, each designed to help match the needs of varying
investors based on their individual goals, risk tolerances, and time horizons.
The EarthFolio Investment Process
Blue Marble follows a multi-step process in determining the securities to include in the model
portfolios:
Step 1 - Fund Universe: EarthFolio invests exclusively in funds categorized as Sustainable
or Socially Responsible which are screened for environmental, social and corporate
governance (ESG).
Step 2 - Asset Allocation: EarthFolio models are strategically allocated across a range of
portfolio objectives designed to maximize long-term returns and lower risk.
Step 3 - Fund Selection: Final fund selections are made based on relative quality and
performance in areas such as capitalization, style consistency, operating expenses, and
passive management.
Step 4 - Portfolio Construction: Portfolios are implemented based on client’s responses to the
investment questionnaire identifying their investment goals and risk tolerances.
Step 5 - Management and Monitoring: Individual asset allocations are periodically rebalanced
to their original portfolio objectives and underlying funds are monitored relative to peer
performance and benchmarks.
Blue Marble monitors the performance of each holding against a stated benchmark. Additionally,
active rebalancing is employed by Blue Marble in an effort to maintain the portfolio’s integrity and
enhance its ability to pursue long-term growth.
EarthFolio’s Integration of ESG Criteria
EarthFolio models are globally diversified and invest in a broad range of equity funds, fixed-
income funds, and money market funds. Funds selected for EarthFolio must pass rigorous
financial screens, and just as importantly, invest in companies committed to ethical practices.
Ethical practices fall into three broad categories: the environment, social progress, and corporate
governance. This type of investing is classified as Socially Responsible Investing, Sustainable
Investing or ESG Investing and is the hallmark of EarthFolio. Some of the most common ESG
screens employed include:
Conservation
Clean Tech
Equality and Diversity
Human Rights
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Fair Labor
Animal Welfare
Non-Violence
Corporate Governance
Healthy Living
Investing Involves Risk
Investing in securities always involves the risk that you will lose money. Before investing in the
securities markets, clients should be prepared to bear that risk. Over time, a client’s account value
will fluctuate. At any time, your assets may be worth more or less than the amount you invested.
Blue Marble makes no guarantees or promises that our market analysis will be accurate or the
investment strategies we use will be successful.
Clients investing in an EarthFolio account will have a model portfolio recommended to them based
on their investment profile as determined by an interactive web-based questionnaire. Clients may
decide to invest in a portfolio different than the one recommended; however, clients should
understand that if they choose a model that was not recommended, the model may not be as
appropriate for the client (may have higher risk or lower return potential) as the model
recommended, based on the client’s time horizon and risk tolerance.
Specific Security Risks
General Risks of Owning Securities
The prices of securities held in client accounts and the income they generate may decline in
response to certain events taking place around the world. These include events directly involving
the issuers of securities held as underlying assets of mutual funds in a client’s account, conditions
affecting the general economy, and overall market changes. Other contributing factors include local,
regional, or global political, social, or economic instability and governmental or governmental
agency responses to economic conditions. Finally, currency, interest rate, and commodity price
fluctuations may also affect security prices and income.
Mutual Funds (Open-end Investment Company)
A mutual fund is a company that pools money from many investors and invests the money in stocks,
bonds, short-term money-market instruments, other securities or assets, or some combination of
these investments. The portfolio of the fund consists of the combined holdings it owns. Each share
represents an investor’s proportionate ownership of the fund’s holdings and the income those
holdings generate. The price that investors pay for mutual fund shares is the fund’s per share net
asset value (NAV) plus any shareholder fees that the fund imposes at the time of purchase (such as
sales loads).
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Mutual funds have benefits such as professional management, diversification, affordability, and
liquidity. However, they also have features that some investors might view as disadvantages:
Costs Despite Negative Returns
Investors must pay management costs and internal fund expenses regardless of how the fund
performs. Depending on the timing of their investment, investors may also have to pay taxes
on any capital gains distribution they receive. This includes instances where the fund went on
to perform poorly after purchasing shares.
