BUILDER INVESTMENT GROUP INC

Form ADV Part 2A March 18, 2025 Builder Investment Group CRD/IARD#: 107671 4401 Northside Pkwy, NW, Suite 520 Atlanta, GA 30327 404-233-9341 big-inc.com This brochure (“Brochure”) provides information about the qualifications and business practices of Builder Investment Group (“BIG”). You should review this Brochure in conjunction with our separate brochure supplement (“Supplement”). The Supplement(s) has been prepared for the purpose of providing information about the qualifications and background of the supervised person(s) working with you on our behalf or who may otherwise participate in the advisory services provided to you. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. If you have any questions about the contents of this Brochure or our Supplement(s), please contact us at 404-233-9341 or dhajost@big-inc.com. Additional information about BIG or any of our supervised persons (who are registered under our firm) is also available on the SEC’s Investment Adviser Public Disclosure (“IAPD”) which can be found at www.adviserinfo.sec.gov. The format/layout of this Brochure has been dictated by the SEC. As such, the Brochure’s table of contents can be found after the “Material Changes” section of this Brochure, not at the beginning of the Brochure. The subsections appearing under each heading shall follow the mandated ordering of the items required to be addressed in this Brochure as set forth in the instructions and guidance issued by the SEC in regard to Part 2A of the Form ADV. BIG’s response to each such item shall immediately follow each numbered item. We encourage any reader of this Brochure to also refer to the SEC’s instructions and guidance related to Part 2A of the Form ADV. Throughout this Brochure, any references to “we,” “our,” “ours,” “us,” etc. are meant to refer to BIG.  II. Material Changes Filing date of last annual ADV update: March 25, 2024. Since the filing of our most recent annual ADV update, there have been no material changes between the information previously reflected in our former Form ADV and this Brochure. Page 2 of 19  III. Table of Contents II. Material Changes................................................................................................................................................................................... 2 III. Table of Contents ................................................................................................................................................................................. 3 IV. Advisory Business ............................................................................................................................................................................... 5 Item IV.(A). BIG at a Glance ................................................................................................................................................................ 5 Firm Profile ....................................................................................................................................................................................... 5 Years in Business .............................................................................................................................................................................. 5 Direct Principal Owners .................................................................................................................................................................... 5 IV.(B). BIG’s Advisory Services.......................................................................................................................................................... 5 Product Type Limitations .................................................................................................................................................................. 5 Our Services ...................................................................................................................................................................................... 5 Ongoing Asset Management ......................................................................................................................................................... 5 IV.(C). Customization of Advisory Services ........................................................................................................................................ 7 IV.(D). Wrap Fee Program Participation .............................................................................................................................................. 7 IV. (E). Assets Under Management (“AUM”) ..................................................................................................................................... 7 V. Fees and Compensation ........................................................................................................................................................................ 8 V.(A). BIG Advisory Fees .................................................................................................................................................................... 8 V.(B). Fee Collection Process .............................................................................................................................................................. 8 V.(C). Other Fee/Expenses. .................................................................................................................................................................. 8 V.(D). Fees Charged in Advance .......................................................................................................................................................... 8 V.(E). Additional Compensation .......................................................................................................................................................... 8 V.(E).(1). Conflicts of Interest ......................................................................................................................................................... 8 V.(E).(2). Client-Directed Brokerage ............................................................................................................................................... 8 V.(E).(3). Brokerage Compensation ................................................................................................................................................. 8 V.(E).(4). Advisory Fee Offset ......................................................................................................................................................... 8 VI. Performance-Based Fees and Side-By-Side Management ................................................................................................................... 8 VII. Types of Clients.................................................................................................................................................................................. 9 VIII. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................................................... 9 VIII.(A). Methods of Analysis .............................................................................................................................................................. 9 VIII.(A). Investment Strategies ............................................................................................................................................................ 9 VIII.(B). Risk Disclosures ................................................................................................................................................................... 10 VIII.(C). Investment-Specific Risks .................................................................................................................................................... 