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FORM ADV PARTS 2A AND 2B
JUNE 30, 2025
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Form ADV Part 2A
Crossmark Global Investments, Inc.
June 30, 2025
This Brochure provides information about the qualifications and business practices of Crossmark Global Investments, Inc. (Crossmark).
If you have any questions about the contents of this Brochure, please contact us at 713-260-9000 or by email to
info@crossmarkglobal.com. 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.
Crossmark is registered with the Securities and Exchange Commission which oversees its investment management activities.
Registration with the Securities and Exchange Commission does not imply a certain level of skill or trading. Our oral and written
communications are intended to provide you with information which you may use to determine to hire or retain us to provide
investment advice.
Additional information about Crossmark is also available on the SEC’s Website at www.adviserinfo.sec.gov.
15375 Memorial Drive
Suite 200
Houston, TX 77079
(713) 260-9000 Phone
(800) 262-6631 Toll Free
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 2 Material Changes
The date of our last Brochure was June 30, 2024. While we have made no material changes in the products and services that we offer, our
investment advice and management processes, or the way that we manage our business, this Brochure contains additional
disclosures regarding our investment processes, investment risks, and how we manage conflicts of interest. Should you have any
questions about these changes or view them as material to your investment decision-making, please contact us.
Pursuant to SEC Rules, we will provide you with:
• An updated annual brochure that includes a summary of any material changes to the brochure during the course of the previous
business year within 120 days of the close of our business fiscal year;
• A summary of material changes within 120 days of the close of our business fiscal year that includes an offer to provide a copy of
the full annual updated brochure and information on how you may obtain the brochure from us;
• An interim amendment to the brochure if new information in response to Item 9 of Part 2A regarding disciplinary information is
available; and
• An interim amendment resulting from any material change that could affect the relationship between you and us.
We will provide, free of charge, a new brochure any time at your request, or as may become necessary based on material changes.
Currently, our Brochure may be requested by contacting our office at 1-800-262-6631. You may also receive this and any other
disclosure documents via electronic delivery.
Additional information about Crossmark is also available via the SEC’s website at www.adviserinfo@sec.gov. The SEC’s website also
provides information about any persons affiliated with Crossmark who are registered or are required to be registered, as investment
adviser representatives of Crossmark.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 3
Table of Contents
Item No
Description
Page
Item 1
Cover Page
1
Item 2
Material Changes
3
Item 3
Table of Contents
4
Item 4
Advisory Business
5
Item 5
Fees and Compensation
6
Item 6
Performance-Based Fees and Side-by-Side Management
9
9Item 7
Types of Clients
9
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
9
Item 9
Disciplinary Information
17
Item 10
Other Financial Industry Activities and Affiliations
17
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
18
Item 12
Brokerage Practices
20
Item 13
Review of Accounts
24
Item 14
Client Referrals and Other Compensation
24
Item 15
Custody
24
Item 16
Investment Discretion
24
Item 17
Voting Client Securities
25
Item 18
Financial Information
26
Privacy Policy Notice
27
Form ADV Part 2B Supplemental Brochures
28
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 4 Advisory Business
Crossmark is a faith-based boutique investment management firm that provides a full suite of investment strategies to institutional
investors, financial advisors, and the clients they serve.
Crossmark is a privately owned SEC-registered investment adviser established in 1987, and headquartered in Houston, Texas. We
primarily offer our services through managed account platforms maintained by unaffiliated financial intermediaries,
including wrap fee programs. Some of these relationships involve dual contract arrangements whereby both Crossmark and the
client’s primary adviser have an advisory agreement with the client. We also provide investment advisory services directly
to clients through separately managed accounts. And, we serve as the investment adviser to the series portfolios of the Crossmark
ETF Trust (the Crossmark ETFs) and Steward Funds, Inc. (the Steward Funds), each a registered investment company under the
Investment Company Act of 1940 (the Investment Company Act), available to both individual and institutional investors.
Crossmark is wholly owned by Crossmark Global Holdings, Inc. (Crossmark Global Holdings), which is also a privately owned
company. Crossmark Global Holdings is a wholly owned indirect subsidiary of AGFinancial, a Missouri non-profit
corporation.
Crossmark manages the assets of each Crossmark ETF and Steward Fund based on the investment goals and objectives outlined
in the applicable fund’s prospectus. Before investing in a mutual fund, you should refer to the fund’s prospectus and Statement of
Additional Information (SAI) for important information regarding the Fund’s investment objective, risks, charges, expenses, and
additional disclosures regarding the management of the fund. For the Crossmark ETFs, these documents are available on-line at
crossmarkglobaletf.com. For the Steward Funds, these documents are available on-line at crossmarkglobal.com/stewardfunds.
Crossmark tailors its advisory services for each fund to the fund’s overall investment program, not to the needs of any individual
investor.
With respect to individual and institutional clients, Crossmark provides model-driven investment advice and discretionary
investment management services. With limited exceptions, our services are not tailored to your individual needs. We rely on your
financial intermediary to review your goals and objectives in developing an investment program tailored to meet those
investment needs and objectives. Institutional clients may develop their own investment programs tailored to meet their
investment needs and objectives. The investment strategies that we offer may be selected by you or your financial intermediary to
achieve certain objectives included in your overall investment program. As the client, you may impose reasonable restrictions on
our ability to invest in certain securities, types of securities, or industry sectors. Clients who impose investment restrictions
should be aware that the performance of their accounts may differ from that of the investment strategies not subject to
investment restrictions. Crossmark manages its wrap program accounts in substantially the same manner as its other clients
employing the same investment strategy.
Crossmark provides asset allocation, investment advice, and discretionary investment management services that cover equity
securities, options on equity securities, corporate debt instruments, government and agency securities, municipal securities, exchange
traded funds (ETFs), and mutual funds, including the Crossmark ETFs and the Steward Funds. The specific investment style chosen for
each client should be based on the goals, objectives, and individual needs of the client. Crossmark has recommended, and may
in the future recommend, that its clients invest in the Crossmark ETFs and the Steward Funds. Any client may, outside of any
relationship with Crossmark, make direct investments in the Crossmark ETFs and/or the Steward Funds.
As of March 31, 2025, Crossmark had approximately $7.048 billion of discretionary assets under management, and $359 million of
assets we advise on a non-discretionary basis.
As used in this Brochure, the words firm, we, our, and us refer to Crossmark; and the words you, your, and client refer to you as either
a client or prospective client of Crossmark.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 5
Fees and Compensation
Advisory Fees in General
The fees that we charge for the services provided to you vary depending on several factors, which include:
•
The type and level of service we provide to you
•
The asset class in which you are invested
•
The size of your account
•
The complexity of your investment program
Our advisory fees are negotiable and will vary from relationship-to-relationship, but typically take the form of an annual percentage
of the value of the client assets managed by us. Fees may be as low as 0.05% (5 bps) for employee accounts up to 1.00% (100
bps) for an actively managed long/short strategy.
The manner in which our advisory fee is calculated and charged varies from relationship-to-relationship but is generally calculated
quarterly in advance, based upon the amount of asset under management at the end of preceding quarter, but may be charged in an
alternative manner in accordance with the applicable client agreement. Depending on the type of relationship we have with you,
we may request that you authorize and direct the custodian of your account to pay our fees directly to us from the assets in your
account. However, it is your option to authorize this process, and if you do not approve of the direct deduction from your account,
we will submit periodic invoices directly to you or the custodian as you request.
In the event your agreement with Crossmark is terminated for any reason by either of us, our fee is pro-rated for the portion of
a period that the portfolio is being managed by us. This pro-rated period will include any termination notice required to be given
under your investment advisory agreement. You may either pay these fees directly to Crossmark or authorize deduction of the
fees from the account. There is no penalty for terminating an agreement.
You will pay fees whether you make or lose money on your investments. Fees will reduce any amount of money you make on
your investment over time. Please make sure you understand the fees and costs you are paying. You should note that similar
advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower
fees.
Our employees and their family members, as well as persons affiliated with indirect owners of Crossmark, may be charged a
lower fee for us to manage their accounts.
Crossmark ETFs
Crossmark receives a management fee in connection with the Crossmark ETFs. The fees paid by the Crossmark ETFs to
Crossmark in respect of the management of the funds is 0.50% (50 bps). This is a unitary fee, with Crossmark paying all fund
operating expenses out of the fee. Additional information on the fees and expenses of the Crossmark ETFs is set forth in the
applicable prospectus and offering materials for each fund.
Steward Funds
Crossmark receives a management fee in connection with the Steward Funds. The fees paid by the Steward Funds to Crossmark
and its affiliates in respect of the management of the Funds range from 0.29% (29 bps) to 1.075% (107.5 bps) of client assets
under management. Additional information on the fees and expenses of the Steward Funds is set forth in the applicable
prospectus and offering materials for each Steward Fund.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Wrap Fee Programs
Crossmark provides investment advisory services to clients of national and regional financial intermediaries, such as banks,
broker-dealers and investment advisers, through programs commonly called wrap fee programs, in which the client has executed
an all-inclusive investment services agreement with the financial intermediary (the wrap sponsor) for a single all-inclusive fee based
on a percentage of the client’s assets (a wrap fee). The wrap fee typically covers fees to the investment adviser and execution by the
sponsor of all portfolio transactions within the account. In addition, the wrap sponsor typically provides some or all of the
following services:
•
recommends selection of the investment adviser;
• pays the advisory fee from the client account;
• monitors and evaluates the performance of the investment adviser; and
• provides custodial services for the account’s assets.
The all-inclusive wrap fee charged by the wrap sponsor is set forth in the applicable accounting opening agreements for your account.
The annual advisory fees paid by wrap sponsors to Crossmark under these programs generally range from 0.20% (20 bps) to 0.55%
(55 bps) of client assets under management. Wrap sponsors are responsible for delivering the relevant disclosure information to
their clients electing to be in the wrap program.