Lack of Control
Investors typically cannot ascertain the exact make-up of a fund’s portfolio at any given time,
nor can they directly influence which securities the fund manager buys and sells or the timing
of those trades.
Price Uncertainty
With an individual stock, investors can obtain real-time (or close to real-time) pricing
information with relative ease by checking financial websites or by calling a broker or your
investment adviser. Investors can also monitor how a stock’s price changes from hour to
hour—or even second to second. By contrast, with a mutual fund, the price at which an
investor purchases or redeems shares will typically depend on the fund’s NAV, which the fund
might not calculate until many hours after the investor placed the order. In general, mutual
funds must calculate their NAV at least once every business day, typically after the major U.S.
exchanges close.
Different Types of Funds
When it comes to investing in mutual funds, investors have literally thousands of choices. Most mutual
funds fall into one of three main categories; money market funds, bond funds (also called “fixed income”
funds), and stock funds (also called “equity” funds). Each type has different features and different risks
and rewards. Generally, the higher the potential return, the higher the risk of loss.
Money Market Funds
Money market funds have relatively low risks, compared to other mutual funds (and most other
investments). By law, they can invest in only certain high quality, short-term investments issued by
the U.S. Government, U.S. and foreign corporations, state and local governments, and bank issued
certificates of deposit. Money market funds try to keep their net asset value (NAV), which
represents the value of one share in a fund, at a stable $1.00 per share. However, the NAV may fall
below $1.00 if the fund’s investments perform poorly. Investor losses have been rare, but they are
possible. Money market funds pay dividends that generally reflect short-term interest rates, and
historically the returns for money market funds have been lower than for either bond or stock funds.
That is why “inflation risk,” the risk that inflation will outpace and erode investment returns over time,
can be a potential concern for investors in money market funds. Money Market Funds are only used
minimally within the active management of our portfolios.
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Stock Funds
Although a stock fund’s value can rise and fall quickly (and dramatically) over the short term,
historically stocks have performed better over the long term than other types of investments. This is
true for corporate bonds, government bonds, and treasury securities. Overall “market risk” poses
the greatest potential danger for investors in stock funds. Stock prices can fluctuate for a broad
range of reasons such as the overall strength of the economy or demand for particular products or
services. Not all stock funds are the same. For example:
Growth Funds
Growth funds focus on stocks that may or may not pay a regular dividend but have the
potential for large capital gains. These funds favor companies expected to grow earnings,
which could result in stock prices rising faster than the economy, and may be smaller and less
seasoned companies. The smaller and less seasoned companies that may be in a growth
fund have a greater risk of price volatility. Growth stocks, which can be priced on future
expectations rather than current results, may decline substantially when expectations are not
met or general market conditions weaken.
Equity Income Funds
Equity income funds stress current income over growth, and may invest in stocks that pay
regular dividends. These funds are subject to dividend payout risk, which is the possibility that
a number of the companies in which the fund invests will reduce or eliminate the dividend on
the securities held by the fund.
Small Cap Funds
Funds that invest in stocks of small companies involve additional risks. Smaller companies
typically have higher risk of failure, and are not as established as larger blue-chip companies.
Historically, smaller- company stocks have experienced a greater degree of market volatility
than the overall market average.
Mid Cap Funds
Funds that invest in companies with mid-range market capitalizations involve additional risks.
The securities of these companies may be more volatile and less liquid than the securities of
larger companies.
Index Funds
Index funds aim to achieve the same return as a particular market index, such as the S&P 500
Composite Stock Price Index or the Calvert U.S. Large Cap Core Index, by investing in all—or
perhaps a representative sample—of the companies included in an index.
International Funds
International investments are subject to additional risks, including currency fluctuation, political
instability, and potential illiquid markets.