11 IX. Disciplinary Information ................................................................................................................................................................... 12 X. Other Financial Industry Activities and Affiliations ........................................................................................................................... 12 X.(A). Broker-Dealers ......................................................................................................................................................................... 12 X.(B). Futures Commission Merchants, Introducing Brokers, Commodity Trading Advisors, Commodity Pool Operators ............. 12 X.(C). Related Persons ........................................................................................................................................................................ 12 X.(D) Use of Other Investment Advisers ............................................................................................................................................ 12 XI. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................... 13 XI.A Code of Ethics ............................................................................................................................................................................ 13 XI.(B) Participation in Client Trading ................................................................................................................................................. 13 Page 3 of 19  XI.(C) Trading Alongside Our Clients ................................................................................................................................................ 13 XI.(D) Trading Around the Same Time as Clients .............................................................................................................................. 14 XII. Brokerage Practices .......................................................................................................................................................................... 14 XII.(A).(1). Research and Soft Dollar Benefits ................................................................................................................................... 15 XII.(A).(2). Brokerage for Client Referrals ......................................................................................................................................... 15 XII.(A).(3). Directed Brokerage .......................................................................................................................................................... 15 XII.(A).(3)(a). Directed Brokerage – Recommended, Requested, or Required ......................................................................... 15 XII.(A).(3)(b). Directed Brokerage – Permitted ........................................................................................................................ 15 XII.(B). Order Batching....................................................................................................................................................................... 15 XIII. Review of Accounts ........................................................................................................................................................................ 16 XIII.(A). Review of Accounts or Financial Plans................................................................................................................................ 16 Review of client accounts. .............................................................................................................................................................. 16 Review of Financial Plans. .............................................................................................................................................................. 16 XIII.(B). Non-Periodic Account Reviews ........................................................................................................................................... 16 XIII.(C). Reports to Clients ................................................................................................................................................................ 16 XIV. Client Referrals and Other Compensation ...................................................................................................................................... 16 XIV.(A). Compensation we Receive ................................................................................................................................................... 16 XIV.(B). Compensation we Pay .......................................................................................................................................................... 16 XV. Custody ............................................................................................................................................................................................ 17 XVI. Investment Discretion ..................................................................................................................................................................... 17 XVII. Voting Client Securities................................................................................................................................................................. 17 XVII.(A). Proxy Voting....................................................................................................................................................................... 17 Proxy Voting Policies and Procedures and Client Instruction......................................................................................................... 17 How to obtain our proxy voting record… ....................................................................................................................................... 18 XVII.(B). Proxy Voting ....................................................................................................................................................................... 18 XVIII. Financial Information ................................................................................................................................................................... 18 XVIII.(A). Balance Sheet ................................................................................................................................................................... 18 XVIII.(B). Adverse Financial condition ............................................................................................................................................. 18 XVIII.(C). Bankruptcy-Related Matters .............................................................................................................................................. 19 XIX. Requirements for State-Registered Advisers .................................................................................................................................. 19 Page 4 of 19  IV. Advisory Business Item IV.(A). BIG at a Glance Firm Profile BIG is an Atlanta based registered investment advisory firm that provided personalized portfolio management services for individuals, corporations, and corporate employee benefit plans. Years in Business Date of formation: August 9, 1983. Date of initial investment adviser registration: October 1, 1983. Direct Principal Owners Allen A. Builder is the sole owner of BIG. IV.