Dual Contract Managed Accounts
Crossmark also provides investment advisory services to clients of broker-dealers in which the client enters into an investment advisory
agreement directly with Crossmark for management of the client’s portfolio, and the client enters into a separate agreement with the
broker-dealer for provision of brokerage, custodial, portfolio monitoring and evaluation services. In these programs the client pays
the broker-dealer a fee for its services and separately pays an annual advisory fee to Crossmark, which ranges from 0.25% (25 bps) to
1.00% (100 bps) of client assets under management.
Separately Managed Accounts
Crossmark also provides investment advisory services to clients under which the client enters into an investment advisory agreement
directly with Crossmark for management of the client's portfolio. Crossmark receives advisory fees based upon a percentage of the
assets under management, generally calculated and payable quarterly in advance. Fees are based on account asset values on the last
business day of the previous quarter, although some accounts may be charged quarterly in arrears. We usually require a minimum
account size and we at times require a minimum annual fee to open an account with us.
The fee that you are being charged by us for the investment management of your assets is exclusive of, and in addition to, brokerage
commissions, transaction fees, custodial fees, and any other related costs and expenses. We do not receive any portion of these
commissions, fees, other costs and expenses. Fees may be negotiable on a client-by-client basis depending on a number of factors,
including the type and nature of services to be provided, the amount of assets to be managed, and/or anticipated future additional
assets. The specific annual fee schedule for fees charged by us is identified in the contract between you and us.
The annual advisory fee paid to Crossmark varies based on the factors discussed above and ranges from 0.20% (20 bps) to 1.00% (100
bps) of client assets under management.
For institutional clients with accounts exceeding $1 million in regulatory assets under management, the annual advisory fee paid to
Crossmark varies based on the factors discussed above and ranges from 0.075% (7.5 bps) to 0.20% (20 bps), with a minimum quarterly
fee of $2,500.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Mutual Fund and ETF Fees
A portion of your account assets that we manage may be invested in mutual funds and/or ETFs, including the Crossmark ETFs and
Steward Funds. The Steward Funds incur certain expenses that are borne by their shareholders; these expenses include fees for
investment advice, portfolio administration, shareholder servicing, and in the case of funds that have adopted distribution plans under
SEC Rule 12b-1, distribution and marketing. Details regarding these fees can be found in each fund’s prospectus and statement of
additional information. With respect to the Steward Funds, some of these fees are paid to Crossmark and its affiliates. The Crossmark
ETFs utilize a unitary management fee, with Crossmark paying all fund operating expenses out of the fee.
Advisory clients invested in the Crossmark ETFs or the Steward Funds are generally subject to the management fee charged by the
applicable fund in addition to Crossmark’s advisory fee. No mutual fund fees are credited against the advisory fee being charged by
Crossmark to manage your account, but the overall level of fees being incurred by you is considered in the selection of appropriate
investments for your account.
Fees Charged by Brokers, Dealers, Banks, and Custodians
Crossmark does not charge transaction fees, custody fees, or account maintenance fees. Please note, however, that any asset
custodians, banks, brokers, or dealers who maintain your account(s), provide custody services with respect to your assets, or execute
securities trades or asset transfers on your behalf usually charge such fees, whether they are recommended or chosen by us or by you
independent of your relationship with Crossmark. Examples of such fees include, but are not limited to, administration expenses,
brokerage commissions, transaction fees, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Non-Standard Accounts
There are accounts managed by Crossmark that were opened prior to the adoption of these fee rates that may have fee rates higher
or lower than the ranges outlined above. There may also be accounts opened in the future with fee rates higher or lower than
these ranges, with variations based on factors outlined above.
Compensation of Supervised Persons
Some of our supervised persons receive direct compensation for the sale of securities or other investment products. As noted above,
however, we do not generally maintain direct client relationships, but rather offer our services through independent financial
intermediaries who determine the needs of their clients and make specific recommendations as to the securities and other investment
products available in the marketplace to meet those needs.
Certain of our supervised persons do receive compensation based on sales of Crossmark ETF shares, Steward Fund shares, and
Crossmark investment advisory services by financial intermediaries within their assigned territories. These supervised persons act in
the role of wholesalers, providing product and service information to financial intermediaries, not involving themselves in the
discussions between such intermediaries and their clients regarding specific investment recommendations.
Our portfolio managers receive compensation that is based, in part, on the value of the assets they manage. While this compensation
is affected by factors other than sales (investment performance, market movements, and redemptions), it does create an incentive to
increase sales.
All compensation that is tied to sales creates a conflict of interest that gives the supervised person an incentive to recommend
investment products based on the compensation received, rather than on a client’s needs. As noted above, our clients (including most
of our institutional clients) generally have independent financial intermediaries who determine their needs and make specific
recommendations as to the securities and other investment products available in the marketplace to meet those needs.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 6 Performance-Based Fees and Side-by-Side Management
Performance-Based Fees
Crossmark does not provide any services for performance-based fees. Performance-based fees are fees based on a share of capital
gains on capital appreciation of the assets of a client.
Side-by-Side Management
Crossmark simultaneously manages the portfolios of multiple clients according to the same or similar investment strategy (i.e., side-
by-side management). The simultaneous management of these different investment portfolios creates certain conflicts of interest, as
the fees for the management of certain types of accounts are higher than others. Nevertheless, when managing the assets of such
accounts, Crossmark seeks to treat all such accounts fairly and equitably over time.
Although Crossmark seeks to treat all portfolios within an investment strategy fairly and equitably over time, such portfolios will not
necessarily be always managed the same. Specifically, there is no requirement that Crossmark use the same investment practices
consistently across all portfolios. Crossmark will not necessarily purchase or sell the same securities at the same time or in the same
proportionate amounts for all eligible portfolios, and one account’s performance will not necessarily be reflective of the performance
of another account managed using a similar strategy, due to a variety of factors including the nature of the services provided by
Crossmark, the structure of the accounts, differences in cash flows and the timing of trading. As a result, although Crossmark manages
multiple portfolios with similar or the same investment objectives, or may manage accounts with different objectives that trade in the
same securities, the portfolio decisions relating to these accounts, and the performance resulting from such decisions, may differ from
portfolio to portfolio.
Item 7 Types of Clients
Crossmark provides investment management services to individuals, institutions, and registered investment companies under the
Investment Company Act. Institutional clients may include, but are not limited to, corporations, trusts, endowments, religious
organizations, other not-for-profit enterprises, employee benefit plans, and governmental entities.
We have minimum account sizes that vary based on:
•
The type and level of service we provide to you
•
The asset class in which you are invested
•
The complexity of your investment program
We may not agree to manage an account if the assets invested are insufficient to implement the investment program desired by the
client. Minimum account requirements will differ among clients.
Details of minimum investment requirements for the Steward Funds can be found in the prospectus of the applicable Steward Fund.
The Crossmark ETFs are exchange-traded funds with no minimum investment requirements.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Quantitative Analysis seeks to understand behavior by using complex mathematical and statistical modeling,
measurement, and research. When a securities analyst focuses on a corporation's financial data in order to project potential
future performance, the process is called quantitative analysis. This methodology involves looking at profit-and-loss
statements, sales and earnings histories, and the statistical state of the economy rather than at more subjective factors such as
management experience, employee attitudes, and brand recognition. The primary risk in using quantitative analysis is that while
the overall health and position of a company may be good, market conditions may negatively impact the security.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Fundamental Analysis involves an assessment of the fundamental financial condition and competitive position of a company.
This approach generally involves an analysis of the financial condition, capabilities of management, earnings, new products
and services, as well as the company’s markets and position versus its competitors in order to determine the recommendations
made to clients. The primary risk in using fundamental analysis is that while the overall health and position of a company may
be good, market conditions may negatively impact the security.
Technical Analysis involves the examination of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of various quantitative-based calculations,
variation metrics and charts to identify market patterns and trends which may be based on investor sentiment rather than
the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to
predict such trends in the future.
Cyclical Analysis is similar to technical analysis in that it involves the assessment of market conditions at a macro (entire
market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the health of the
particular company that Crossmark is recommending. The risks with cyclical analysis are similar to those of technical
analysis.
Positive Value Investing. Through multi-factor quantitative models and fundamental analysis, Crossmark may consider, among
other factors, a company’s valuation, financial strength, growth potential, competitive position in its industry, projected future
earnings, cash flows and dividends when deciding whether to buy or sell investments. With respect to the rankings provided by
the multi-factor quantitative models, the models also include components for identifying companies that, through their activities,
both externally and internally, seek to reduce risk and create long-term resilience through sustainable and responsible business
practices. Crossmark believes that such companies exhibit positive values, including, but not limited to, the fair treatment of
employees, respect for the environment, positive engagement with the communities in which they operate, and responsible
governance practices. This component of the multi-factor quantitative models is based on data and ratings generated by multiple
third-party providers unaffiliated with Crossmark.
Socially Conscious Investing Screens are applied to certain strategies and can be applied to any individual client’s portfolio at the
client’s option. Depending on the investment strategy or client-specific restrictions, a client’s account can undergo exclusionary
screening according to values-based characteristics. These criteria are nonfinancial reasons to exclude a security, and therefore,
the client’s account or strategy may forgo some market opportunities available to portfolios that don’t use such screening. The
values-based characteristics are evaluated entirely by third-party providers unaffiliated with Crossmark.
Crossmark uses its best efforts to avoid investments in companies that do not pass the screening criteria. Crossmark will divest
any securities of companies held in a portfolio that are later determined not to pass the values-based screening criteria, although
the sale may be delayed if such securities are illiquid or if Crossmark determines that an immediate sale would have a negative
tax or other effect on the client.
Crossmark offers both screened and unscreened investment strategies. Crossmark also works with clients who have their own
screening processes and investment restrictions.