Emerging Market Funds
Funds that invest in foreign securities of smaller, less-developed countries involve special
additional risks. These risks include, but are not limited to currency risk, political risk and risk
associated with varying accounting standards. Investing in emerging markets may accentuate
these risks.
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Sector Funds
Sector funds may specialize in a particular industry segment, such as technology or consumer
products stocks. Funds that invest exclusively in one sector or industry involve additional
risks. The lack of industry diversification subjects the investor to increased industry-specific
risk.
TIPS Funds
Treasury Inflation Protected Securities (TIPS) are inflation-indexed securities structured to remove
inflation risk. TIPS are indexed to an inflationary gauge to protect investors from the decline in the
purchasing power of their money. The value of TIPS will increase with inflation but will decrease
with deflation.
Bond Funds
Bond funds generally have higher risks than money market funds, largely because they typically
pursue strategies aimed at producing higher yields. Unlike money market funds, the SEC’s rules do
not restrict bond funds to high quality or short-term investments. Because there are many different
types of bonds, bond funds can vary dramatically in their risks and rewards.
Some of the risks associated with bond funds include:
Credit Risk
There is a possibility that companies or other issuers may fail to pay their debts (including the
debt owed to holders of their bonds). Consequently, this affects mutual funds that hold these
bonds. Credit risk is less of a factor for bond funds that invest in insured bonds or U.S.
Treasury Bonds. By contrast, those that invest in the bonds of companies with poor credit
ratings generally will be subject to higher risk.
Interest Rate Risk
There is a risk that the market value of the bonds will go down when interest rates go up.
Because of this, investors can lose money in any bond fund, including those that invest only in
insured bonds or U.S. Treasury Bonds. Funds that invest in longer-term bonds tend to have
higher interest rate risk.
Prepayment Risk
Issuers may choose to pay off debt earlier than the stated maturity date on a bond. For
example, if interest rates fall, a bond issuer may decide to “retire” its debt and issue new
bonds that pay a lower rate. When this happens, the fund may not be able to reinvest the
proceeds in an investment with as high a return or yield.
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Tax Consequences of Mutual Funds
When investors buy and hold an individual stock or bond, the investor must pay income tax each
year on the dividends or interest the investor receives. However, the investor will not have to pay
any capital gains tax until the investor actually sells and makes a profit. Mutual funds are different.
When an investor buys and holds mutual fund shares, the investor will owe income tax on any
ordinary dividends in the year the investor receives or reinvests them. Moreover, in addition to
owing taxes on any personal capital gains when the investor sells shares, the investor may have to
pay taxes each year on the fund’s capital gains. That is because the law requires mutual funds to
distribute capital gains to shareholders if they sell securities for a profit that cannot be offset by a
loss.
Brokered CDs
CDs brokered by Schwab offer some of the same benefits as bank CDs. They are steady and
predictable, offer FDIC insurance, have a broad selection of maturity dates, and can be held in a
variety of investment accounts. Brokered CDs can also make it easier to build CD ladders. Risks
associated with brokered CDs:
Market risk
The most common risk is that you'll need your funds before the CD matures. Although there
are no early redemption fees (like there are for bank-issued CDs), you may receive less than
your original purchase price.
Call risk
Brokered CDs may have call features that give the issuing bank the right, after a set period of
time, to redeem or “call” the brokered CD before its maturity date. The risk is that the issuer
will exercise a call option at an unfavorable time for the holder, such as when interest rates
decline.
Cash and Cash Equivalents
Cash and cash equivalents are the most liquid of investments. Cash and cash equivalents are
considered very low-risk investments meaning, there is little risk of losing the principal investment.
Typically, low risk also means low return and the interest an investor can earn on this type of
investment is low relative to other types of investing vehicles. Cash and cash equivalents are used
minimally within the active management of our portfolios.
Voting Client Securities
Proxy Voting
Blue Marble does not accept or have the authority to vote client securities. In the rare event that a
proxy is issued, clients may call us if they have questions about a particular solicitation. Blue Marble
will not be deemed to have proxy-voting authority solely as a result of providing advice or
information about a particular proxy vote to a client. Clients will receive their proxies or other
solicitations directly from their custodian or a transfer agent.
