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Firm Brochure
(Part 2A of Form ADV)
EagleStone Wealth Advisors, Inc.
1101 Wootton Parkway
Suite 400
Rockville, MD 20852-1067
Phone: (301) 924-2160
Fax: (202) 204-6322
www.EagleStoneWealth.com
operations@eaglestonewealth.com
October 9, 2025
This brochure provides information about the qualifications and business practices of
EagleStone Wealth Advisors, Inc. If you have any questions about the contents of this
brochure, please contact us at (301) 924-2160, or by email at
operations@EagleStonewealth.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission, or by any state
securities authority. In this brochure, EagleStone refers to itself as a Registered Investment
Advisor. The term "Registered" does not in any way imply a certain level of skill or training.
Additional information about EagleStone Wealth Advisors, Inc. is available on the SEC's
website at www.adviserinfo.sec.gov.
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Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our last update dated August 28 2025, we have made the following material changes:
Item 4 Advisory Business
Following an asset purchase agreement with an unaffiliated registered investment adviser, EagleStone
has discontinued providing continuous and regular investment-advisory services and is completing the
transition of client accounts to the acquiring firm. The firm remains registered with the U.S. Securities
and Exchange Commission during this transition and continues to meet its regulatory and contractual
obligations to clients in transition.
Item 9 Disciplinary Information
This Brochure has been updated to reflect recent regulatory and operational developments. Additional
information regarding regulatory actions involving James D. Warring, the firm's former CEO and
founder, is available in Item 9 of this Brochure and in the firm's Form ADV Part 1, which is publicly
available at www.adviserinfo.sec.gov.
Item 10 Other Financial Industry Activities and Affiliations
The Brochure also reflects a new disclosure in Item 10 regarding an asset purchase agreement
between EagleStone Wealth Advisors and an unaffiliated registered investment adviser, pursuant to
which certain client relationships and assets may transition to that firm over time. The firm is not
actively providing advisory services during the transition but continues to meet its regulatory and client
obligations.
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Table Of Contents
Cover Page
Material Changes
Table Of Contents
Advisory Business
Fees and Compensation
Performance-Based Fees and Side-By-Side Management
Types of Clients
Methods of Analysis, Investment Strategies and Risk of Loss
Disciplinary Information
Other Financial Industry Activities and Affiliations
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Brokerage Practices
Review of Accounts
Client Referrals and Other Compensation
Custody
Investment Discretion
Voting Client Securities
Financial Information
Requirements for State-Registered Advisers
Additional Information
Firm Biographies
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Advisory Business
The information below describes the advisory services and fee arrangements that EagleStone Wealth
Advisors, Inc. ("EagleStone") historically provided to clients prior to the firm's asset purchase
agreement and current wind-down of its advisory operations. Following an asset purchase agreement
with an unaffiliated registered investment adviser, clients who previously received investment advisory
services from EagleStone are being transitioned to the acquiring firm under the terms of that
agreement. EagleStone no longer provides continuous and regular supervisory or management
services to client portfolios. The firm remains registered with the U.S. Securities and Exchange
Commission while completing the transition of client accounts and continues to meet its regulatory and
contractual obligations to clients in transition. The firm expects to file a Form ADV-W to withdraw its
registration upon completion of the transition.
Description of Firm
EagleStone Tax & Wealth Advisors is a registered investment adviser primarily based in Rockville, MD.
We are organized as a corporation under the laws of the State of Maryland. We have been providing
investment advisory services since 02/01/2007. We are primarily owned by Eaglestone Tax & Wealth
Advisors, Inc.
The following paragraphs describe our services and fees. Refer to the description of each investment
advisory service listed below for information on how we tailor our advisory services to your individual
needs. As used in this brochure, the words "we," "our," and "us" refer to EagleStone Tax & Wealth
Advisors and the words "you," "your," and "client" refer to you as either a client or prospective client of
our firm.