Asset Allocation
The implementation of an investment strategy that attempts to balance risk versus reward by adjusting the percentage of each
asset in an investment portfolio. Asset allocation is based on the principle that different assets perform differently in different
market and economic conditions. A fundamental justification for asset allocation is the notion that different asset classes offer
returns that are not perfectly correlated, hence diversification reduces the overall risk in terms of the variability of returns for
a given level of expected return. Although risk is reduced as long as correlations are not perfect, it is typically forecast (wholly
or in part) based on statistical relationships (like correlation and variance) that existed over some past period. Expectations for
return are often derived in the same way.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
An asset class is a group of economic resources sharing similar characteristics, such as riskiness and return. There are many
types of assets that may or may not be included in an asset allocation strategy. The "traditional" asset classes are stocks (value,
dividend, growth, or sector-specific [or a "blend" of any two or more of the preceding]; large-cap versus mid-cap, small- cap or
micro-cap; domestic, foreign [developed], emerging or frontier markets), bonds (fixed income securities more generally:
investment-grade or junk [high-yield]; government or corporate; short-term, intermediate, long-term; domestic, foreign,
emerging markets), and cash or cash equivalents. Allocation among these three provides a starting point. Usually included are
hybrid instruments such as convertible bonds and preferred stocks, counting as a mixture of bonds and stocks.
Investment Strategies
As noted above, we primarily offer our services through managed account platforms maintained by unaffiliated financial
intermediaries. We offer the following strategies for use in managing client accounts:
Equity Strategies
Covered Call Income
The Crossmark Covered Call Income strategy seeks to generate option premium income, with the potential for capital appreciation
and less volatility than the broad equity market. Crossmark uses a combined quantitative/fundamental approach to identify large-cap
domestic stocks selling at a low range of valuation measurements which also exhibit positive price momentum. The strategy then
supplements the overall portfolio’s dividend yield by implementing a covered call option overlay. Crossmark may select non-dividend
paying stocks for the portfolio when listed options on those stocks exhibit potential to generate option premium income.Crossmark
also manages single-stock portfolios for clients who desire to generate option premium income on their concentrated positions. Such
portfolios are reviewed on a case-by-case basis to determine whether the potential to generate option premium income is consistent
with the client’s stated objectives.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, option writing
risk, and positive value investing risk, each discussed below.
Global Equity Income
The Crossmark Global Equity Income strategy seeks to provide high dividend income with long-term capital appreciation. The strategy
invests in U.S. and non-U.S. dividend-paying stocks that have demonstrated a higher yield within their respective sectors,
increasing dividends and favorable earnings growth. We invest in the common stocks of companies that represent a broad spectrum
of the global economy. Although the strategy invests primarily in large cap stocks, it is also able to invest in mid-cap and small-cap
stocks. The non-U.S. investments are primarily in the form of depositary receipts which are U.S. dollar denominated instruments
representing securities of non-U.S. issuers that are traded in the U.S. and in non-U.S. markets.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, foreign
securities risk, socially conscious investing risk, and positive value investing risk, each discussed below.
Equity Market Neutral
The Crossmark Equity Market Neutral strategy seeks long-term capital appreciation and to provide absolute returns
independent of equity market direction. The goal is to find long positions that outperform a targeted benchmark and shorts that
underperform a targeted benchmark in up, down and sideways markets. The strategy’s investment process employs a combination
of fundamental and quantitative factors, values-based criteria, and prudent portfolio constraints and risk management tools. Factors
utilized in the traditional multi-factor model include earnings quality, profitability, growth dynamics, valuation and capital
deployment. The strategy is subject to Crossmark’s values-based screening methodology and utilizes values-based data from 3rd
party providers as well as our in-house research team as it relates to the long holdings. Derivatives are not utilized in this strategy
which incorporates active risk management with a target beta range of -0.2 to +0.4 versus a widely recognized large and mega-
cap equity index. Inputs including economic indicators, monetary variables, valuation, momentum and sentiment are utilized as
part of a quantitative tool to provide insights for determining the beta position with a central tendency of +0.1. The risk
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
management process involves set parameters around issuers, sectors, industries and risk factors as compared to the referenced
index. The number of holdings in this strategy averages approximately 100 long and 100 short with full holdings transparency
and daily liquidity.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, short selling
risk, socially conscious investing risk, and positive value investing risk, each discussed below.
Large Cap Core
The Crossmark Large Cap Core strategy seeks to outperform the investment benchmark (the Russell 1000 Index) over a market cycle.
The strategy’s investment process employs a combination of fundamental and quantitative factors, values-based criteria, and prudent
portfolio constraints and risk management tools with the goal of long-term capital appreciation. Factors utilized in the traditional
multi-factor model include earnings quality, profitability, growth dynamics, valuation and capital deployment. The strategy is subject
to Crossmark’s values-based screening methodology and utilizes values- based data from third party providers as well as our in-house
research team. The risk management process involves set parameters around issuers, sectors, industries and risk factors as compared
to a widely recognized large and mega-cap equity index. The number of holdings in this strategy averages 45-60, investing with an
emphasis on large and mega- cap companies.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, socially
conscious investing risk, and positive value investing risk, each discussed below.
Large Cap Core Unscreened
The Crossmark Large Cap Core Unscreened strategy seeks to outperform the investment benchmark (the Russell 1000 Index) over a
market cycle. The strategy’s investment process employs a combination of fundamental and quantitative factors, prudent portfolio
constraints, and risk management tools with the goal of long-term capital appreciation. Factors utilized in the traditional multi-factor
model include earnings quality, profitability, growth dynamics, valuation and capital deployment. The risk management process
involves set parameters around issuers, sectors, industries and risk factors as compared to a widely recognized large and mega-cap
equity index. The average number of holdings is between 45-60 for this strategy.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, and company risk, each
discussed below.
Large Cap Growth
The Crossmark Large Cap Growth strategy seeks to outperform the investment benchmark (the Russell 1000 Growth Index) over a
market cycle. The strategy’s investment process employs a combination of fundamental and quantitative factors, values-based
criteria, and prudent portfolio constraints and risk management tools with the goal of long-term capital appreciation. Factors utilized
in the traditional multi-factor model include earnings quality, profitability, growth dynamics, valuation and capital deployment. The
strategy is subject to Crossmark’s values-based screening methodology and utilizes values- based data from third party providers as
well as our in-house research team. The risk management process involves set parameters around issuers, sectors, industries and risk
factors as compared to a widely recognized large and mega-cap growth-oriented equity index. The number of holdings in this strategy
averages 45-60, investing with an emphasis on large and mega-cap companies.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, socially
conscious investing risk, and positive value investing risk, each discussed below.
Large Cap Value
The Crossmark Large Cap Value strategy seeks to outperform the investment benchmark (the Russell 1000 Value Index) over a market
cycle. The strategy’s investment process employs a combination of fundamental and quantitative factors, values-based criteria, and
prudent portfolio constraints and risk management tools with the goal of long-term capital appreciation. Factors utilized in the
traditional multi-factor model include earnings quality, profitability, growth dynamics, valuation and capital deployment. The strategy
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is subject to Crossmark’s values-based screening methodology and utilizes values- based data from third party providers as well as our
in-house research team. The risk management process involves set parameters around issuers, sectors, industries and risk factors as
compared to a widely recognized large and mega-cap value-oriented equity index. The number of holdings in this strategy averages
45-60, investing with an emphasis on large and mega-cap companies.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, company risk, socially
conscious investing risk, and positive value investing risk, each discussed below.
Stand With Israel
The Crossmark Stand With Israel investment strategy invests in U.S. large-cap companies with ties to the Israeli economy, educational
system, and/or Israeli companies. Types of engagement may include direct investment, mergers & acquisitions, local partnerships,
and employment. The Strategy utilizes both quantitative and qualitative components in the portfolio construction process. We run
the stocks in the investible universe through a fundamental multi-factor risk model and optimization tool with the objective of
minimizing the active risk of the portfolio relative to the benchmark index. The end goal is to create an optimized portfolio of U.S.
large-cap stocks with ties to the Israeli economy that attempts to minimize tracking error to the benchmark index (i.e., the difference
in actual performance between the portfolio and its corresponding benchmark).
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, and company risk, each
discussed below.
Fixed Income Strategies
Core Fixed Income
The Crossmark Core Fixed Income Strategy seeks to outperform the bond market over a market cycle while providing diversification,
the ability to match liabilities and assets, and a steady income stream to the investor. The Strategy focuses on high quality,
intermediate-maturity securities, active duration management, selective sector rotation, and selective security rotation. The sectors
invested in for this strategy include U.S. investment-grade corporate issues, U.S. Government agency notes, and U.S. Treasury notes
and bonds. The strategy utilizes a four-step investment process consisting of duration selection, yield curve selection, sector selection
and security selection.
The principal risks associated with this strategy are credit risk, interest rate risk, and liquidity risk.
Current Income Portfolio
The Crossmark Current Income Portfolio is a separately managed account strategy designed for investors who seek above-average
income flows within an investment grade, intermediate-maturity strategy. The strategy focuses on investment-grade corporate bonds
and U.S. Government agency securities with a maximum maturity of ten years. In addition, an allocation to fixed-rate preferred stocks
is utilized for income generation purposes while maintaining an overall intermediate-term duration for the strategy. The strategy
utilizes a four-step investment process consisting of duration selection, yield curve selection, sector selection and security selection.
The principal risks associated with this strategy are credit risk, interest rate risk, and liquidity risk.
Intermediate Fixed Income
The Crossmark Intermediate Fixed Income Strategy invests in investment-grade corporate, U.S. Government agency, and U.S. Treasury
issues with a focus on generating consistent cash flow without excessive credit risk. The Strategy is an actively managed solution
consisting of short-to-medium term bonds with maturities up to a maximum of ten years. In addition to managing credit risk, interest
rate risk is addressed by active duration management with the ability to rotate into and out of individual bond issues within the three
sectors noted. The strategy utilizes a four-step investment process consisting of duration selection, yield curve selection, sector
selection and security selection.
The principal risks associated with this strategy are credit risk, interest rate risk, and liquidity risk.
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Municipal Fixed Income
The Crossmark Municipal Fixed Income Strategy invests primarily in investment-grade municipal debt issues. It is a conservative,
actively-managed solution focusing on municipal bonds analyzed to be most likely to fulfill the strategy objective. Generally, the
portfolio will consist of 15 to 30 individual issues. By actively managing exposure to various states and sectors, the Strategy aims to
maximize the generation of tax-free income. The issues are limited to those of A rated or better at time of purchase, substantially
reducing the risk of default. Individual issues are selected from general obligation and essential service sectors such as water, sewer,
utilities, transportation, highways, and education. Current exclusions include hospitals, assisted living, retirement centers, hotel,
healthcare, housing, jail or student dormitory-related, and U.S. territories (or states at the discretion of the portfolio manager).