Class Actions
Blue Marble does not instruct or give advice to clients on whether or not to participate as a member
of class action lawsuits and will not automatically file claims on the client’s behalf. However, if a
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client notifies us that they wish to participate in a class action, we will provide the client with any
transaction information pertaining to the client’s account needed for the client to file a proof of claim
in a class action.
ITEM 7 - CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
Clients investing in EarthFolio accounts will complete a web-based interactive questionnaire which
contains questions about the investor’s time horizon and risk tolerance. The questionnaire is designed to
help the investor determine his/her appropriate investment profile based on the answers he/she
provides and to recommend the EarthFolio portfolio that appears to best match his/her appropriate
profile. The client may choose not to invest in the recommended model portfolio. The client’s account
will be managed according to the selected model portfolio. It is the client’s responsibility to keep Blue
Marble informed of any changes to their investment objectives.
ITEM 8 - CLIENT CONTACT WITH PORTFOLIO MANAGERS
We have no restrictions on clients’ ability to contact and consult with Blue Marble.
ITEM 9 - ADDITIONAL INFORMATION
Disciplinary Information
Blue Marble and our personnel seek to maintain the highest level of business professionalism, integrity,
and ethics. Blue Marble does not have any disciplinary information to disclose.
Other Financial Industry Activities and Affiliations
Arturo Tabuenca, Blue Marble’s Portfolio Manager, is also a licensed insurance agent and a
registered securities representative of Purshe Kaplan Sterling Investments (“PKS”), a non-
affiliated registered broker-dealer and a member of the Financial Industry Regulation Authority
(“FINRA”). Mr. Tabuenca’s activities with PKS represent less than 5% of his time and are
generally only conducted upon client request or for products outside the scope of Blue Marble’s
socially responsible objective. A conflict of interest exists to the extent that Mr. Tabuenca
receives commissions and/or trailing service fees related to the sale of commissionable
products, as this practice gives him an incentive to recommend products based on the
compensation received, rather than on the client’s needs. Therefore, clients are advised that
the client is under no obligation to act on these recommendations or purchase commissionable
products through Mr. Tabuenca as a registered representative. In all cases, insurance
commissions will be fully disclosed to the client. Commissions from these products are
separate from any fees that Blue Marble receives for advisory services. Clients have the right
to utilize or decline to utilize the services of any representative of Blue Marble in their outside
capacity and have the right to purchase services or products recommended by Blue Marble
through another provider.
Sierra Smith is a licensed insurance agent and a registered representative of Purshe Kaplan
Sterling Investments (“PKS”). Ms. Smith’s activities with PKS represent less than 5% of her
time and are generally conducted only upon client request. Clients should be aware that these
services pay a commission and involve a possible conflict of interest, as commissionable
products can conflict with the fiduciary duties of a registered investment adviser. Blue Marble
always acts in the best interest of the client; including in the sale of commissionable products to
advisory clients. Clients are in no way required to utilize the services of any representative of
Blue Marble in such individual's outside capacity. Clients always have the right to decide
whether or not to utilize the services of any representative of Blue Marble in such individual’s
outside capacities.
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Codes of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Code of Ethics
Blue Marble believes that we owe clients the highest level of trust and fair dealing. As part of our
fiduciary duty, we place the interests of our clients ahead of the interests of the firm and our
personnel. Blue Marble and its personnel do not have a material financial interest in
recommendations made to client accounts. We have adopted a Code of Ethics that emphasizes the
high standards of conduct that Blue Marble seeks to observe. Blue Marble’s personnel are required
to conduct themselves with integrity at all times and follow the principles and policies detailed in our
Code of Ethics.