(B). BIG’s Advisory Services In this section, we will describe the services we offer as well as the fees that correspond to those services. Product Type Limitations We generally provide investment advice in relation to the following specific types of securities/investments. • Exchange listed equities • Over the counter equities • Interests in privately offered securities (hedge funds, venture capital funds, private equity funds, etc.) involving any of the following: o Real estate o Oil and gas o Mortgages or other receivables/assets o Other: venture capital funds, direct equity investments • Corporate debt securities (other than commercial paper) • Certificates of deposit • Municipal securities • Variable annuities • Mutual funds (closed-end and open-end funds) • U.S. government securities Our Services Service: Ongoing Asset Management Service description: Use of discretion: Our ongoing asset management services are offered a discretionary basis. Under this service, we may design, revise, and reallocate a custom investment portfolio for you. Investments are determined based upon factors such as your investment objectives, risk tolerance, net worth, net income, age, time horizon, tax situation and other various suitability factors. Depending on your individual needs and the services you request of us, we may exercise full discretion as to the securities to be bought or sold; amount of the securities to be bought or sold; timing as to when such securities are to be bought or sold; broker- dealer and/or custodian to be used.. Page 5 of 19  Our specific discretionary authority will be set forth in your service agreement (“Agreement”) with us. For the service described above, we will charge fees in the following manner: Asset-Based Fee Schedule Account(s)/Portfolio Value First $1,000,000 Annual Percentage 1.00 % Next $2,000,000 0.750% Next $7,000,000 0.50% In excess of $10,000,000 negotiable Service fees: Other fee/account maintenance conditions… Minimum account/portfolio balance (initial): Minimum account/portfolio balance (ongoing): Minimum annual fee: None $250,000 None $ None $ Other fees: All fee arrangements are negotiable at our sole discretion. Specific fee arrangements will be set forth in your service Agreement with us. In addition to our service fees, you may be assessed other fees by parties independent from us. You may also incur, relative to certain investment products (such as mutual funds), charges imposed directly at the investment product level (i.e. advisory fees, administrative fees, and other fund expenses.) Brokerage fees/commissions charged to you for securities trade executions may be billed to you by the broker-dealer or custodian of record for your account, not us. Any such fees are exclusive of, and in addition to our compensation. You will be solely and directly responsible for all fees, including fees other than those we may bill directly to you. Refer to Item V.(E) and Item 12 for additional information regarding other fees such as sales compensation, brokerage fees, custodial fees, etc. Contemporaneously with the execution of the Agreement, you will be asked to sign an authorization that will allow the custodian of any of your account(s) to debit the account(s) the amount of our service fees and remit the fee to us. The authorization will remain valid unless and until we receive a written revocation of such authorization from you. In connection with this fee deduction process, the custodian will send you a statement, at least quarterly, indicating: Fee collection: all amounts disbursed from the account, and the amount of advisory fees paid directly to us. • • Specific fee arrangements will be set forth in your Agreement with us. For the service described above, the frequency and timing of our fee collection process occurs as follows: quarterly, monthly, in advance, or in arrears. Fee frequency/timing: Advanced billing and refunds: Specific fee arrangements will be set forth in your Agreement with us. As described above, our advisory fees may be charged in advance. Fees paid in advance will be considered earned and non-refundable to you up to the effective termination of the Agreement as the termination process is described in the Agreement. Upon receipt of a proper notice of termination (“Termination Notice”) as described in the Agreement, we will calculate a prorata refund of any fees not yet earned by us after the effective termination date of the Agreement. The prorata refund will equal the total number of calendar days remaining in the billing period after the date of the termination of the Agreement to the end of that billing period divided by the total number of calendar days in that billing period. The result of that calculation will be multiplied by the total fee already paid for that billing period. The result of that calculation will represent the refund owed to you. Refunds of advance payments owed back to you shall be paid as Page 6 of 19  soon as reasonably possible but not sooner than ten (10) business days after our receipt of a proper Termination Notice. Specific fee arrangements will be set forth in your Agreement with us. IV.(C). Customization of Advisory Services To the fullest extent possible, we will endeavor to tailor our advisory services to meet the specific needs of each and every client. In order to determine a suitable course of action for an individual client, we will perform a review of our clients’ financial circumstances and other factors that may influence the investment recommendations we may make to you from time to time. Such review may include, but would not necessarily be limited to, investment objectives, consideration of a client’s overall financial condition, income and tax status, personal and business assets, risk profile, and other factors unique to a client’s particular circumstances. In making investment recommendations on behalf of a client, we will rely on a data gathering document or other questionnaire, which would be completed based on information provided by a client. Our clients are free to impose any restrictions or other conditions with regard to how we provide our advisory services. If we agree to such restrictions and/or conditions, please be advised that restrictions and guidelines that you impose on our investment management functions may affect the composition and performance of custom portfolios (as a result, performance of custom portfolios within the same investment objective may differ and you should not expect that the performance of a custom portfolio will be identical to any other individual’s portfolio performance) as well as any recommendations provided to you. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. IV.(D). Wrap Fee Program Participation None of our investment advisory services involve the use of wrap programs. IV. (E). Assets Under Management1 (“AUM”) AUM (discretionary): $ 837,804,375 AUM (non-discretionary): $ 0 Total AUM: $ 837,804,375 Date of AUM calculation: February 28, 2025 1 The term, “assets under management” shall carry the same meaning as that term is defined by Form ADV. Page 7 of 19  V. Fees and Compensation V.(A). BIG Advisory Fees Refer above to Item IV.(B). V.(B). Fee Collection Process Refer above to Item IV.(B). V.(C). Other Fee/Expenses. Refer above to Item IV.(B). V.(D). Fees Charged in Advance Refer above to Item IV.(B). V.(E). Additional Compensation Item V.(E) requires us to address situations in which we or any of our supervised persons accepts compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Neither we, nor any of our supervised persons are party to such arrangements. V.(E).(1). Conflicts of Interest The instructions in the Form ADV require us to tell you that the receipt or potential for the receipt of Additional Compensation gives our supervised persons an incentive to recommend investment products based on the Additional Compensation received, rather than on your specific needs. As described above in Item V.(E)., neither we nor any of our supervised persons are party to any such arrangement, therefore, no conflict in this regard is present. V.