The Strategy focuses on short- to intermediate-term fixed rate callable issues. Municipal bonds are limited to those with a credit rating
of single-A or better as measured by Moody’s, S&P or Fitch at the time of purchase. Investors can choose from three different
strategies to best accomplish their tax-free income goals.
The principal risks associated with this strategy are credit risk, interest rate risk, and liquidity risk.
Blended and Custom Strategies
Balanced Core
The Crossmark Balanced Core Strategy seeks to provide a balance of long-term growth and current income by investing in a
combination of equity and fixed income securities. The Strategy seeks to take advantage of the opportunities presented by each - the
potential for capital appreciation from the equity component and current income/lower volatility from the fixed income component.
The Balanced Core strategy targets a mix of 50% equities and 50% fixed income securities. It employs a rebalancing feature to ensure
the allocation stays on track throughout a full market cycle. This unique rebalancing process is triggered by market movements, not
by a preset schedule or calendar. This allows for up to 10% appreciation in either component before the rebalance is triggered,
providing an opportunity for the portfolio to capture gains. Once the equity or fixed income component reaches 60% of total asset
value, the portfolio is rebalanced to 50%/50%. Each component is managed by the investment team of the underlying strategies – the
Large Cap Core Unscreened strategy and the Core Fixed Income strategy.
The principal risks associated with this strategy are general market risk, equity market risk, selection risk, credit risk, interest rate risk,
and liquidity risk.
Custom Asset Allocation
Crossmark’s custom asset allocation process provides the client the ability to create a custom asset allocation portfolio using stocks,
bonds, mutual funds and ETFs to meet their specific income and growth objectives.
The principal risks associated with this strategy depend on the benchmark(s) and any social screens chosen by the client. These are
individual, custom tailored portfolios.
Custom Equity Indexation
The Crossmark Custom Equity Solutions Screened strategy seeks to provide investors with a separately managed portfolio of stocks
designed to closely track the total return of a benchmark index while applying client-specified constraints.
The principal risks associated with this strategy depend on the benchmark and any screens chosen by the client. These are individual,
custom tailored portfolios.
Risks Associated with All Investment Strategies
The analysis of securities investments requires subjective assessments and decision-making by experienced investment professionals.
However, there is a risk of an error in judgment. An investment in securities is subject to investment risks including interest rate risk,
market risk, inflation risk, currency risk, liquidity risk, business risk, financial risk, and the possibility of the loss of some, or all, of the
principal amount invested. There can be no assurance that Crossmark will be successful in meeting the client’s investment objective.
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Crossmark’s ability to choose suitable securities has a significant impact on the ability of Crossmark to achieve any selected investment
objective.
Portfolio managers may consider, among other factors, a company’s valuation, financial strength, growth potential, competitive
position in its industry, projected future earnings, cash flows and dividends when deciding whether to buy or sell investments. With
respect to the rankings provided by the multi-factor quantitative models, the models also include a component for ranking companies
according to values-based characteristics to identify companies that (through their activities, both externally and internally) exhibit
support for widely-held traditional values, create long-term resiliency, and reduce risk. Such values-based characteristics may include,
but are not limited to, the fair treatment of employees, respect for the environment, positive engagement with the communities in
which they operate, and responsible governance practices. The values-based characteristics are evaluated entirely by third-party
providers unaffiliated with Crossmark. Crossmark uses ratings from multiple providers to develop the multi-factor quantitative models.
To the extent two or more securities eligible for inclusion in a portfolio have similar risk-reward characteristics, portfolio managers will
typically favor the securities that have better values-based characteristics.
Risks Associated with All Forms of Analysis
Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies
that review these securities, and other publicly available sources of information about these securities are providing accurate and
unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be
compromised by inaccurate or misleading information.
Principal Risks Associated with Equity and Fixed Income Investing
Market Risk – Either the market as a whole, or the value of an individual company, goes down, resulting in a decrease in the value of
client investments. Global markets are interconnected, and events like hurricanes, floods, earthquakes, forest fires and similar natural
disturbances, war, terrorism or threats of terrorism, civil disorder, public health crises, and similar “Act of God” events have led, and
may in the future lead, to increased short-term market volatility and may have adverse long-term and wide-spread effects on world
economies and markets generally. Clients may have exposure to countries and markets impacted by such events, which could result
in material losses.
Equity Securities – Equity investments generally involve certain principal risks including:
• Equity Market Risk – The value of equity securities will rise and fall in response to general market and/or economic
conditions.
• Selection Risk – The value of any individual equity security will rise and fall in response to the market’s perception of
the issuer’s revenues, earnings, balance sheet, credit worthiness, business plan, and overall perception of the viability of
the issuer’s business.
• Company Risk – There is always a level of company or industry risk when investing in stock positions. This is referred to as
unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company will perform poorly
or that its value will be reduced based on factors specific to it or its industry.
Smaller Companies Risk − Stocks of smaller, less seasoned companies are generally subject to greater price fluctuations, less liquidity,
higher transaction costs and higher investment risk than those of larger, more seasoned issuers. Smaller companies may have limited
product lines, markets or financial resources, and they may be dependent on a limited management group or lack substantial capital
reserves or an established performance record. There is generally less publicly available information about such companies than for
larger, more established companies.
Foreign Securities Risk − Investments in securities of issuers in foreign countries involve risks not associated with domestic
investments. These risks include, but are not limited to: (1) political and financial instability; (2) currency exchange rate fluctuations;
(3) greater price volatility and less liquidity in particular securities and in certain foreign markets; (4) lack of uniform accounting,
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auditing, and financial reporting standards; (5) less government regulation and supervision of some foreign stock exchanges, brokers
and listed companies; (6) delays in transaction settlement in certain foreign markets; (7) less availability of information; and (8)
imposition of foreign withholding or other taxes.
Risks Associated with Socially Conscious Investing − Depending on the strategy or client-specific restrictions, a client’s account may
undergo exclusionary screening based on environmental, social and corporate governance criteria, as well as other criteria based on
religious beliefs. These criteria are nonfinancial reasons to exclude a security and therefore the client’s account or strategy may forgo
some market opportunities available to portfolios that don’t use such screening. Stocks selected following these criteria may shift into
and out of favor with stock market investors depending on market and economic conditions, and the client’s or strategy’s performance
may at times be better or worse than the performance of accounts or strategies that do not use such criteria.
Risks Associated with Positive Value Investing – Increasing exposure to investments that exhibit positive value characteristics carries
the risk that your portfolio may increase its exposure to certain types of issuers and, therefore, may underperform funds that do not
consider the same or any positive value characteristics. A company’s positive value characteristics, as used by Crossmark, are based
on data and rankings generated by multiple third-party providers unaffiliated with Crossmark and such information may be unavailable
or unreliable. As a result, your portfolio may fail to increase its exposure to investments that do exhibit positive value characteristics
or may increase its exposure to investments that do not exhibit positive value characteristics. Although Crossmark follows procedures
reasonably designed to implement the positive value investing process, such procedures could fail to accurately identify companies
that exhibit positive value characteristics. Investors can also differ in their views of what constitutes positive value characteristics. As
a result, Crossmark may increase exposure to issuers that do not reflect or support, or that act contrary to, the values of any particular
investor.
Risks Associated with Covered Call Option Writing – Options are not suitable for every investor. Writing call options to generate
income and to potentially hedge against market declines by generating option premiums involves risk. These risks include, but are not
limited to, potential losses if equity markets or an individual equity security do not move as expected. If the market price of a security
increases, a call option written against that security limits the gain that can be realized. And, there are differences between the
securities and options markets that could result in an imperfect correlation between these markets, causing a given transaction not to
achieve its objectives.
Risks Associated with Short Selling Securities – An investor’s account will incur a loss as a result of a short sale if the price of the
security sold short increases in value between the date of the short sale and the date on which the account purchases the security to
replace the borrowed security. In addition, the securities sold short may have to be returned to the lender on short notice, which may
result in the account having to buy the securities sold short at an unfavorable price to close out a short position. If this occurs, any
anticipated gain to the account may be reduced or eliminated or the short sale may result in a loss.
Fixed-Income Securities – Fixed income investments generally involve two principal risks—interest rate risk (duration risk) and credit
risk.
•
Interest Rate Risk – Prices of fixed-income securities rise and fall in response to interest rate changes. Generally, when interest
rates rise, prices of fixed-income securities fall. The longer the duration of the security, the more sensitive the security is to
this risk. If a note has a duration of one year, then a 1% increase in interest rates would reduce the value of a $100 note by
approximately one dollar.
• Credit Risk – There is a risk that the issuer of a note or bond will be unable to pay agreed interest payments and may be unable
to repay the principal upon maturity. Lower-rated bonds, and bonds with longer final maturities, generally have higher credit
risks.
ETF, Closed-end Fund and Mutual Fund Risk – ETF, closed-end fund and mutual fund investments bear additional expenses based on
a pro-rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF, closed-end
fund or mutual fund generally reflects the risks of owning the underlying securities held by the ETF, closed-end fund or mutual fund.
If the ETF, closed-end fund or mutual fund fails to achieve its investment objective, the account’s investment in the fund may adversely
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affect its performance. In addition, because ETFs and many closed-end funds are listed on national stock exchanges and are traded
like stocks listed on an exchange, (1) the account may acquire ETF or closed end fund shares at a discount or premium to their NAV,
and (2) the account may incur greater expenses since ETFs are subject to brokerage and other trading costs. Since the value of ETF
shares depends on the demand in the market, we may not be able to liquidate the holdings at the most optimal time, adversely
affecting performance. Closed-end funds which are not publicly offered provide only limited liquidity to investors. Closed-end funds
generally are not required to buy their shares back from investors upon request. In addition, they are allowed to hold a greater
percentage of illiquid securities in their investment portfolios than mutual funds.