Blue Marble’s Code of Ethics attempts to address specific conflicts of interest that either we have identified or
that could likely arise. Our personnel are required to follow clear guidelines from the Code of Ethics in areas
such as gifts and entertainment, other business activities, prohibitions of insider trading, and adherence to
applicable state and federal securities laws. Blue Marble will provide a complete copy of the Code of Ethics to
any client or prospective client upon request.
Personal Trading Practices
Individuals who formulate investment advice for clients, or who have access to nonpublic
information regarding any clients’ purchase or sale of securities, are subject to Blue Marble’s
personal trading policies. Blue Marble and our personnel may purchase or sell securities for
ourselves that we also recommend to clients. This includes related securities (e.g., warrants,
options, or futures). This presents a conflict of interest as we have an incentive to favor our personal
trades over client transactions or use the information about the transactions we intend to make for
clients to our personal benefit. Our policies to address these conflicts include the following:
1. As a fiduciary to our clients, we always seek to put our clients’ interests first. Clients receive the opportunity
to act on investment recommendations prior to and in preference to accounts of Blue Marble and our
personnel. Blue Marble prohibits trading in a manner that takes personal advantage of our knowledge
of client transactions or price movements caused by client transactions.
2. At times, we might wish to trade in the same security that we plan to trade for a client. For mutual
funds, if we traded on the same day as clients, we would receive the same price, since mutual funds
are issued and redeemed once daily at the fund's net asset value ("NAV"). For stocks or other
securities where prices fluctuate during the day, we will place our own transactions after we place
client trades. Since prices fluctuate, this does not guarantee that clients will get better prices than
our personnel.
Brokerage Practices
Blue Marble requires clients to open an account with Charles Schwab (Schwab), an independent
qualified custodian. The client will enter into a separate agreement with Schwab to custody the
assets. Blue Marble is independently owned and operated and is not affiliated with Schwab.
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By requiring clients to use Schwab, Blue Marble believes we may be able to more effectively
manage the client’s portfolio, achieve favorable execution of client transactions, and overall lower
the costs to the portfolio. Clients may not direct Blue Marble to place trades through any outside
brokers. Not all investment advisers require their clients to trade through specific brokerage firms.
Factors Considered in Selecting Broker-Dealers for Client Transactions
Research and Other Benefits
Schwab provides Blue Marble with access to Schwab’s institutional trading and custody services,
which are typically not available to Schwab retail investors. Schwab includes brokerage services
that are related to the execution of securities transactions, custody, research, including that in the
form of advice, analyses and reports, and access to mutual funds and other investments that are
otherwise generally available only to institutional investors or would require a significantly higher
minimum initial investment. For Blue Marble client accounts maintained in its custody, Schwab
generally does not charge separately for custody services but is compensated by account holders
through commissions or other transaction-related or asset-based fees for securities trades that are
executed through Schwab or that settle into Schwab accounts.
Schwab also makes available to Blue Marble other products and services that benefit Blue Marble
but may not benefit its clients’ accounts. These benefits may include national, regional or Blue
Marble specific educational events organized and/or sponsored by Schwab. Other potential benefits
may include occasional business entertainment of Blue Marble personnel by Schwab personnel,
including meals, invitations to sporting events, including golf tournaments, and other forms of
entertainment, some of which may accompany educational opportunities. Other of these products
and services assist Blue Marble in managing and administering clients’ accounts. These include
software and other technology (and related technological training) that provide access to client
account data (such as trade confirmations and account statements), facilitate trade execution (and
allocation of aggregated trade orders for multiple client accounts, if applicable), provide research,
pricing information and other market data, facilitate payment of Blue Marble’s fees from its clients’
accounts (if applicable), and assist with back-office training and support functions, recordkeeping
and client reporting. Many of these services generally may be used to service all or some
substantial number of Blue Marble’s accounts. Schwab also makes available to Blue Marble other
services intended to help Blue Marble manage and further develop its business enterprise. These
services may include professional compliance, legal and business consulting, publications and
conferences on practice management, information technology, business succession, regulatory
compliance, employee benefits providers, and human capital consultants, insurance and marketing.