Portfolio Management Services
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow us to determine
the specific securities, and the amount of securities, to be purchased or sold for your account without
your approval prior to each transaction. Discretionary authority is typically granted by the investment
advisory agreement you sign with our firm and the appropriate trading authorization forms.
You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing.
Asset Allocation Services
We offer asset allocation services that are tailored to meet our clients' needs and investment
objectives. Once you have retained our firm for asset allocation services, we will gather information
about your financial situation and objectives, and assist you in determining your investment goals,
objectives, risk tolerance, and retirement plan time horizon. We will initially provide you with
recommendations as to how to allocate your investments among categories of assets. We will then
review your account on a periodic basis. Where appropriate, we may provide you with
recommendations to change your asset allocation in an effort to remain consistent with your stated
financial objectives. You are free at all times to accept or reject any of our investment
recommendations. You are solely responsible for implementing our recommendations. Unless you
separately retain our services, we will not execute any transactions or changes in asset allocation on
your behalf.
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Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
clients regarding the management of their financial resources based upon an analysis of their
individual needs. These services can range from broad-based financial planning to consultative or
single subject planning. If you retain our firm for financial planning services, we will meet with you to
gather information about your financial circumstances and objectives. We may also use financial
planning software to determine your current financial position and to define and quantify your long-term
goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we
will develop shorter-term, targeted objectives. Once we review and analyze the information you provide
to our firm and the data derived from our financial planning software, we will deliver a written plan to
you, designed to help you achieve your stated financial goals and objectives.
Retirement Accumulation Strategies:
• 401(k)s, 403(b)s, Design and Oversight
IRA Rollover and Beneficiary Designation Planning
•
• Pension Plan and Profit Sharing Design Consultation
• Defined Benefit Plan Oversight
IRA vs ROTH IRA Analysis
•
• Financial Independence Studies
Advisory Services for Organizations:
• Entity Selection for Small Business
• Company and Employer Fringe Benefits
• Business Succession & Buy-Sell Planning
• Risk Management & Insurance Protection Planning for Business Owners and Key Executives
• Review of Legal Documents
Wealth Accumulation Strategies for Individuals and Families:
• Education Planning and Funding
• UTMAs/UGMAs for Minors
• Risk Management and Insurance Protection for Families
• Mortgage Counseling
Other Advisory Services:
Initial Public Offerings (IPO), when appropriate
• Access to Institutional Money Managers, when appropriate
•
• Tax Planning
Wealth Preservation Strategies:
• Review of Estate Planning Documents
• Wealth Transfer Techniques
• Estate Tax Minimization
• Generation Skipping Trust Planning
• Philanthropic Strategies
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change.
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You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
Financial Consulting Services
We offer financial consulting services that primarily involve advising clients on specific financial-related
topics. The topics we address may include, but are not limited to, risk assessment/management,
investment planning, financial organization, or financial decision making/negotiation.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services may include an existing plan review and analysis, plan-level advice regarding fund selection
and investment options, education services to plan participants, investment performance monitoring,
and/or ongoing consulting. These pension consulting services will generally be non-discretionary and
advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor
or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational
seminars to plan participants on such topics as:
• Diversification;
• Asset allocation;
• Risk tolerance; and
• Time horizon
Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually
negotiated basis. All services, whether discussed above or customized for the plan based upon
requirements from the plan fiduciaries (which may include additional plan-level or participant-level
services) shall be detailed in a written agreement and be consistent with the parameters set forth in the
plan documents.
Either party to the pension consulting agreement may terminate the agreement upon written notice to
the other party in accordance with the terms of the agreement for services. The pension consulting
fees will be prorated for the quarter in which the termination notice is given and any unearned fees will
be refunded to the client.