(E).(2). Client-Directed Brokerage You have the ability to purchase investment products that we recommend through any broker-dealer or other financial institution you choose. If you choose to use a firm other than the broker-dealer(s) we may normally recommend, we may not be able to properly monitor your assets and therefore we cannot be held responsible for the success or failure of any investment products or strategies that you implement at firms other than those we recommend. In other words, our services and responsibilities will not apply to transactions you effect on your own whether through firms you choose on your own or through any broker-dealer we may recommend. V.(E).(3). Brokerage Compensation We are not registered as a broker-dealer and thus, we do not receive transaction–based compensation for securities-related activities. V.(E).(4). Advisory Fee Offset Since none of our supervised persons receive compensation other than our advisory fees as described above in Item IV.(B), this issue does not apply to us. VI. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees. Page 8 of 19  VII. Types of Clients We will generally provide our services to the following types of clients. Individuals • • High net worth individuals • Pension plans / profit sharing plans • Foundations / charitable organizations • Trusts for natural persons • Estates for natural persons • Business or corporate entities For information on any minimum fees, minimum initial/ongoing account balances, or other conditions we may impose, please refer to Item IV.(B). VIII. Methods of Analysis, Investment Strategies and Risk of Loss VIII.(A). Methods of Analysis In the course of our management process and as appropriate on a case by case basis, we will employ some or all of the following methods of analysis. For a description of the risks related to each particular method of analysis, see the information following each analysis method description. A description of each key risk appears later in this section. Charting / Technical The terms “charting” and “technical” analysis are generally used synonymously and therefore, for the purpose of this document, we will use the term, “technical analysis.” In most cases, technical analysis involves the evaluation of historical market data such as price and volume of a particular security or investment instrument. Technical analysis often times involves the use of charts, graphs, and other tools to evaluate historical factors relating to the investment instrument and perhaps the market as a whole. The goal of technical analysis is to try to identify historical trading patterns that suggest future trading activity or price targets. Key risk(s): Economic Risk, Financial Risk, Inflation Risk, Interest Rate Risk, Legal/Regulatory Risk, Market Risk, Operational Risk, and Strategy Risk. Fundamental Fundamental analysis is generally the considered the opposite approach to technical analysis. Fundamental analysis involves the attempt to identify the intrinsic value (i.e. the actual, true/real value) of an investment instrument by examining any related economic, financial, and other quantitative/qualitative factors relevant to that instrument. Fundamental analysis can take into account anything that may impact the underlying value of the instrument. Examples of such things may include large-scale economic issues such as the overall condition or current cycle of the economy, industry-specific or sector-specific conditions, etc. Other company/issuer-specific factors may also be taken into consideration such as the company’s/issuer’s current financial condition, management experience and capabilities, legal/regulatory matters, the overall type and volume of current and expected business, etc. One of the goals of fundamental analysis is to attempt to derive a value that can be compared to the current market price for a particular financial instrument in hopes of determining whether the instrument is overpriced (time to sell) or underpriced (time to buy). Key risk(s): Economic Risk, Financial Risk, Inflation Risk, and Interest Rate Risk. Investing in securities or other investment products involves the risk of loss and you should be prepared to bear such losses. VIII.(A). Investment Strategies In the course of our management process and as appropriate on a case by case basis, we will employ any of the following investment strategies. For a description of the risks related to each particular investment strategy, see the information following each strategy description. The codes used below relate to risks described further below in this section. Page 9 of 19  Long-Term Purchases Long-term purchases generally involve the acquisition of an investment instrument and holding it for a period of at least one year. Key risk(s): Capital Risk, Economic Risk, Financial Risk, Inflation Risk, Interest Rate Risk, Legal/Regulatory Risk, Liquidity Risk, Market Risk, Operational Risk, Strategy Risk. Short-Term Purchases Short-term purchases generally involve the acquisition of an investment instrument and holding it for a period of not more than one year. Key risk(s): Capital Risk, Economic Risk, Financial Risk, Higher Trading Costs, Interest Rate Risk, Legal/Regulatory Risk, Liquidity Risk, Market Risk, Operational Risk, Strategy Risk. Margin Trading Margin trading, or “trading on margin,” as it is generally stated, involves the ability to purchase a dollar value of securities that is greater than the dollar value of funds you have available for the purchase. Essentially, trading on margin means that you can borrow additional funds, generally from the firm that holds your brokerage account, to purchase investment instruments that exceed the amount with which you have funded your account. Key risk(s): Capital Risk, Economic Risk, Financial Risk, Interest Rate Risk, Legal/Regulatory Risk, Liquidity Risk, Market Risk, Operational Risk, Strategy Risk. Investing in securities or other investment products involves the risk of loss and you should be prepared to bear such losses. VIII.(B). Risk Disclosures Capital Risk Capital risk is one of the most basic, fundamental risks of investing; it is the risk that you may lose 100 percent of your money. All investments carry some form of risk and the loss of capital is generally a risk for any investment instrument. Credit Risk Credit risk can be a factor in situations where an investment’s performance relies on a borrower’s repayment of borrowed funds. With credit risk, an investor can experience a loss or unfavorable performance if a borrower does not repay the borrowed funds as expected or required. Investment holdings that involve forms of indebtedness (i.e. borrowed funds) are subject to credit risk. Currency Risk Fluctuations in the value of the currency in which your investment is denominated may affect the value of your investment and thus, your investment may be worth more or less in the future. All currency is subject to swings in valuation and thus, regardless of the currency denomination of any particular investment you own, currency risk is a realistic risk measure. That said, currency risk is generally a much larger factor for investment instruments denominated in currencies other than the most widely used currencies (U.S. dollar, British pound, German mark, Euro, Japanese yen, French franc, etc.). Economic Risk The prevailing economic environment is important to the health of all businesses. Some companies, however, are more sensitive to changes in the domestic or global economy than others. These types of companies are often referred to as cyclical businesses. Countries in which a large portion of businesses are in cyclical industries are thus also very economically sensitive and carry a higher amount of economic risk. If an investment is issued by a party located in a country that experiences wide