Cybersecurity – Despite Crossmark’s extensive efforts, Crossmark’s information and technology systems remain at times be vulnerable
to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by
unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires,
tornados, floods, hurricanes and earthquakes. Although Crossmark has implemented various measures to protect the confidentiality
of its internal data and to manage risks relating to these types of events, if these systems are compromised, become inoperable for
extended periods of time or cease to function properly, Crossmark will likely have to make a significant investment to fix or replace
them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in Crossmark’s
operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information
relating to clients. Such a failure could harm Crossmark’s reputation or subject it or its affiliates to legal claims and otherwise affect
their business and financial performance. Crossmark will seek to notify affected clients of any known cybersecurity incident that will
likely pose substantial risk of exposing confidential personal data about such clients to unintended parties.
The foregoing list of risk factors does not purport to be a complete explanation of the risks involved in Crossmark’s advisory services.
Investors should read the applicable prospectus or similar account opening documents for such client, if any, in addition to consulting
with their own financial and tax advisers.
Item 9 Disciplinary Information
Crossmark has no disciplinary information to report. .
Item 10 Other Financial Industry Activities and Affiliations
Crossmark is affiliated with the following companies, each of which is wholly owned by Crossmark Global Holdings:
•
Crossmark Distributors, Inc. (Crossmark Distributors), a limited purpose broker/dealer registered with FINRA that serves as
the underwriter and distributor for the Steward Funds. See more information regarding Crossmark Distributors below.
•
Crossmark Wealth Management, LLC (Crossmark Wealth), an SEC-registered investment adviser that provides investment
advice and discretionary investment management services to direct clients. Certain directors, officers, and employees of
Crossmark also serve as directors and officers of Crossmark Wealth.
Crossmark ETF Trust
Crossmark and its affiliates also provide other administrative services to the Crossmark ETFs. And, certain directors, officers, and
employees of Crossmark also serve as directors and officers of the Crossmark ETFs. Crossmark directors, officers, and employees who
serve as directors and officers of the Crossmark ETFs receive no separate compensation from the Crossmark ETFs for the services they
provide.
Where appropriate, we may recommend that our clients invest in the Crossmark ETFs. Crossmark has an incentive to recommend the
Crossmark ETFs over similar unaffiliated options. Crossmark receives management fees for its management of the Crossmark ETFs, in
addition to the advisory fee applicable to clients that invest in the Crossmark ETFs.
Where Crossmark recommends the Crossmark ETFs to a client or utilizes investments in the Crossmark ETFs within a client’s account,
Crossmark takes into consideration the fees paid by the Crossmark ETFs to Crossmark in evaluating the overall reasonableness of the
fee charged to the client.
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Steward Funds
Crossmark and its affiliates also provide other distribution and administrative services to the Steward Funds. And, certain directors,
officers, and employees of Crossmark also serve as directors and officers of the Steward Funds. Crossmark directors, officers, and
employees who serve as directors and officers of the Steward Funds receive no separate compensation from the Steward Funds for
the services they provide.
Where appropriate, we may recommend that our clients invest in the Steward Funds. Crossmark has an incentive to recommend the
Steward Funds over similar unaffiliated options as a result of the conflicts described below. Some, but not all, of the conflicts of
interest of Crossmark’s recommendation of the Steward Funds include the following:
•
Crossmark receives management fees for its management of the Steward Funds, in addition to the advisory fee applicable to
clients that invest in the Steward Funds.
•
Crossmark also receives fees from the Steward Funds for administrative, compliance, and shareholder services.
•
A client that invests in a Steward Fund will pay the client’s pro rata share of the expenses of the Steward Fund, specifically
including a pro rata share of the fees paid to Crossmark.
Where Crossmark recommends the Steward Funds to a client or utilizes investments in the Steward Funds within a client’s account,
Crossmark takes into consideration the fees paid by the Steward Funds to Crossmark and its affiliates in evaluating the overall
reasonableness of the fee charged to the client.
Crossmark Distributors
Crossmark Distributors receives fees from the Steward Funds for distribution and shareholder services under plans adopted pursuant
to Rule 12b-1 under the Investment Company Act. These fees are generally re-allotted to other broker/dealers and financial
intermediaries who sell Steward Fund shares and service shareholder accounts. Crossmark also receives fees from the Steward Funds
for administrative, compliance, and shareholder services. Some of these fees are also re-allotted to broker/dealers and financial
intermediaries who service shareholder accounts.
Certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered representatives of Crossmark
Distributors. The business operations of Crossmark Distributors are limited to acting as the underwriter and distributor of the Steward
Funds. The activities of its associated persons are limited to marketing and wholesaling the Steward Funds.
Crossmark’s Shared Services Platform
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of staffing
and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers, employees,
and registered representatives are compensated based on commensurate skills and experience as well as performance. Compensation
programs are designed to avoid potential conflicts of interest between the companies and their clients as well as to avoid potential
conflicts between clients. Crossmark does not believe these relationships create material conflicts of interest between Crossmark and
its clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Crossmark has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees,
including compliance with applicable federal securities laws.
Crossmark and our personnel owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not
only to the specific provisions of the Code of Ethics but to the general principles that guide the Code of Ethics.
The purpose of our Code of Ethics is to reinforce the fiduciary principles that govern the conduct of our firm and the actions of our
advisory personnel. Each member of the firm is instructed to act in the best interests of all of our clients, to avoid any real or potential
conflicts of interest and to conduct their personal activities with the utmost integrity.
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Crossmark's Code of Ethics has been distributed to all members of the firm. The Code of Ethics generally covers:
•
Standards of business conduct
•
Compliance with federal securities laws
•
Review and/or approval of personal securities transactions
• Obligation to report violations
•
Annual employee certification
•
The Code of Ethics includes specific policies and procedures covering:
• Disclosure and monitoring of personal securities accounts of employees.
•
Preclearance of personal securities trades by employees where such trades do not fall into certain pre-defined exempt
categories.
•
Preclearance of certain business gifts as well as limitations on business gifts and entertainment (given and received).
•
Preclearance of certain political contributions.
The Code of Ethics also includes our policy prohibiting the use of material non-public information. While we do not believe that we
have any particular access to non-public information, all employees are reminded that any such information may not be used in a
personal or professional capacity.
Finally, the Code of Ethics also contains relevant oversight, enforcement, and recordkeeping provisions.
A copy of our Code of Ethics is available to our clients and prospective clients. You may request a copy by email sent to
info@crossmarkglobal.com, or by calling us at 713-260-9000 or by contacting us (toll-free) at 1-800-262-6631.
Interest in Client Transactions
Crossmark and its employees are prohibited from engaging in principal transactions with clients. A principal transaction is one in which
Crossmark, acting on behalf of our own account, buys or sells a security to a client.
We also do not permit agency cross transactions. An agency cross transaction is one in which our firm acts as a broker for both the
buyer and seller of a security. Crossmark and our affiliates are not restricted from forming additional investment funds, entering into
other investment advisory relationships, or engaging in other business activities, even though such activities may be in competition
with a client (including the Steward Funds) and/or may involve substantial time and resources of Crossmark and its affiliates.
Potentially, such activities could be viewed as creating a conflict of interest in that the time and effort of our management team and
employees will not be devoted exclusively to the business of existing clients.
As noted above, investments in the Steward Funds may be recommended by Crossmark and may be utilized as investments within a
client’s account.
Personal Trading
Crossmark's Code of Ethics is designed to ensure that the personal securities transactions by our employees and the activities and
interests of our employees will not interfere with:
• making decisions in your best interests; and
•
implementing such decisions while, at the same time, allowing our employees to invest for their own accounts.
Crossmark employees may purchase or sell securities in their personal accounts that we may have an interest in or subsequently invest
in.
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Because situations like these may represent actual or potential conflicts of interest, we have established the following policies and
procedures as part of our Code of Ethics to ensure we comply with our regulatory obligations and to provide you, other clients, and
other potential clients, with full and fair disclosure of such conflicts or potential conflicts of interest:
• No principal or employee of our firm may put his or her own interest ahead of the interest of your account(s).
• No principal or employee of our firm may buy or sell any security for their personal portfolio(s) where their decision is based
on information received because of their employment unless the information is available to the investing public.
• We may prohibit or require prior approval for any IPO or private placement investments by any employee or related persons
of the firm.
• Our employees, and anyone associated with our firm that has access to our investment recommendations (Access Persons),
must obtain approval for opening securities accounts, must report securities holdings upon becoming Access Persons and
annually thereafter, and must provide quarterly transaction reports or duplicate account statements.
•
Certain security purchase and/or sale transactions by employees and other Access Persons must be approved prior to placing
the order.
Any employee who violates any of these restrictions may be subject to varying levels of disciplinary action, including termination.
We maintain all records regarding personal securities transactions as required by SEC Rule 204A-1, under the Investment Advisers Act
of 1940 (the Advisers Act).
Item 12 Brokerage Practices
General
We manage both accounts in which Crossmark is given authority by the client to select brokers and negotiate commissions, and
accounts in which the client designates the broker-dealer to which brokerage should be directed. Where Crossmark has discretionary
authority, we usually determine without consultation with the client on a transaction- by-transaction basis, the securities to be bought
or sold, and the amount of securities to be bought or sold, subject to and in accordance with the investment objective and investment
restrictions of the client.
You are under no obligation to use any particular trading intermediary. We are regularly asked if we would recommend a particular
asset custodian. Because we have established relationships with several custodians and receive services as outlined below in the
section titled “Research and Soft Dollar Benefits,” and they are firms whom we feel can provide our customers with high quality service,
we suggest them. However, you are free to use any custodian that you may choose.
If you allow us to choose the custodian for your account, your investment management agreement with us will reflect that you are
providing us with the authority to determine the trading intermediaries to use. In addition, you will also be allowing us to choose the
commission costs that will be charged to you.
You may change your custodian at any time, as well as amend or revoke discretionary authority at any time by providing us with written
notice.