Family Office and Wealth Planning Services
We offer Family Office and Wealth Planning Services designed to help our clients organize their
financial situation and plan for the successful transfer of wealth to the next generation in the most tax-
advantaged manner. Such services generally include financial planning in the following areas:
• Family Continuity;
• Estate Planning and Trustee Oversight;
Integrated Tax and Financial Planning;
•
• Lifestyle Management;
• Family Philanthropy; and
• Risk Management
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Types of Investments
We offer advice on equity securities, corporate debt securities (other than commercial paper),
commercial paper, certificates of deposit, municipal securities, variable life insurance, variable
annuities, mutual fund shares, closed-end interval funds, United States government securities, private
placements, money market funds, real estate, REITs, structured products, ETFs, leveraged ETFs,
interests in partnerships investing in real estate, interests in partnerships investing in oil and gas
interests and interests in partnerships investing in Opportunity Zones.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
Principals, investment adviser representatives or other associated persons of the Adviser maintain
registration as registered representatives of Emerson Equity LLC ("Emerson"), a broker/dealer and
FINRA member firm. These representatives are subject to Emerson's compliance policies and
procedures and supervisory oversight. In our capacity as registered representatives, the Adviser and
the Emerson representatives will not receive a share of Emerson's compliance and supervisory fee.
Clients are advised that there may be other alternative investment sponsors and/or products not
recommended by the Adviser that are suitable for the client and that may cost more or less than those
recommended by the Adviser. While Emerson reviews numerous alternative investment sponsors
and/or products on an on-going basis, Emerson approves only a select number of sponsors/products
pursuant to its due diligence requirements and reviews. Accordingly, your ability to obtain alternative
investments through the Adviser will be limited to those approved products. While you are free to
explore various alternative investments independent of the Adviser, such investments cannot be
obtained by means of the Adviser's guidance and recommendation.
EagleStone Managed Account Program (E-MAP)
EagleStone will design and manage a portfolio that will be invested similarly to the portfolios of other
clients who have similar investment objectives. EagleStone will perform research and design a
portfolio that is specifically designed to meet the client's risk tolerance, objectives, time horizon, unique
needs and circumstances, while taking into consideration the client's specific tax profile. The currently
available E-MAP portfolio models are designated as Ultra-Conservative, Conservative, Moderate,
Moderately Aggressive, Aggressive, and Highly Aggressive. Periodically, EagleStone may create
additional portfolio models. In addition, EagleStone and the client may create a customized portfolio
for the client's investment account, if necessary and appropriate.
Generally, the client will choose, in consultation with EagleStone, one of the E-MAP portfolio types that
most closely match the client's investment objectives. The E-MAP portfolios consist primarily of listed
securities which include, but are not limited to, money market funds, ETFs and no-load or load-waived,
no transaction fee mutual funds. However, from time to time, the portfolios may also consist of listed
securities including, but not limited to, stocks, bonds, unit investment trusts, certificates of deposit and
other securities defined as such under applicable Federal and State laws.
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EagleStone will monitor market conditions and the performance of the client's portfolio. The client may
change the E-MAP portfolio model at any time. Via an Investment Management Agreement and
Investment Policy Statement that the client will sign, the client agrees to notify EagleStone of a
change in risk tolerance, objectives or time horizon. The minimum initial investment in the E-MAP
Program is $80,000.
EagleStone Wealth Advisors, Inc.'s employees or affiliates may occasionally act in the capacity of a
registered representative, if it is in the best interest of the client to do so. Generally, a registered
representative will earn a commission for such services. Generally, the commission is paid directly to
the employee or affiliate by the provider or vendor through a broker dealer. EagleStone Wealth
Advisors, Inc. does not receive commissions for such investment products. Products and services
offered by EagleStone's employees or affiliates include, but are not limited to:
Partnership Investments:
• REITs/Real Estate
• Oil & Gas
• Equipment Leasing
• Private Equity
Insurance Related Vehicles:
• Life Insurance Policies
• Disability Insurance
• Long Term Care Insurance
• Annuities (Fixed)
• Annuities (Variable & Indexed)
• Life Settlements
Education Planning:
• 529 College Savings Plans
• Coverdell Savings Plans
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. When we provide investment advice to you regarding your
retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I
of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable,
which are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
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We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Assets Under Management
As of December 31, 2024, EagleStone Wealth Advisors, Inc. manages $197,712,199 on a
discretionary basis.