In addition, Schwab may make available, arrange and/or pay vendors for these types of services
rendered to Blue Marble by independent third parties. Schwab may discount or waive fees it would
otherwise charge for some of these services or pay all or a part of the fees of a third-party providing
these services to Blue Marble. Blue Marble is independently owned and operated and not affiliated
with Schwab.
Account Reviews
Accounts are reviewed on a regular basis by the Portfolio Manager to determine their conformity
with client investment objectives, guidelines and Blue Marble’s investment strategy. The review
process is based on a variety of factors, which include but are not limited to: each model’s
investment strategy, a client’s stated investment objectives, the economic environment, outlook for
the securities markets and the merits of the securities and/or mutual funds in which the accounts
are invested. Each client account will be reviewed at least quarterly. In addition, a special review of
an account may be triggered by one or more of the following: 1) a change in the client’s investment
objectives, guidelines and/or financial situation communicated by the client, 2) change in
diversification, 3) tax considerations, 4) cash added or withdrawn from account, and 5) purchase or
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sale of a security or mutual fund in the account.
Account Reporting
Each client has access to a written account statement from the custodian that includes an
accounting of all holdings and transactions in the client’s account for the reporting period. Blue
Marble does not provide additional reporting on the accounts we manage.
Client Referrals and Other Compensation
Support Products and Services
We receive an economic benefit from Charles Schwab & Co. (Schwab) in the form of the support
products and services they make available to us and other independent investment advisors whose
clients maintain their accounts at Schwab. These products and services, how they benefit us, and
the related conflicts of interest are described in our Form ADV Part 2A brochure. We do not base
particular investment advice, such as buying particular securities for our clients, on the availability of
Schwab’s products and services to us.
Other than the benefits from Schwab discussed immediately above, we do not receive any
compensation from third parties for advisory services we provide to clients and we do not pay any
third party for referrals.
Financial Information
Registered investment advisers are required in this item to provide clients with certain financial
information or disclosures about the firm’s financial condition. Blue Marble does not foresee any
financial condition that is reasonably likely to impair our ability to meet contractual commitments to
clients. Blue Marble Investments has never had a bankruptcy petition.
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Form ADV, Part 2B Brochure Supplement
Arturo Tabuenca
CRD # 2134379
Blue Marble Investments, LLC
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
www.bluemarble.com
www.earthfolio.net
May 6, 2026
This brochure supplement provides information about Arturo Tabuenca that supplements the Blue Marble
Investments, LLC brochure. You should have already received a copy of that brochure. Please contact us
at 805.595.1820 if you did not receive our brochure or if you have any questions about the contents of this
supplement. Additional information about Arturo Tabuenca is available on the SEC's website at
www.adviserinfo.sec.gov.
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ARTURO A. TABUENCA
CRD # 2134379
ITEM 2 - EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Arturo A. Tabuenca, Managing Member and Portfolio Manager, b. 1968
Education:
B.A. in Business Administration; Loma Linda University, Riverside, CA; 1991
Business Background:
2000 to present
Blue Marble Investments, LLC ("Blue Marble")
Managing Member and Investment Adviser
Representative (from 2000-2007 Blue Marble
held IAR registration with the SEC through
Commonwealth Financial Network)
2015 to present
Purshe Kaplan Sterling Investments;
Registered Representative
2007 to 2014
Sorrento Pacific Financial, LLC, formerly
Partnervest Advisory Services, LLC;
Registered Representative
Commonwealth Financial Network;
Registered Representative
2000 to 2007
1993 to 2000
Banc of America Investment Services (AKA
BA Investment Services, Inc.); Vice President;
Financial Advisor
1991 to 1993
Great American Securities; Registered
Representative
ITEM 3 - DISCIPLINARY INFORMATION
Arturo Tabuenca has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
In addition to the investment advisory services he provides through Blue Marble, Arturo Tabuenca,
Blue Marble's Portfolio Manager, is also a licensed insurance agent and a registered securities
representative of Purshe Kaplan Sterling Investments ("PKS"), a non-affiliated registered
broker-dealer and a member of the Financial Industry Regulation Authority ("FINRA"). Mr.