Best Execution
With respect to accounts for which Crossmark is given authority to select brokers, dealers, or exchange members (collectively, trading
intermediaries) and negotiate commission rates, our policy in selecting such intermediaries is to seek best execution of trades in and
for client accounts. In seeking best execution, we will consider brokerage and research services provided by a trading intermediary in
addition to commission rates, execution price, and other factors. This involves paying a commission to a trading intermediary that
exceeds the commission rate Crossmark might have obtained if the transaction had been executed through another intermediary if it
is determined by us in good faith that the amount of the commission is reasonable in relation to the value of brokerage and research
services provided by such intermediary.
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When selecting trading intermediaries and in the course of negotiating commissions, we consider among other factors the
intermediary’s reliability and the quality of its execution services on a continuing basis in addition to commission rates and the ability
to provide ancillary brokerage and research services.
Research and Soft Dollar Benefits
In instances where Crossmark chooses to utilize soft dollars for the procurement of eligible brokerage and research services from a
trading intermediary or a third party in connection with the execution of client securities transactions, we will do so in accordance
with the safe harbor afforded by Section 28(e) of the Securities Exchange Act of 1934.
We believe that most of the brokerage and research services we obtain generally benefit several or all of the relevant categories of
accounts we manage, as opposed to solely benefiting one account or one type of account. The brokerage services we obtain are used
to facilitate trading and reconciliation functions for all of the accounts we manage. The research services we obtain generally relate
to particular investment types—for example, research related to equity issuers or markets; research related to fixed income issuers or
markets; or research related to social screening functions implemented across account types.
Crossmark has entered into soft dollar agreements for eligible brokerage, research, and research-related products. Our policy is to
receive soft dollar credits only with respect to accounts for which we exercise brokerage discretion. When Crossmark utilizes soft
dollars, we use brokerage commissions generated from your trades to purchase the above discussed services. It is possible that the
brokerage, research, and research products purchased using your commission dollars also benefit other clients who have not
generated an equal amount or, in some cases, any commissions through transactions. Conversely, you can also benefit from the
brokerage, research, and research products we receive as a result of the commissions generated by other clients even though your
account did not generate any commissions.
Examples of such eligible research products and services include advice, both directly and in writing, as to the value of securities, the
advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities, as
well as furnishing analyses and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and
the performance of accounts. Eligible brokerage services, for this purpose, include effecting securities transactions and, between the
time the order is transmitted and the securities are delivered or credited to the applicable Crossmark account, performing functions
incidental to the transaction (such as clearance, settlement, and custody) or required in connection therewith by rules of the SEC or
applicable self-regulatory organizations and in accordance with relevant SEC guidance. Products and services related to trade
execution, trade settlement, and reconciliation processes are also eligible.
There are some instances in which eligible products and services are used by some employees within the firm for functions that are
not covered by the safe harbor afforded by Section 28(e). In these cases, Crossmark assesses the overall use of the products and
services to make a good faith determination as the portion of the usage that is covered by the safe harbor and pays for the remaining
portion from its own funds.
There are also instances in which Crossmark receives some benefit simply by utilizing certain trading intermediaries based on the
amount of assets, including those directed by the client, maintained with those intermediaries. These benefits are available to all
investment advisory firms who meet the intermediary’s minimum guidelines. In some cases, we receive research and services from
some intermediaries that, while not covered in a soft dollar agreement , nonetheless, benefits Crossmark. Without these
arrangements, we might be compelled to purchase the same or similar services at our own expense.
As a result of receiving these services at no additional cost, we have an incentive to continue to use or expand the use of such
intermediaries. We evaluate and examine this conflict of interest when we chose to enter into these relationships and determine that
the relationships are in the best interests of our clients and satisfy our client obligations, including our duty to seek best execution,
which is a component of the duty of care we are subject to.
You pay a commission rate that is higher than another intermediary might charge to effect the same transaction where we determine
in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking
best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative
21 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
execution, taking into consideration the full range of an intermediary’s services, including the value of research provided, execution
capability, commission rates, and responsiveness.
Accordingly, while we will seek competitive commission rates, to the benefit of you and other clients, we do not necessarily obtain the
lowest possible commission rates for your specific account transactions. Although the investment research products and services that
may be obtained by us will generally be used to service all of our clients, a brokerage commission paid by you can be used to pay for
research that is not used in managing your specific account.
Large trading intermediaries also provide us products and services that assist us in managing and administering your account(s). These
include software and other technology that:
•
provides access to your account data including trade confirmations and account statements;
•
facilitates trade execution and allocation of aggregated trade orders for multiple client accounts;
•
provides research, pricing and other market data;
•
facilitates payment of our fees from client accounts; and
•
assists with back-office functions, recordkeeping, and client reporting.
We also receive other services intended to help us manage and further develop our business enterprise. These services may include:
•
compliance, legal and business consulting;
•
publications and conferences on practice management and business planning; and
•
access to employee benefit providers, human capital consultants and insurance providers.
Large trading intermediaries also make available third-party vendors for some of the services rendered to us. These intermediaries
usually discount or waive fees they would otherwise charge for some of those services, or they pay all or a part of the fees of the third-
party providing those services to us. These intermediaries may also provide benefits such as educational events or occasional business
entertainment to our personnel.
In evaluating whether to recommend that you custody your assets at one of these intermediaries , we take into account the availability
of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider. Thus, this
decision is not based solely on the nature, cost or quality of custody and brokerage services provided by the intermediary. This may
create a potential conflict of interest.
Directed Brokerage
Clients have the option to direct us in writing to use a particular broker-dealer to execute some or all transactions for the client. In
that case, the client will negotiate terms and arrangements for the account with that broker-dealer, and we will not seek better
execution services or prices from other broker-dealers or be able to “batch” client transactions for execution through other broker-
dealers with orders for other accounts managed by us (as described below). As such, a client who directs brokerage should consider
that they: (i) may pay higher commissions on some transactions than may be attainable by Crossmark, or may receive less favorable
execution of some transactions or both; (ii) may forego any benefit on execution costs that could be obtained for clients through
negotiated volume discounts on bunched transactions; (iii) may not be able to participate in the allocation of a new issue, if the new
issue shares are provided by another broker; (iv) may receive execution of a particular trade after the execution of such trade for
clients who have not directed the brokerage for their accounts; and (vii) may not experience returns equal to clients who have not
directed brokerage for their accounts. While we outline the possibilities of directed brokerage resulting in higher fees and/or lower
benefits for clients, we would assist with such analysis to identify when the above possibilities are actualized.
Brokerage for Client Referrals
Crossmark does not receive client referrals in exchange for using any particular trading intermediary.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Trade Aggregation and Allocation
Transactions for each client account will be effected independently unless we decide to purchase or sell the same securities for multiple
clients at approximately the same time and from the same brokerage firm. At that point, Crossmark can, but is not obligated to,
combine or “batch” your orders with orders of other clients and Crossmark employees. The process of combining these orders often
allows us to negotiate more favorable commission rates. We can also allocate equitably among you and other clients the differences
between prices, commissions, and other transaction costs that had each order been placed independently. This allows you to receive
the average price paid or received as well as to share in the purchase or sale pro-rata in the event that an order is only partially
completed. We will not receive any additional compensation as a result of aggregating these orders.
Crossmark may choose not to aggregate orders in its sole discretion. Reasons that we may not aggregate orders include, but are not
limited to:
• Only a small percentage of an order is completed and thus the shares would be assigned to the account with the smallest
order or position, or that is out of line with respect to a security or sector weightings.
•
Allocations given to one account when that account has investment limitations which restrict it from purchasing other
securities which are expected to produce similar investment results.
•
If an account reaches an investment guideline limit and cannot participate in an allocation which may occur due to unforeseen
changes in account assets after an order is placed.
•
Sale allocations given to accounts that are low in cash.
• When a pro rata allocation would result in a de minimis allocation in one or more accounts.
•
In the case where a proportion of an order is filled in all accounts, shares may be allocated to one or more accounts on a
random basis.
Wrap Fee Program Considerations
Owners of accounts which are involved in wrap programs and client-directed brokerage accounts designate a registered representative
of the wrap sponsor or broker-dealer through whom portfolio transactions in their account will be effected.
Transactions in wrap program accounts are effected “net” (meaning without commission) and a portion of the fee paid by the client
to the wrap sponsor is generally considered as being in lieu of commissions. Transactions for client-directed brokerage accounts are
most often effected net, but the client may choose to have transactions effected with a commission charged per transaction at a
schedule that he/she may negotiate with his/her brokerage firm. Because Crossmark, for client-directed brokerage accounts, is
required to execute transactions only with the broker-dealer selected by the client, we will not be free to seek best price and execution
by placing transactions with other brokers and dealers and may not be able to obtain discounted rates for the client by combining his
transactions with those of other clients for trading as a block; therefore, these clients may not necessarily obtain commission rates as
favorable as other Crossmark clients.
You should wish to satisfy yourself that the broker-dealer offering the wrap program can provide adequate price and execution of
most transactions. You should also consider that, depending upon the level of the fee charged by the wrap sponsor or the broker-
dealer, the amount of portfolio activity in your account, the value of custodial and other services which are provided under the
arrangement, and other factors, the fee may or may not exceed the aggregate cost of such services if they were to be provided
separately and if Crossmark were free to negotiate commissions and seek best execution of transactions for your account.
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Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Item 13 Review of Accounts
Client accounts are managed using pre-defined investment strategy models (described above) chosen by the client in consultation
with a broker/dealer, investment adviser, or other investment consultant (the client’s intermediary). We monitor how each account
tracks the chosen model portfolio. Reviewing deviations from the model help us identify style drift and opportunities to rebalance
accounts.
Changes in your investment objectives, cash flow needs, risk tolerance, or time horizon should be discussed with your chosen
intermediary. Such changes may lead to a decision to change the investment strategy model used to manage your assets.
In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer or custodian, we
make available reports summarizing account performance and balances.