Fees and Compensation
Portfolio Management Services
Our annual fee for portfolio management services varies between 1.50% to 1.95% (usually discounted
from stated fees) depending upon the market value of your assets under our management, the type
and complexity of the asset management services provided, as well as the level of administration
requested either directly or assumed by the client. Assets in each of your account(s) are included in
the fee assessment unless specifically identified in writing for exclusion.
Our annual portfolio management fee is billed and payable, quarterly in advance, based on the
balance at end of billing period.
If the portfolio management agreement is executed at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is
negotiable, depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. We will send you an invoice showing the
amount of the fee. Further, the qualified custodian will deliver an account statement to you at least
quarterly. These account statements will show all disbursements from your account. You should review
all statements for accuracy.
We encourage you to reconcile our invoices with the statement(s) you receive from the qualified
custodian. If you find any inconsistent information between our invoice and the statement(s) you
receive from the qualified custodian, call our main office number located on the cover page of this
brochure.
If the Managed Account Value is:
From
$80,000
To
$150,000
Maximum Annual
Management Fee
will be:
E-MAP
1.95%
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$250,000
$500,000
$750,000
$1,000,000
$3,000,000
$5,000,000
$7,500,000
$10,000,000
$150,000
$250,000
$500,000
$750,000
$1,000,000
$3,000,000
$5,000,000
$7,500,000
over $10,000,000
1.90%
1.85%
1.80%
1.75%
1.70%
1.65%
1.60%
1.55%
1.50%
The Investment Management Agreement may be terminated by either party providing ninety (90) days
written notice to the other by certified, registered mail or electronic mail to the addresses set forth
above. This Agreement shall be valid for one (1) year from the effective date below and will be
automatically renewed annually for one (1) year terms. However, either party may terminate this
Agreement at any time by giving written notice. Upon termination, EagleStone can trade or transact on
the account unless Client provides written instructions to the contrary.
Financial Planning Services
If a client will incur hourly charges for Comprehensive Financial Planning services, the client will agree
to any fees in advance of the service. EagleStone's fees are based on the number of hours required
multiplied by the standard billing rate of the professional or para-professional working on the
Comprehensive Financial Planning services. In addition, we may charge for computer processing
costs, delivery charges, long-distance telephone calls, and any out-of-pocket costs that we incur on the
client's behalf.
Following is a summary of our hourly billing rates, which parallels the experience level of the staff
involved:
Partners / Shareholders $300 - $400
Manager / Directors $250 - $300
Senior Staff $200 - $250
Financial Advisors / Wealth Advisors $150 - $200
Financial Analysts $100 - $150
Junior Financial Analysts / Administrative Staff $75 - $100
EagleStone and the client will determine whether to pay an hourly fee, flat fee, or retainer for
Comprehensive Financial Planning services. EagleStone and the client will agree on a fixed fee based
on an estimate of the number of hours and level of staff required to service the client. For
Comprehensive Financial Planning services, the client decides in advance on how EagleStone is to be
compensated.
We will not require prepayment of a fee more than six months in advance and in excess of $1,200.
At our discretion, we may offset our financial planning fees to the extent you implement the financial
plan through our Portfolio Management Service.
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You may terminate the financial planning agreement upon providing ninety (90) days written notice to
the other by certified, registered mail or electronic mail to the addresses set forth above. If you have
pre-paid financial planning fees that we have not yet earned, you will receive a prorated refund of
those fees. If financial planning fees are payable in arrears, you will be responsible for a prorated fee
based on services performed prior to termination of the financial planning agreement.
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Financial Consulting Services
You may terminate the financial consulting agreement upon providing ninety (90) days written notice to
the other by certified, registered mail or electronic mail to the addresses set forth above. If you have
pre-paid financial consulting fees that we have not yet earned, you will receive a prorated refund of
those fees. If financial consulting fees are payable in arrears, you will be responsible for a prorated fee
based on services performed prior to termination of the financial consulting agreement.