swings from an economic standpoint or in situations where certain elements of an investment instrument are hinged on dealings in such countries, the investment instrument will generally be subject to a higher level of economic risk. Financial Risk Financial risk is represented by internal disruptions within an investment or the issuer of an investment that can lead to unfavorable performance of the investment. Examples of financial risk can be found in cases like Enron or many of the dot com companies that were caught up in a period of extraordinary market valuations that were not based on solid financial footings of the companies. Higher Trading Costs For any investment instrument or strategy that involves active or frequent trading, you may experience larger than usual transaction- related costs. Higher transaction-related costs can negatively affect overall investment performance. Page 10 of 19  Inflation Risk Inflation risk involves the concern that in the future, your investment or proceeds from your investment will not be worth what they are today. Throughout time, the prices of resources and end-user products generally increase and thus, the same general goods and products today will likely be more expensive in the future. The longer an investment is held, the greater the chance that the proceeds from that investment will be worth less in the future than what they are today. Said another way, a dollar tomorrow will likely get you less than what it can today. Interest Rate Risk Certain investments involve the payment of a fixed or variable rate of interest to the investment holder. Once an investor has acquired or has acquired the rights to an investment that pays a particular rate (fixed or variable) of interest, changes in overall interest rates in the market will affect the value of the interest-paying investment(s) they hold. In general, changes in prevailing interest rates in the market will have an inverse relationship to the value of existing, interest paying investments. In other words, as interest rates move up, the value of an instrument paying a particular rate (fixed or variable) of interest will go down. The reverse is generally true as well. Legal/Regulatory Risk Certain investments or the issuers of investments may be affected by changes in state or federal laws or in the prevailing regulatory framework under which the investment instrument or its issuer is regulated. Changes in the regulatory environment or tax laws can affect the performance of certain investments or issuers of those investments and thus, can have a negative impact on the overall performance of such investments. Liquidity Risk Certain assets may not be readily converted into cash or may have a very limited market in which they trade. Thus, you may experience the risk that your investment or assets within your investment may not be able to be liquidated quickly, thus, extending the period of time by which you may receive the proceeds from your investment. Liquidity risk can also result in unfavorable pricing when exiting (i.e. not being able to quickly get out of an investment before the price drops significantly) a particular investment and therefore, can have a negative impact on investment returns. Market Risk The market value of an investment will fluctuate as a result of the occurrence of the natural economic forces of supply and demand on that investment, its particular industry or sector, or the market as a whole. Market risk may affect a single issuer, industry or sector of the economy or may affect the market as a whole. Market risk can affect any investment instrument or the underlying assets or other instruments held by or traded within that investment instrument. Operational Risk Operational risk can be experienced when an issuer of an investment product is unable to carry out the business it has planned to execute. Operational risk can be experienced as a result of human failure, operational inefficiencies, system failures, or the failure of other processes critical to the business operations of the issuer or counter party to the investment. Past Performance Charting and technical analysis are often used interchangeably. Technical analysis generally attempts to forecast an investment’s future potential by analyzing its past performance and other related statistics. In particular, technical analysis often times involves an evaluation of historical pricing and volume of a particular security for the purpose of forecasting where future price and volume figures may go. As with any investment analysis method, technical analysis runs the risk of not knowing the future and thus, investors should realize that even the most diligent and thorough technical analysis cannot predict or guarantee the future performance of any particular investment instrument or issuer thereof. Strategy Risk There is no guarantee that the investment strategies discussed herein will work under all market conditions and each investor should evaluate his/her ability to maintain any investment he/she is considering in light of his/her own investment time horizon. Investments are subject to risk, including possible loss of principal. VIII.(C). Investment-Specific Risks There is no single type of investment instrument that we predominantly recommend, however, please be mindful that all investments carry some form and degree of risk. Certain types of investments carry greater types and levels of risk than others and you should make sure that you fully understand not only the investment product itself but also the attendant risk factors associated with such products. Page 11 of 19  IX. Disciplinary Information The purpose of this section is for us to disclose to you any legal, disciplinary, or other events that you may consider material in your evaluation of our firm or the integrity of our management. We have no such events to report. X. Other Financial Industry Activities and Affiliations The following information will address any active or pending financial industry affiliations that you need to know about for the purpose of identifying any related conflicts of interest that you might consider material in regard to letting us handle your investment advisory needs. X.(A). Broker-Dealers Neither BIG nor any of its management persons is registered as a broker-dealer nor do either parties have an application pending or otherwise in process for the purpose of seeking registration as a broker-dealer. Further, none of our management persons are registered as or currently seeking registration as a registered representative of a broker-dealer. X.(B). Futures Commission Merchants, Introducing Brokers, Commodity Trading Advisors, Commodity Pool Operators Neither BIG nor any of its management persons is registered as a futures commission merchant, an introducing broker, a commodity trading adviser, or a commodity pool operator, nor do either parties have an application pending or otherwise in process for the purpose of seeking registration as any of these types of firms. Further, none of our management persons are registered as or currently seeking registration as associated persons of any of these types of firms. X.