Item 14 Client Referrals and Other Compensation
Crossmark has entered into contractual arrangements with individuals who may solicit clients for Crossmark. The arrangements are
in compliance with the applicable requirements of the Advisers Act. As solicitors (also called promoters) are entitled to compensation
from Crossmark under such arrangements, they have a financial incentive to recommend Crossmark.
Item 15 Custody
Crossmark does not generally maintain custody of client cash or securities. However, depending on the type of relationship that we
have with you, we can request that you direct your account custodian to allow Crossmark to debit your management fees directly
from your account(s). The approval of the direct debit of fees is solely your choice. You have no obligation to allow us to do so.
If you agree to allow us to direct debit fees from your account(s), we will require authorization in writing from you. Each billing period
we will notify your qualified custodian of the amount of the fee to be deducted from your account(s). On at least a quarterly basis,
your account custodian will send to you and us a statement showing all transactions, including management fees disbursed from your
account during the reporting period.
It is important for you to carefully review the custodial statements to verify the accuracy of the calculation, among other things. You
should contact us directly if you believe there may be an error in your statement.
In addition to the periodic statements that you receive directly from your custodians, we may also send or provide via electronic
format, account statements directly to you on a periodic basis based on the requirements of your agreement.
In the event that you receive a statement from Crossmark, we urge you to carefully compare the information provided on the
statements you receive from us to the statements you receive from the custodian to ensure that all account transactions, including
the debit of management fees, holdings and values are correct and current.
Item 16 Investment Discretion
Generally, we accept both discretionary and non-discretionary accounts. At times, we request that we be given discretionary authority
from the outset of our advisory relationship so that we provide discretionary asset management services for your accounts. However,
you may deny such authority and request that we manage your account on a non- discretionary basis. If we do manage your account
on a discretionary basis and that authority is denied or revoked in the future we may, at our sole discretion, choose to terminate any
advisory relationship with you.
When you agree to give us discretionary authority we can place trades in your account without contacting you prior to each trade to
obtain your permission.
Our discretionary authority includes the ability to do the following without contacting you:
•
determine the security to buy or sell; and/or
•
determine the amount of the security to buy or sell.
24 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
In all cases this discretion is to be used in a manner consistent with the stated investment objectives for your account. When we select
securities and determine the amounts of those securities to buy or sell we will observe the policies, limitations or restrictions which
you may have given us to follow.
You give us discretionary authority when you sign a discretionary investment management agreement with our firm and you may limit
this authority by giving us written instructions in advance of entering into an agreement. You may also limit this authority at any time
after entering into an agreement while that agreement remains in effect by once again providing us with written instructions. These
limitations and other instructions will become a part of your permanent file. Examples include restrictions against owning certain
stocks and bonds and limitations on the percentage of cash held at any one time.
Item 17 Voting Client Securities
Crossmark has adopted and implemented written proxy voting policies and procedures (Proxy Voting Procedures) which are designed
to reasonably ensure that Crossmark votes proxies in the best interest of its advisory clients for whom it has voting authority (Proxy
Clients).
Crossmark has engaged Institutional Shareholder Services (ISS) to provide proxy research, recommendations, and voting services. ISS
provides a password protected website (Proxy Exchange), which is accessible to authorized personnel to download upcoming proxy
meeting data, including research reports, of companies held in Proxy Client portfolios. Proxy Exchange can be used to view proposed
proxy votes, obtain research for vote recommendations and to enter votes for upcoming meetings for Proxy Client portfolio securities.
Crossmark will generally follow the ISS United States Proxy Voting Guidelines (the Guidelines) to vote proxies for Proxy Client accounts,
so long as such Guidelines are considered to be in the best interests of the Proxy Client, and there are no noted or perceived conflicts
of interest. Crossmark’s use of the Guidelines is not intended to constrain consideration of any proxy proposal, and there are be times
when Crossmark deviates from the Guidelines, including when required by SEC Rule 12d1-4 agreements between Fund Proxy Clients
and certain acquired funds and other regulatory obligations. Crossmark retains final authority and fiduciary responsibility for proxy
voting.
In most cases, when securities of foreign issuers are held through ADRs, the holder of the ADR has the right to vote proxies with respect
to the underlying securities. In cases where Crossmark has the ability to vote proxies with respect to securities of foreign issuers held
through ADRs, Crossmark will follow the same processes described above with respect to voting such proxies, based on the ISS Global
Voting Principles and country-specific Proxy Voting Guidelines.
Crossmark can offer to certain Proxy Clients the ability to select an alternative set of proxy voting guidelines to be utilized with respect
to the securities held in their accounts (e.g. the ISS Catholic Faith-Based Proxy Voting Guidelines). Crossmark will only utilize
alternative voting guidelines where those alternative guidelines are affirmatively elected by the Proxy Client.
Crossmark determines whether voting in accordance with the Guidelines (or other applicable proxy voting guidelines) is in the best
interests of Proxy Client. Whenever a conflict of interest arises between ISS and a target company subject to a proxy vote, Crossmark
considers the recommendation of the company and what Crossmark believes to be in the best interests of the Proxy Client and will
vote that proxy without using the Guidelines (or other applicable proxy voting guidelines). If Crossmark has knowledge of a material
conflict of interest between itself and a Proxy Client, Crossmark shall vote the applicable proxy in accordance with the Guidelines (or
other applicable proxy voting guidelines) to avoid such conflict of interest. If there is a decision to vote against the Guidelines (or other
applicable proxy voting guidelines), Crossmark will document the reason and will vote accordingly on Proxy Exchange. Additionally, if
there is a conflict of interest between a mutual fund Proxy Client and Crossmark or other fund service providers, Crossmark will vote
the proxy based on the Guidelines to avoid such conflict of interest.
If a Proxy Client requests Crossmark to follow specific voting guidelines or additional guidelines, Crossmark shall review the request
and follow such guidelines, unless Crossmark determines that it is unable to do so. In such case, Crossmark shall inform the Proxy
Client that it is not able to honor the Proxy Client's request.
25 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
You may obtain a copy of our Proxy Voting Policy or information about how we voted client proxies by contacting us (toll- free) at 1-
800-262-6631.
Crossmark can provide tailored proxy voting with respect to accounts that meet certain minimum investment requirements.
Item 18 Financial Information
Registered investment advisers, such as Crossmark, are required to provide you with certain financial information or disclosures about
their financial condition.
•
Crossmark has no financial condition that is reasonably likely to impair our ability to meet contractual commitments to clients;
and
•
Crossmark has not been the subject of a bankruptcy proceeding.
We do not require or solicit prepayment of more than $1,200 in fees per client six months or more in advance, therefore we have no
material additional financial disclosures.
26 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
PRIVACY POLICY NOTICE
Crossmark appreciates the privacy concerns and expectations of our customers. We are committed to maintaining a high level of
privacy and confidentiality when it comes to your personal information and we use that information only as permitted by law. This
privacy policy contains information about how we fulfill this commitment to you. In compliance with government regulations, we will
provide this notice to you annually.
OUR COMMITMENT TO YOU
We value the trust of our customers and will continue to recognize the importance of holding your personal financial information as
confidential.
We will use information responsibly in order to protect you from fraud, offer you improved products and services and comply with
legal obligations.
We will maintain accurate customer information and respond promptly to customer requests to correct information.
We will require companies with which we do business to use our customer information appropriately and to safeguard the
confidentiality of such information.
COLLECTION OF INFORMATION
We collect non-public personal information about you from the following sources:
•
Information that we receive from you personally on applications, forms, or other correspondence, such as your name,
address, phone number, social security number, and e-mail address.
•
Information about your transactions with us, such as your account holdings and transaction history.
DISCLOSURE OF INFORMATION
We do not disclose any information about our customers or former customers to third parties except to the extent necessary to service
your account, as permitted by law.
WE PROTECT NON-PUBLIC PERSONAL INFORMATION ABOUT FORMER CUSTOMERS
If you decide to close your account(s), we will continue to adhere to the privacy policies and practices described in this notice. As
permitted by law, we may disclose your non-public personal information to affiliates of Crossmark and to third parties involved in the
maintenance of your account(s).
WE HAVE SAFEGUARDS IN PLACE
We have safeguards in place to protect the confidentiality, security and integrity of your non-public personal information. We restrict
access to non-public personal information to those who need to know that information in order to service your account. We maintain
physical, electronic and procedural safeguards that comply with government requirements to guard non-public personal information.
We appreciate the opportunity to serve your investment needs. We pledge to follow the policies, safeguards and guidelines as
described in this notice and to protect the confidentiality of your information. Your relationship is very important to us, and we will
take great care to honor these commitments to you.
For more information about Crossmark’s privacy policies, please call (800) 262-6631.
27 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
FORM ADV PART 2B SUPPLEMENTAL BROCHURE
ITEM 1
Crossmark Global Investments, Inc., 15375 Memorial Drive, Suite 200
Houston, Texas, 77079
(713) 260-9000
www.crossmarkglobal.com
Robert C. (Bob) Doll, CFA
President, Chief Executive Officer, and Chief Investment Officer
Victoria L. Fernandez, CFA
Ryan E. Caylor, CFA
Chief Market Strategist
Portfolio Manager – Head of Research
Robert (Rob) Botard, CFA
Andrew Cullivan, CFA
Managing Director – Head of Equity Investments
Portfolio Manager
Paul C. Townsen
Greg Brunk
Managing Director – Portfolio Manager
Head of Product Strategy and Marketing
Patrick N. (Pat) Garboden
Will Sorrell
Senior Portfolio Manager – Municipal Bonds
Senior Director – Values-Based Investing
This brochure supplement provides information about the above named professionals that supplements the Crossmark Global
Investments, Inc. (Crossmark) brochure. You should have received a copy of that brochure.
Please contact us by email at info@crossmarkglobal.com if you did not receive Crossmark’s brochure or if you have any questions
about the contents of this supplement.