Pension Consulting Services
Our advisory fees for these customized services will be negotiated with the plan sponsor or named
fiduciary on a case-by-case basis.
You may terminate the pension consulting services agreement upon providing ninety (90) days written
notice to the other by certified, registered mail or electronic mail to the addresses set forth above. You
will incur a pro rata charge for services rendered prior to the termination of the agreement, which
means you will incur advisory fees only in proportion to the number of days in the quarter for which you
are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated
refund of those fees.
Family Office and Wealth Planning Services
You may terminate the family office and wealth planning services agreement upon providing ninety
(90) days written notice to the other by certified, registered mail or electronic mail to the addresses set
forth above. You will incur a pro rata charge for services rendered prior to the termination of the
agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses. You will also incur transaction charges and/or
brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by
the broker-dealer or custodian through whom your account transactions are executed. We do not
share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or
custodian. To fully understand the total cost you will incur, you should review all the fees charged by
mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices,
refer to the Brokerage Practices section of this brochure.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm are registered representatives with Emerson
Equity, a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. In their capacity as registered representatives, these
persons receive compensation in connection with the purchase and sale of securities or other
investment products, including asset-based sales charges, service fees or 12b-1 fees, for the sale or
holding, of mutual funds. Compensation earned by these persons in their capacities as registered
representatives is separate and in addition to our advisory fees. This practice presents a conflict of
interest because persons providing investment advice to advisory clients on behalf of our firm who are
registered representatives have an incentive to recommend investment products based on the
compensation received rather than solely based on your needs. Persons providing investment advice
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to advisory clients on behalf of our firm can select or recommend, and in many instances will select or
recommend, mutual fund investments in share classes that pay 12b-1 fees when clients are eligible to
purchase share classes of the same funds that do not pay such fees and are less expensive. This
presents a conflict of interest. You are under no obligation, contractually or otherwise, to purchase
securities products through any person affiliated with our firm who receives compensation described
above.
Persons providing investment advice on behalf of our firm are licensed as independent insurance
agents. These persons will earn commission-based compensation for selling insurance products,
including insurance products they sell to you. Insurance commissions earned by these persons are
separate and in addition to our advisory fees. This practice presents a conflict of interest because
persons providing investment advice on behalf of our firm who are insurance agents have an incentive
to recommend insurance products to you for the purpose of generating commissions rather than solely
based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance
products through any person affiliated with our firm.
Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of a capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above, and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
Types of Clients
EagleStone Wealth Advisors, Inc. clients include, but are not limited to individuals, nonprofits,
foundations, corporations, partnerships, estates, trusts and pension/profit sharing plans.
Account Minimums
EagleStone Wealth Advisors, Inc.'s philosophy is to embrace new relationships and accept clients who
may be considered too small by some firms. Therefore, the account minimum for a managed account
with EagleStone is generally $80,000. Exceptions can be made based on consolidated household
accounts or relationships with or referrals from other clients. EagleStone reserves the right to grant
exceptions on a case by case basis for account minimums based on each scenario.
Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis & Client Profile
EagleStone Wealth Advisors, Inc. will make recommendations concerning strategy, portfolio mix,
liquidity, risk profile and strategic allocation. EagleStone recognizes that each client's circumstances
are unique and as such, each investment strategy will be unique to the client.
When creating an investment strategy, EagleStone will take into consideration a client's objectives,
income, net worth, time horizon, tax profile, level of comfort with certain investments, age, risk
tolerance and liquidity needs.