(C). Related Persons The purpose of this section is to address any relationship or arrangement that is material to our advisory business or to our clients that we or any of our management persons have with certain related persons of BIG. As outlined below, certain of BIG’s supervised persons serve as either the general partner or managing member of one or more pooled investment vehicles. Pooled Investment Vehicle BIG Partners XI General Partner / Managing Member Allen A. Builder How we Address the Conflict(s): First and foremost, we address this conflict by disclosing it to you in this Brochure. As a matter of general policy, we aggressively discourage activities that put your interests anywhere but first. Additionally, we have instituted a comprehensive supervisory program, detailed in our Written Supervisory Procedures (“WSPs”) that was designed to address, among other things, conflicts of interest such as the relationship between us and the Funds mentioned above. In addition, we have designated a Chief Compliance Officer, as set forth on Schedule A of our Form ADV, to be the party responsible for the overall application and oversight of our supervisory process and our WSPs. Our Chief Compliance Officer has the authority to delegate certain supervisory responsibilities to other supervised persons within our firm in order to ensure that our overall system of supervision is being carried adequately out and in a timely manner. As we stated above, in an effort to inform you of these conflicts of interest, we have prepared this Brochure and have provided it to you, in part, for the purpose of disclosing these conflicts. You are always welcome to request a current copy of our Brochure. We are obligated to provide you a copy of this Brochure no later than the time you sign our Agreement and on an annual basis, we are required to provide you either (1) a copy of our current Brochure or (2) a set of instructions as to how you can request a copy of our current Brochure. X.(D) Use of Other Investment Advisers We do not use other investment advisers in the course of the services described above in Item IV.(B). Page 12 of 19  XI. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading XI.A Code of Ethics We take great pride in our commitment to serving our clients’ needs and the integrity with which we conduct our business. In our recent history, the financial services industry has come under significant scrutiny, especially in the area of the inherent responsibility of financial professionals to behave in the best interests of their clients. We have developed a Code of Ethics (“Code”) as a means of memorializing our vision of appropriate and professional conduct in carrying out the business of providing investment advisory services. Our Code addresses issues such as the following: • Standards of conduct and compliance with applicable laws, rules, and regulations • Protection of material non-public information • The addressing of conflicts of interest • Employee disclosure and reporting of personal securities holdings and transactions • The firm’s IPO and private placement policy • The reporting of violations of the Code • Educating employees about the Code • Enforcement of the Code Each of our representatives has been furnished with a copy of our Code and has signed their names to a written acknowledgement attesting to their understanding of the Code and acceptance of its terms. A copy of our Code is available to all current and/or prospective clients upon request. XI.(B) Participation in Client Trading The information in this item is intended to address situations in which we or one of our related persons may have a material financial interest in the investment instruments we may recommend to you. Certain persons associated with BIG act as the general partner in one or more partnerships in which one or more of our clients have invested. For additional details on these arrangements, refer above to Item X.(C). XI.(C) Trading Alongside Our Clients On occasion, we may invest for our own accounts or have a financial interest in the same securities or other investments that we recommend or acquire for the accounts of our clients. Further, we may also engage in transactions that are the same as or different than transactions recommended to or made for our client’s accounts. Such transactions are permitted if effected, pre-cleared and reported in compliance with our policy on personal securities transactions. Generally, personal securities transactions will not be pre- cleared when an order for the same or a related security is pending for the account of a client. Our Designated Supervisor reviews reports of personal transactions in securities by all of our associated persons quarterly or more frequently if required. Investment Policy None of our associated persons may effect for himself/herself or for accounts in which he/she holds a beneficial interest, any transactions in a security which is being actively recommended to any of our clients, unless in accordance with the following procedures. Firm Procedures In order to implement our Investment Policy, the following procedures have been put into place. 1) If we are recommending that any of our clients buy any security, no associated person may purchase that security prior to a client’s purchase of that security; and 2) If we are recommending that any of our clients sell any security, no associated person may sell that security prior to a client’s sale of that security. As an alternative to the procedures described in the preceding points, we may included our own order(s) in a batch order with other client orders that would involve average pricing for the entire batch such that we would receive the same pricing as all other clients participating in the batch. Page 13 of 19  It is the primary intent of these procedures to ensure that the best interests of our clients are always served over that of our own. Trading on our own behalf that results in our own interests being served over that of our clients could be considered a breach of our fiduciary duty and thus, is aggressively discouraged. XI.(D) Trading Around the Same Time as Clients The information in this item is intended to address situations in which we or any of our related persons may invest in the investment instruments we may recommend to you. Since we do not make recommendations as to specific securities instruments, no such arrangements exist. Transactions for the client’s account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at the same or approximately the same time. We may (but are not obligated to) combine or “batch” such orders in order to obtain best execution or to negotiate more favorable transaction rates. To the extent that we elect to aggregate client orders for the purchase or sale of securities, including securities in which our associated persons may invest, we will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. We will not receive any additional compensation or remuneration as a result of a batched order. XII. Brokerage Practices The purpose of this Item is to present to you the factors that we take into consideration when (1) selecting or recommending broker- dealers to you for the purpose of effecting transactions on your behalf and (2) for determining the reasonableness of such broker- dealers’ compensation related to such transactions. BIG will select brokers based on a number of factors, including, but not limited to: • Speed and accuracy of order execution, • Cost of services rendered, • Research and statistical assistance made available to BIG. Other factors may include such entity’s financial strength, reputation, pricing, and service. In return for effecting securities transactions through certain broker-dealers/custodians, BIG or certain of its representatives may receive certain investment research products and/or services. Such investment research products and/or related services may assist BIG in its investment decision-making process for all of BIG’s clients. In seeking best execution, the determinative factor is not always the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer services, including factors such as the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although BIG will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. Although the investment research products and/or services that may be obtained by BIG will generally be used to service all of BIG’s clients, a brokerage commission paid by a specific client may be used (indirectly and in part) to pay for research that is not used in managing that specific client’s account. The reasonableness of brokerage commissions will be evaluated through objective comparison with rates charged for comparable services by other brokers and subjective estimates by the principals of the appropriate cost of such services. Research services received from brokers will consist of primarily historical information about companies being evaluated and their market environment, general tax, business information, and economic trend information. Selection of brokers will be based on each clients’ best interests, and, in many instances, a broker with a higher commission rate than another broker will be selected where the importance to the clients of other factors, such as execution reliability and research service availability, outweighs the additional costs. To the extent that these other factors affect BIG’s brokerage selections, clients may bear disproportionately more of the costs of these other factors, including research services. Page 14 of 19  XII.