Additional information about the above named professionals is available on the SEC’s website at: www.adviserinfo.sec.gov
28 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Robert C. (Bob) Doll, CFA, President, Chief Executive Officer, and Chief Investment Officer
Birth Year: 1954
Item 2
Educational Background and Business Experience
Bob Doll joined Crossmark in 2021, as Chief Investment Officer (CIO), bringing over 40 years of industry experience to guide the
investment process and serve as portfolio manager for multiple Crossmark large-cap strategies. He also utilizes his investment
expertise to provide weekly and quarterly investment commentaries, as well as annual market predictions. Bob is a regular
guest and contributor to multiple media outlets such as Bloomberg TV, Fox Business News, CNBC and Faith & Finance Live Radio.
Prior to arriving at Crossmark, he held the roles of Senior Portfolio Manager and Chief Equity Strategist at Nuveen (2012-2021)
and Blackrock (2006-2012), President and Chief Investment Officer at Merrill Lynch Investment Managers (1999-2006), and Chief
Investment Officer at Oppenheimer Funds, Inc. (1987-1999).
Bob graduated from Lehigh University with a B.S. in Accounting and a B.A. in Economics. He later went on to earn an M.B.A.
from the Wharton School of the University of Pennsylvania. He is a Certified Public Accountant (CPA) and holds the Chartered
Financial Analyst (CFA®) designation, as well as the FINRA Series 7 and 63 securities licenses.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Bob is an officer of the Crossmark
ETFs and the Steward Funds, and a registered representative of Crossmark Distributors.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Bob does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Bob is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
29 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Victoria L. Fernandez, CFA, Chief Market Strategist
Birth Year: 1973
Item 2
Educational Background and Business Experience
Victoria Fernandez joined Crossmark in 2012, and serves as the Chief Market Strategist. She works with the firm’s executive and
research teams to analyze current market trends and provide comments to the media and public around Crossmark’s investment
outlook on networks including Bloomberg, CNBC, Fox Business and Yahoo Finance. She is also responsible for managing the
Crossmark Fixed Income Investment team while serving as Portfolio Manager for taxable fixed income products.
Victoria began her career in 1994, at Fayez Sarofim & Company, a Houston-based financial advisory firm. During her 18 years at
the firm, Victoria enhanced her knowledge of the industry through a variety of roles within the fixed income division, including
Head Trader, Municipal Portfolio Manager, and as an Associate on the management team.
Victoria earned a Bachelor of Arts from Rice University. She earned a Master of Business Administration from the May’s Business
School at Texas A&M University, and she is a CFA® Charterholder.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Victoria is an officer of the
Crossmark ETFs and the Steward Funds.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Victoria does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Victoria is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such,
is subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
30 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Rob Botard, CFA, Managing Director – Head of Equity Investments
Birth Year: 1970
Item 2
Educational Background and Business Experience
Rob Botard joined Crossmark in 2022, and serves as Managing Director – Head of Equity Investments. Rob has more than 30
years of investment management experience. Prior to joining Crossmark, he served as a portfolio manager at Invesco, focusing
primarily on the company’s dividend value investment strategies. He began his career at Criterion Investments but quickly
moved to AIM/Invesco, where he held leadership roles in quantitative and equity analysis and as a derivatives trader.
Rob holds a B.B.A. in Finance and International Business from the University of Texas at Austin and a Master of International
Management from Thunderbird, The American Graduate School of International Management. He is also a CFA® Charterholder.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Rob is an officer of the Crossmark
ETFs and the Steward Funds.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Rob does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Rob is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
31 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Paul Townsen, Managing Director – Portfolio Manager
Birth Year: 1971
Item 2
Educational Background and Business Experience
Paul Townsen began his investment career at Crossmark in 1993. Since 2005, he has served as Portfolio Manager for the
Crossmark Covered Call Income SMA and Steward Covered Call Income Fund. In 2021, Paul was promoted to Managing Director
within the Equity Investments Team. Since starting his career at Crossmark, Paul has worked in a variety of roles within the
investment and trading teams, with a focus on portfolio management and trading operations across multiple strategies.
Paul earned a B.B.A. in Finance from the University of the Incarnate Word.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Paul is an officer of the Crossmark
ETFs and the Steward Funds.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Paul does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Paul is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
32 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Patrick N. (Pat) Garboden, Senior Portfolio Manager – Municipal Bonds
Birth Year: 1957
Item 2
Educational Background and Business Experience
Pat Garboden joined Crossmark in 2004, and serves as Senior Portfolio Manager – Municipal Bonds. Pat brings over 41 years of
experience within the financial services industry, including 19 years with Smith Barney. His broad financial background includes
serving as First Vice President, Branch Manager for 11 years, and as an Investment Management Specialist/Portfolio Manager
with the Consulting Group, a division of Citigroup Global Markets. Before joining Smith Barney, Pat was a general partner in the
financial services firm of Jones, Humphrey, Garboden, and Company.
Pat attended the University of Oregon and currently holds the Series 7, 63, and 65 securities licenses.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Pat is a registered representative
of Crossmark Distributors.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Pat does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Pat is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
33 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Ryan E. Caylor, CFA, Portfolio Manager – Head of Research
Birth Year: 1986
Item 2
Educational Background and Business Experience
Ryan Caylor joined Crossmark in June of 2016, and currently serves as Portfolio Manager – Head of Research. As Portfolio
Manager, he is responsible for co-managing several of our equity strategies in the large cap space. As Head of Research, he is
responsible for quantitative and fundamental research on markets, sectors, and individual companies, in addition to overseeing
the firm’s values-based research team in support of Crossmark’s Portfolio Managers and Investments group.
Before joining Crossmark, Ryan was a sell-side equity research analyst at energy investment bank Tudor, Pickering, Holt & Co.,
covering competitive power and electric utility stocks. Previously, he was an Associate in the Energy Valuation Group at
PricewaterhouseCoopers. Ryan graduated from Tulane University in New Orleans with an undergraduate degree in Finance, as
well as Masters degrees in Accounting and Finance. He currently holds the Series 7, 63, 86, and 87 securities licenses and is a
CFA® Charterholder.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Ryan is an officer of the Crossmark
ETFs and the Steward Funds, and a registered representative of Crossmark Distributors.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Ryan does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Ryan is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such,
is subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
34 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Andrew Cullivan, CFA, Portfolio Manager
Birth Year: 1991
Item 2
Educational Background and Business Experience
Andrew Cullivan joined Crossmark in April of 2024. He currently serves as a portfolio manager and brings over a decade of
industry experience to the investment team. In his role as a portfolio manager, Andrew oversees the values enhanced Steward
Funds as well as Crossmark’s custom equity index strategies. Prior to joining Crossmark, Andrew was a portfolio manager with
Veriti Management (acquired by First Trust in 2022) where he managed tax-aware index strategies as well as a variety of passive
institutional mandates.
Andrew holds a B.S. in Finance from Bentley University and is also a CFA Charterholder.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Andrew is an officer of the
Crossmark ETFs and the Steward Funds.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Andrew does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Andrew is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such,
is subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
35 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Gregory T. (Greg) Brunk, Head of Product Strategy and Marketing
Birth Year: 1969
Item 2
Educational Background and Business Experience
Greg Brunk joined Crossmark in 2023, as a client portfolio manager and became Head of Product Strategy and Marketing in 2025.
Greg has been in the asset management industry since 1992. Most recently, Greg served as Managing Director, Senior Equity
Product Specialist with Blackrock and held similar roles with Nuveen and Van Kampen. He led a wide range of initiatives from
product launches to restructuring projects to developing strategy to help reverse years of net outflows. Greg has frequently
engaged with financial advisors/clients to provide strategy updates and portfolio reviews. He has also served as a speaker at
industry events and new business presentations.
Greg holds FINRA Series 7, 24, and 63 licenses.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Greg is a registered representative
and registered principal of Crossmark Distributors.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Greg does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Greg is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
36 | P a g e
Crossmark Global Investments, Inc.
Form ADV Parts 2A and 2B Revised June 30, 2025
Will Sorrell, Senior Director – Values-Based Investing
Birth Year: 1994
Item 2 Educational Background and Business Experience
Will Sorrell joined Crossmark in 2024, as Senior Director – Values-Based Investing. Will has been in the asset management
industry since 2021.
Will leads the firm’s messaging and methodology around values-based investing strategy. He specializes in quantitative analysis,
qualitative research, corporate engagement, and thought leadership for both institutional and retail investors. Will is also
Crossmark’s Senior Proxy Advisor and chairs the Active Ownership Committee. Before joining Crossmark, Will served as Director
of Values-Based Investing at OneAscent. Will earned an MBA from Samford University’s Brock School of Business and a Master
of Divinity from Beeson Divinity School.
Item 3 Disciplinary Information
There are no legal or disciplinary actions to report.
Item 4 Other Business Activities
As noted above, certain directors, officers, and employees of Crossmark also serve as directors, officers, and registered
representatives of various Crossmark affiliates, the Crossmark ETFs, and the Steward Funds. Will does not hold a formal role
with any affiliated entity but does serve in a cross functional role, supporting the Crossmark ETFs, the Steward Funds, and
Crossmark Wealth Management.
Crossmark does not believe these relationships create material conflicts of interest between Crossmark and its clients.
Crossmark and its affiliates employ an integrated staffing and resource plan that is intended to ensure that appropriate levels of
staffing and infrastructure support exist to undertake the obligations of each company to its clients. Individual directors, officers,
employees, and registered representatives are compensated based on commensurate skills and experience as well as
performance. Compensation programs are designed and monitored to avoid potential conflicts of interest between the
companies and their clients as well as to avoid potential conflicts between clients.
Item 5 Additional Compensation
Will does not receive any additional compensation from non-clients for providing advisory services.
Item 6 Supervision
Will is a supervised person and an Access Person (as defined under Rule 204A-1 of the Investment Advisers Act), and as such, is
subject to the firm’s compliance policies and procedures in addition to the Crossmark Code of Ethics. The firm’s compliance
department periodically monitors supervised persons’ trading for client accounts.
The following individuals comprise Crossmark’s Management Team:
•
Robert C. (Bob) Doll, CFA
• Heather Lindsey
•
•
James Jacoby
Jim Coppedge
• Victoria L. Fernandez, CFA
37 | P a g e