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Investment Strategies & Asset Management Philosophy
EagleStone Wealth Advisors, Inc. utilizes "Modern Portfolio Theory" as recognized by the 1990 Nobel
Prize. Modern Portfolio Theory (MPT), a disciplined and proven approach to investing, quantifies risk
and mathematically explains why and how portfolio diversification works to reduce volatility and/or
increase investment returns. Because MPT recognizes the importance of the inter-relationships
among asset classes within an overall investment portfolio, it profoundly shaped how institutional
portfolios are managed to optimize market risk against expected returns. According to MPT, over the
long term, stocks have historically provided growth in a portfolio while fixed income (such as bonds and
cash) have provided stability. When combined in a portfolio, stocks and bonds should provide steady
growth over the longer term. Another facet of MPT is asset class correlation. In order to reduce the
volatility of a portfolio, EagleStone looks for asset classes that are negatively correlated or have a low
correlation to stocks. Theoretically, when the stock market is in decline, the presence of asset classes
that are negatively correlated or have a low correlation to stocks will increase or hold their value, thus
smoothing out the volatility of a portfolio.
Under MPT, portfolios will be constructed using a variety of asset classes in a specific mix to meet the
client's risk tolerance, investment objectives and time horizon. Examples of the asset classes that
EagleStone uses to diversify a portfolio are: US Large Capitalization Growth, US Large Capitalization
Value, US Mid Capitalization Growth, US Mid Capitalization Value, US Small Capitalization Growth, US
Small Capitalization Value, Foreign Equities from Developed Countries, Foreign Equities from
Emerging Markets, US Corporate Bonds of varying maturities, US Government Bonds of various
agencies and maturities, International Bonds from both developed and emerging markets, High Yield
Bonds (both foreign and domestic), Real Estate (both foreign and domestic) and various "Alternative"
asset classes. EagleStone defines "Alternative" asset classes as commodities (oil, gas, gold, etc.),
currencies and hedging strategies (long/short, market neutral, inverse, etc.). In addition, certain tax
sensitive portfolios may also contain Municipal Bonds.
Increasing diversification of the portfolio by using multiple levels of asset classes should decrease
portfolio risk. Additionally, investing globally helps to minimize overall portfolio risk. Investing in
equities offers the potential for higher returns when compared to fixed income (such as bonds or
cash). In exchange for higher returns, equities are also more volatile in their performance when
compared to fixed income. Generally, more conservative portfolios will have a higher proportion of
fixed income (such as bonds and cash) than stocks and more aggressive portfolios will have a higher
proportion of stocks and foreign exposure than fixed income.
EagleStone assumes that markets are efficient and it is impossible to know ahead of time what sectors
of the market will perform in a superior fashion, and therefore, we do not subscribe to market timing.
Market timing of sales and purchases is highly unlikely to increase returns and, therefore, will be
avoided. The underlying approach to this portfolio will be to optimize the risk/return relationship
appropriate to the client's needs and goals using a globally diversified portfolio following the "buy and
hold" theory with periodic rebalancing.
EagleStone may choose to employ the benefits of dollar cost averaging to reduce the impact of short
term market fluctuations on the portfolio. Diversification of asset categories and selection will be
deemed critical to take advantage of correlation and risk/return relationships. This technique will be
employed during the entire process. To the extent that history has indicated that a substantial portion
of the return derived from a portfolio is based on its allocation, the portfolio is scheduled to be
rebalanced at least annually to maintain the desired allocation. From time to time market conditions
will cause the portfolio's investment in various classes to vary from the established target allocation.
Keep in mind that the target allocation is only a guideline, and actual holdings will differ from the target
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at all times. This will be reviewed periodically and if the actual weighting differs significantly from the
established allocation, the portfolio will be reallocated, based on professional judgment, income tax
ramifications, and the client's goals.
Diversification of investment products and asset classes are critical to wealth accumulation and wealth
preservation. EagleStone will recommend specific investment products to clients to be used in their
overall investment portfolio.