(A).(1). Research and Soft Dollar Benefits Soft dollar benefits are items such are research or other products or services (other than the typical execution and other brokerage services available to all other investment advisers) that an investment adviser may receive from a broker-dealer(s) or other party in connection with the client securities transactions are directed to that particular broker-dealer(s). We do not participate in soft dollar arrangements. XII.(A).(2). Brokerage for Client Referrals In certain circumstances, firms like ours may receive client referrals as a result of recommending particular broker-dealers or other service providers. We, however, do not participate in any formal arrangements wherein we receive client referrals from any particular broker-dealer in return for selecting or recommending such broker-dealer. XII.(A).(3). Directed Brokerage This item is intended to address situations where we may recommend, request, or require you to provide us instructions as to how to direct brokerage activity on your behalf. XII.(A).(3)(a). Directed Brokerage – Recommended, Requested, or Required Not all investment advisers require their clients to direct brokerage activity through any particular broker-dealer. We do not routinely recommend, request, or require that you direct us as to how to execute brokerage transactions on your behalf (i.e. using a particular broker-dealer for execution purposes). XII.(A).(3)(b). Directed Brokerage – Permitted Not all investment advisers require their clients to direct brokerage activity through any particular broker-dealer, however, you may direct us to use a particular broker-dealer (subject to our right to decline such a request) to execute some or all transactions for your account or otherwise on your behalf. In such an event, we will not negotiate terms and arrangements for the account with the other broker-dealer, and we will not seek better execution services or prices from other broker-dealers or be able to “batch” the transactions for execution through other broker-dealers with orders for other accounts we manage. As a result, you may pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. XII.(B). Order Batching Transactions for the client’s account generally will be effected independently, unless we decide to purchase or sell the same securities for several clients at the same or approximately the same time. We may (but are not obligated to) combine or “batch” such orders in order to obtain best execution or to negotiate more favorable transaction rates. Reasoning for attempting to effect a batch order is that we may need to trade in the same security for multiple accounts at or around the same time and batching may allow us to achieve a more favorable price on average for all clients. Batching, however, doesn’t guarantee the lowest possible price for execution, however, it is intended to reduce the overall volatility in execution price for a large # of orders that if not batched together, may experience significantly different execution prices. Conversely, in the event that we do not batch a group of orders that otherwise may be a prime candidate for a batched order, the resulting cost for some clients may be higher or lower than what we might be able to achieve by processing a batched order for the benefit of those same clients. On most occasions BIG utilizes block trades to allocate a particular stock purchase or sale over multiple clients accounts. In these instances, proprietary trades are not included, Commission rates are the same for all clients participating in each block trade, and the criteria for including or excluding certain accounts in a block trade is solely based on the needs and objectives of any singular client. Clients are not excluded if the block trade is or can be advantageous to any particular clients. Page 15 of 19  XIII. Review of Accounts XIII.(A). Review of Accounts or Financial Plans Review of client accounts. We will review your accounts on an ongoing basis, but no less frequently than a quarterly basis. The Designated Supervisor (i.e. the person named in our written supervisory procedures as the responsible party for this function) will review your accounts for best execution, suitability, and service. The Designated Supervisor will review the performance and cost basis for your transactions. Your investment objectives are used to review for suitability. Quarterly, transactions are reviewed referencing your investment objectives for any transaction that may not fit your stated objectives, or our understanding of your investment objectives will be flagged and reviewed with the investment adviser representative placing the trade. Name and title of Designated Supervisor: Dale R. Hajost, EVP/CCO. Mr. Hajost will employ the procedures noted above for the client’s accounts subject to BIG’s investment advisory services. Review of Financial Plans. Since we do not offer financial planning, this section is not applicable to us. XIII.(B). Non-Periodic Account Reviews Events that may trigger further client account reviews in addition to the standard quarterly review process may include, but would not be limited to, a notable increase in the volume of requests by the client to effect transactions in his/her accounts, where such transactions may appear to be inconsistent with the client’s previously stated investment objectives. Other factors may include requests by the client to liquidate certain securities positions/contracts where such transactions may appear to be inconsistent with the client’s previously stated investment objectives. Additional triggering factors could be the performance on an individual account being an outlier to the performance of accounts with similar investment objectives, and a very important trigger would be customer complaints. This last trigger would be a prime example of a trigger for an intermittent review of a client account. XIII.(C). Reports to Clients Account statements will be provided no less frequently than quarterly by the custodian, not by us. Account statements will identify account positions, balances, and transaction details. Upon your request, a quarterly account appraisal (written or electronic) may be created for you as well as an annual year-end statement. In the event we also send account statements to you in addition to those provided by the qualified custodian, you are urged to compare any account statements provided by us to those provided by the custodian. XIV. Client Referrals and Other Compensation XIV.(A). Compensation we Receive Other than the compensation arrangements described above in Item IV.(B), BIG does not receive any other compensation in connection with the investment advisory services provided to our clients. XIV.