Tabuenca's activities with PKS represent less than 5% of his time and are generally only conducted
upon client request or for products outside the scope of Blue Marble's socially responsible objective.
A conflict of interest exists to the extent that Mr. Tabuenca receives commissions and/or trailing
service fees related to the sale of commissionable products, as this practice gives him an incentive
to recommend products based on the compensation received, rather than on the client's needs.
Therefore, clients are advised that the client is under no obligation to act on these
recommendations or purchase commissionable products through Mr. Tabuenca as a registered
representative. In all cases, insurance commissions will be fully disclosed to the client.
Commissions from these products are separate from any fees that Blue Marble receives for
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advisory services. Clients have the right to utilize or decline to utilize the services of any
representative of Blue Marble in their outside capacity and have the right to purchase services or
products recommended by Blue Marble through another provider.
ITEM 5 - ADDITIONAL COMPENSATION
Arturo Tabuenca's compensation comes from his regular income and ownership of Blue Marble
and from his other business activities described in Item 4 above.
ITEM 6 - SUPERVISION
Arturo Tabuenca is the Managing Member of Blue Marble and is supervised by Linda Shelby, the
firm's Chief Compliance Officer. Linda Shelby is responsible for ensuring that Arturo Tabuenca
adheres to all required regulations regarding the activities of an Investment Adviser Representative,
as well as all policies and procedures outlined in the firm's Code of Ethics and compliance manual.
The phone number for Linda Shelby is (805) 595-1820.
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Form ADV, Part 2B Brochure Supplement
Linda S. Shelby
CRD# 1286574
Blue Marble Investments, LLC
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
www.bluemarble.com
www.earthfolio.net
May 6, 2026
This brochure supplement provides information about Linda Shelby that supplements the Blue
Marble Investments, LLC brochure. You should have already received a copy of that brochure.
Please contact us at 805.595.1820 if you did not receive our brochure or if you have any questions
about the contents of this supplement.
Additional information about Linda Shelby is available on the SEC’s website at
www.adviserinfo.sec.gov.
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LINDA SMITH SHELBY
CRD# 1286574
ITEM 2- EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Linda S. Shelby, Chief Administrative Officer and Chief Compliance Officer, b. 1960
Education:
B.S. in Business Administration/Finance; California State University, Fresno, CA; 1983
Business Background:
2017 to present
Blue Marble Investments, LLC; Compliance
Officer; Chief Administrative Officer
1990 to 2016
Bank of America/Merrill Lynch; Senior
Vice President; West Division Executive
Registered Representative and IAR;
(Prior to merger with ML, Bank of
America investment firms operated
under names: Banc of America
Investment Services, Inc., BA
Investment Services, Inc., Investment
Network of America – Great Northern
Annuity
1989 to 1990
First Imperial Investments; Financial
Advisor-Registered Representative
1987- 1989
Merrill Lynch; Financial Advisor-Registered
Representative,
1984-1987
Dean Witter Reynolds (Morgan Stanley);
Financial Advisor-Registered Representative
ITEM 3 – DISCIPLINARY INFORMATION
Linda Shelby has no disciplinary history to disclose.
ITEM 4 – OTHER BUSINESS ACTIVITIES
Linda Shelby is not actively engaged in any other business or occupation that creates a material
conflict of interest.
ITEM 5 – ADDITIONAL COMPENSATION
Linda Shelby does not receive additional compensation that creates a material conflict of interest.
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ITEM 6 – SUPERVISION
Arturo Tabuenca is the Managing Member of Blue Marble and supervises the investment activities
performed by Linda Shelby. Arturo Tabuenca is responsible for ensuring that Linda Shelby adheres
to all required regulations regarding the activities of an Investment Adviser Representative, as well
as all policies and procedures outlined in the firm’s Code of Ethics and compliance manual. Arturo
Tabuenca can be reached at 805-595-1820.