An investment management account is generally viewed as a critical part of an overall investment
strategy. In many instances, ETFs and no load or load waived, no transaction fee mutual funds will
be the underlying investments in managed accounts. Clients will be informed as to the general asset
classes that will be used to implement a client's investment strategy. Clients will approve the Asset
Allocation Model that will be used in advance after completing an Investment Policy Statement, which
will include a Risk Tolerance Profile. Clients may request that Eaglestone Wealth Advisors, Inc. or its
Sub-Advisors (if any), provide a sample asset allocation model in advance of proceeding with the
investment strategy as determined in the Investment Policy Statement. EagleStone Wealth Advisors,
Inc. or its Sub-Advisors (if any), will then implement the Investment Policy Statement and make
specific investments on behalf of the Client, without having to obtain specific client consent for each
transaction. Any client who elects to utilize this option shall provide written consent for any such
discretionary transactions (i.e. Limited Power of Attorney via an Investment Management Agreement).
EagleStone Wealth Advisors, Inc. and its Sub-Advisors (if any), in using the limited power of attorney,
may decide (i) what securities to trade (ii) when to trade the securities (iii) the quantity of securities to
trade and (iv) at what price to trade the securities. In using discretionary authority, EagleStone will at
all times be subject to its fiduciary duty to do only what is in the best interest of the client. At no time
will EagleStone Wealth Advisors, Inc., or any related person, take actual custody of client assets, other
than as interpreted by the applicable securities laws regarding advisers who directly deduct fees from
clients' accounts.
During the investment selection process, EagleStone will consider various securities so as to seek
superior performance but also to manage investor risk. Generally, portfolios managed by EagleStone
consist of ETFs and no load or load-waived, no transaction fee mutual funds. EagleStone does, in
some cases, purchase other securities such as individual stocks or bonds, certificates of deposit, etc.
In selecting the ETFs and mutual funds, EagleStone will investigate the many characteristics, including
but not limited to: manager tenure, gross expense ratios (including 12b-1 fees), performance,
independent ratings, style drift, investment methodology (quantitative vs. technical vs. fundamental),
net assets, sector weightings, geographic weightings, MPT statistics like R- squared, beta, alpha,
Sharpe ratio & standard deviation, yield, performance relative to peers, performance relative to
benchmarks, performance in a bear market, performance in a bull market, etc. EagleStone will also
monitor fees, i.e. trading costs and execution costs, if applicable. Custodial charges, transaction fees
and other administrative costs will also be taken into consideration and minimized, if possible. There
may be occasions when a fund no longer meets the stated criteria for selection in this portfolio. If, in
our collective judgment, a holding falls out of favor, a replacement holding will be selected.
Charting Analysis - involves the gathering and processing of price and volume pattern information for
a particular security, sector, broad index or commodity. This price and volume pattern information is
analyzed. The resulting pattern and correlation data is used to detect departures from expected
performance and diversification and predict future price movements and trends.
Risk: Our charting analysis may not accurately detect anomalies or predict future price
movements. Current prices of securities may reflect all information known about the security and
day-to-day changes in market prices of securities may follow random patterns and may not be
predictable with any reliable degree of accuracy.
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Technical Analysis - involves studying past price patterns, trends and interrelationships in the
financial markets to assess risk-adjusted performance and predict the direction of both the overall
market and specific securities.
Risk: The risk of market timing based on technical analysis is that our analysis may not accurately
detect anomalies or predict future price movements. Current prices of securities may reflect all
information known about the security and day-to-day changes in market prices of securities may
follow random patterns and may not be predictable with any reliable degree of accuracy.
Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and
trends. Economic/business cycles may not be predictable and may have many fluctuations between
long-term expansions and contractions.
Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the
risk of cyclical analysis is the difficulty in predicting economic trends and consequently the
changing value of securities that would be affected by these changing trends.
Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected
return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected
return, by carefully diversifying the proportions of various assets.
Risk: Market risk is that part of a security's risk that is common to all securities of the same
general class (stocks and bonds) and thus cannot be eliminated by diversification.
Long-Term Purchases - securities purchased with the expectation that the value of those securities
will grow over a relatively long period of time, generally greater than one year.
Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in
the long term, which may not be the case. There is also the risk that the segment of the market
that you are invested in or perhaps just your particular investment will go down over time even if
the overall financial markets advance. Purchasing investments long-term may create an
opportunity cost - "locking-up" assets that may be better utilized in the short term in other
investments.