(B). Compensation we Pay Under certain circumstances, firms like ours may compensate other parties for having referred clients or potential investment advisory clients them. These sorts of arrangements are generally referred to as “referral” arrangements. From time to time, we may enter into agreements with various independent parties who may refer prospective investment advisory clients to us. We do not charge clients referred by third-parties fees or costs greater than the fees or costs that we would normally charge any other clients who were not introduced by a referring third-party sources, and have similar portfolios under management with us. Any such agreements will be handled in accordance with the provisions of Rule 206(4)-1 under the Investment Advisers Act Page 16 of 19  of 1940. The specific compensation arrangements vary from situation to situation but can be found in the specific solicitor disclosure document relating to each such solicitor arrangement. For more information on our solicitor arrangements, please call 404-233-9341 . XV. Custody As indicted below, we engage in certain activities that result in us being deemed to have custody of certain of our client’s funds and/or securities. Automatic fee deduction from your brokerage or other trading accounts Physical possession or control (even temporary) of client funds or securities The ability to gain access to any client funds and/or securities One of our related persons has custody of funds and/or securities subject to our investment advisory services We or one of our related persons serves as the general partner, managing member, or other similar type of control person • • • • • to an investment fund to which we provide investment advisory services. As stated previously in Item XIII.(C)., your account statements will be provided by the qualified custodian that maintains physical possession of your accounts/assets. In the event that we also provide you information related to your accounts, you are urged to review that information to the information contained on the account statements or other statements received from the qualified custodian. XVI. Investment Discretion In connection with our investment advisory services, we will generally seek and obtain your authorization to carry out part of our services on a purely discretionary basis. We will memorialize your authorization of our discretionary authority in our investment advisory agreement. If you have authorized us to do so, we will exercise discretion over the following areas. 1) The specific securities to be bought or sold on the client’s behalf 2) The amount of securities to be bought or sold on the client’s behalf 3) Timing as to when such securities are to be bought or sold 4) The particular broker or dealer to be used for arranging client securities transactions We will have authority to exercise complete discretion with regard to the above named factors without restriction. If done so on a non-discretionary basis, we will make certain recommendations that must be authorized by you prior to our facilitation of any such transactions. As may be separately agreed to in writing, we will observe any other specific limitations that may be imposed by you in relation to this discretionary authority. XVII. Voting Client Securities XVII.(A). Proxy Voting Proxy Voting Policies and Procedures and Client Instruction We do not vote proxies on behalf of any securities you own. In the event that you have authorized (via the Agreement) us to vote proxies on your behalf, we will perform the voting process for you subject to the following information and procedures. Alternatively, if you provide us with other, specific instructions as to how we are to carry out the proxy voting process on your behalf, we will do so. Such instructions must be written and included in or as part of our Agreement. In an effort to assure that clients’ proxy votes are carried out in our clients’ best interests and not affected by any conflicts of interest that may exist, we have adopted the following elements as part of our proxy voting policy. Regardless of the nature of the issue up for vote, we thoroughly and objectively research the voting options and the corporate landscape in order to arrive at a decision that we believe meets the best interests of the client as a shareholder of the company in question. The overriding theme of our policy is to vote client proxies in the manner that we believe is most consistent with the following: Page 17 of 19  • The client’s stated investment objectives • The client’s desired voting interests • The long-term well-being of the company soliciting the proxy • An increase in shareholder value Conflicts of Interest… We recognize that conflicts of interest may arise when voting your proxies. A conflict of interest exists when your best interests are contrary to our best interests due to some relationship between the us and/or our associated persons and a company that is soliciting a proxy. Some examples may include: • The spouse of one of our associated persons is a board member of a company whose management is soliciting proxies to vote on a salary increase for the board. • We are an affiliated company of a company that has issued a proxy notice to individuals who are our clients. • We or one or more of our affiliates may manage a pension plan, administer employee benefit plans, or provide brokerage, underwriting, insurance, or banking services to a company whose management is soliciting proxies. It is our policy to vote proxies in the best interests of its clients regardless of the existence of any conflict of interest. As authorized in our Agreement, we may exercise complete discretionary voting authority in relation to proxy notices that we receive on your behalf. If no apparent conflict of interest exists in relation to our exercise of our voting authority on your behalf, we shall vote all such proxies as we see fit and in your best interest. Under certain circumstances, the most prudent action on our part may be NOT to vote a proxy(s). Under such circumstances, we shall ensure that appropriate records are maintained so as to justify not having voted such proxy(s). How to obtain our proxy voting record… We will ensure that a complete record is retained of the initial proxy notice and the subsequent vote that we cast on your behalf. For a copy of our proxy voting record on your behalf, please write or call us at: Builder Investment Group, Inc. 4401 Northside Pkwy, NW Suite 520 Atlanta, GA 30327Tel: 404-233-9341 dhajost@big-inc.com XVII.(B). Proxy Voting If you have authorized us to vote proxies on your behalf, we will do so in accordance with the information provided above in XVII.(A). Proxies related to the securities you own will be disseminated as dictated by the issuer, transfer agent, or as otherwise set forth in the account opening paperwork you completed for the custodian holding your account/assets. If you have questions related to a particular proxy notice, please call us at 404-233-9341. XVIII. Financial Information XVIII.(A). Balance Sheet We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. As a result, we are not required to provide our clients with a copy of our balance sheet from our most recently completed fiscal year. XVIII.(B). Adverse Financial condition In the event that we have discretionary authority or custody of any of our clients’ assets or if we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we are required to disclose any financial condition that is reasonably likely to impair our ability to meet contractual commitments with our clients. No such conditions exist. Page 18 of 19  XVIII.(C). Bankruptcy-Related Matters During the past ten years, BIG has not been the subject of a bankruptcy petition. XIX. Requirements for State-Registered Advisers As a federally-registered investment adviser, this section of our Brochure is not applicable to us. Page 19 of 19