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Form ADV, Part 2B Brochure Supplement
Sierra Smith
CRD# 7373331
Blue Marble Investments, LLC
1117 State Street Ste 85
Santa Barbara, CA 93131
805.595.1820
May 6, 2026
This brochure supplement provides information about Sierra Smith that supplements the Blue
Marble Investments, LLC brochure. You should have already received a copy of that brochure.
Please contact us at 805.595.1820 if you did not receive our brochure or if you have any questions
about the contents of this supplement.
Additional information about Sierra Smith is available on the SEC's website at
www.adviserinfo.sec.gov.
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SIERRA KATHRYN SMITH
CRD# 7373331
ITEM 2- EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Sierra Smith, Investment Adviser Representative, b. 1998
Education:
Bachelor of Arts Sociology; California Polytechnic State University, San Luis Obispo, CA; 2021
Business Background:
10/2021 to Present
Blue Marble Investments, LLC; Investment
Adviser Representative
Blue Marble Investments LLC; Associate
04/2021 to 10/2021
09/2017 to 06/2021
California Polytechnic State University;
Student
Professional Designations:
Certified Financial Planner (CFP®) professional
Sierra Smith is certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, she may refer to herself as a
CERTIFIED FINANCIAL PLANNER™ professional or a CFP® professional, and may use these and CFP Board’s
other certification marks (the “CFP Board Certification Marks”). The CFP® certification is voluntary. No
federal or state law or regulation requires financial planners to hold the CFP® certification. You may find
more information about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and
ethics. To become a CFP® professional, an individual must fulfill the following requirements:
Education – Earn a bachelor’s degree or higher from an accredited college or university and complete
CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as comprehensive financial
plan development capstone course. A candidate may satisfy some of the coursework requirement
through other qualifying credentials.
Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations. Experience – Complete 6,000 hours of professional
experience related to the personal financial planning process, or 4,000 hours of apprenticeship
experience that meets additional requirements.
Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
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Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board Certification
Marks:
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to
CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the
client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
professional’s services. A client who seeks a similar commitment should obtain a written engagement
that includes a fiduciary obligation to the client.
Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with
developments in financial planning. Two of the hours must address the Code and Standards.
ITEM 3 - DISCIPLINARY INFORMATION
Sierra Smith has no disciplinary history to disclose.
ITEM 4 - OTHER BUSINESS ACTIVITIES
Sierra Smith is a registered representative of Purshe Kaplan Sterling Investments (“PKS”). From
time to time, she will offer clients advice or products from this activity. Clients should be aware
that these services pay a commission and involve a possible conflict of interest, as
commissionable products can conflict with the fiduciary duties of a registered investment adviser.
Blue Marble always acts in the best interest of the client, including in the sale of commissionable
products to advisory clients. Clients are in no way required to utilize the services of any
representative of Blue Marble in such individual's outside capacity.
Sierra Smith is a licensed insurance agent. From time to time, she will offer clients advice or
products from those activities. Clients should be aware that these services pay a commission and
involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a
registered investment adviser. Blue Marble always acts in the best interest of the client, including
the sale of commissionable products to advisory clients. Clients always have the right to decide
whether to utilize the services of any representative of Blue Marble in such individual's outside
capacities.
ITEM 5 - ADDITIONAL COMPENSATION
Sierra Smith does not receive additional compensation that creates a material conflict of interest.
ITEM 6 - SUPERVISION
As a representative of Blue Marble Investments, LLC, Sierra Smith is supervised by Linda Shelby, the firm's
Chief Compliance Officer. Linda Shelby is responsible for ensuring that Sierra Smith adheres to all required
regulations regarding the activities of an investment adviser representative, as well as all policies and
procedures outlined in the firm's Code of Ethics and compliance manual. The phone number for Linda
Shelby is (805) 595-1820.
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