Short-Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short-
term price fluctuations.
Risk: Using a short-term purchase strategy generally assumes that we can predict how financial
markets will perform in the short term, which may be very difficult and will incur a
disproportionately higher amount of transaction costs compared to long-term trading. There are
many factors that can affect financial market performance in the short term (such as short-term
interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over
longer periods of times.
Margin Transactions - a securities transaction in which an investor borrows money to purchase a
security, in which case the security serves as collateral on the loan.
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Risk: If the value of the shares drops sufficiently, the investor will be required to either deposit
more cash into the account or sell a portion of the stock in order to maintain the margin
requirements of the account. This is known as a "margin call." An investor's overall risk includes
the amount of money invested plus the amount that was loaned to them.
ESG Criteria: At the client's request, we will screen investments for Environmental, Social, and
Governance ("ESG") criteria. The purpose is to seek an additional level of risk management and long
term value by investing in companies that provide a positive impact in the world according to criteria
that assesses the responsibility to all stakeholders including; shareholders, communities, environment,
and the supply chain.
ESG screening has risks including that it may not encompass all environmental, social or governance
issues and that such an approach may not lead to greater portfolio performance.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors.
Your restrictions and guidelines may affect the composition of your portfolio. It is important that you
notify us immediately with respect to any material changes to your financial circumstances,
including for example, a change in your current or expected income level, tax circumstances, or
employment status.
Cash Management
We manage cash balances in your account based on the yield, and the financial soundness of the
money markets and other short term instruments.
Tax Considerations
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your
custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis
of your investments. You are responsible for contacting your tax advisor to determine if this accounting
method is the right choice for you. If your tax advisor believes another accounting method is more
advantageous, provide written notice to our firm immediately and we will alert your account custodian
of your individually selected accounting method. Decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Other Risk Considerations
When evaluating risk, financial loss may be viewed differently by each client and may depend on many
different risks, each of which may affect the probability and magnitude of any potential losses. The
following risks may not be all-inclusive, but should be considered carefully by a prospective client
before retaining our services.
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Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to
high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible
to sell the investment at all.
Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and
sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair
or erase the value of an issuer's securities held by a client.
Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to
changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and
may reduce the purchasing power of a client's future interest payments and principal. Inflation also
generally leads to higher interest rates which may cause the value of many types of fixed income
investments to decline.
Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an
unforeseen event, for example, the loss of your job. This may force you to sell investments that you
were expecting to hold for the long term. If you must sell at a time that the markets are down, you may
lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for
people who are retired, or are nearing retirement.
Recommendation of Particular Types of Securities
We recommend various types of securities and we do not primarily recommend one particular type of
security over another since each client has different needs and different tolerance for risk. Each type of
security has its own unique set of risks associated with it and it would not be possible to list here all of
the specific risks of every type of investment. Even within the same type of investment, risks can vary
widely. However, in very general terms, the higher the anticipated return of an investment, the higher
the risk of loss associated with the investment. A description of the types of securities we may
recommend to you and some of their inherent risks are provided below.
Money Market Funds: A money market fund is technically a security. The fund managers attempt to
keep the share price constant at $1/share. However, there is no guarantee that the share price will stay
at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S.
Securities and Exchange Commission ("SEC") notes that "While investor losses in money market
funds have been rare, they are possible." In return for this risk, you should earn a greater return on
your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured
savings account (money market funds are not FDIC insured). Next, money market fund rates are
variable. In other words, you do not know how much you will earn on your investment next month. The
rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes
down and you earn less than you expected to earn, you may end up needing more cash. A final risk
you are taking with money market funds has to do with inflation. Because money market funds are
considered to be safer than other investments like stocks, long-term average returns on money market
funds tend to be less than long term average returns on riskier investments. Over long periods of time,
inflation can eat away at your returns.
Certificates of Deposit: Certificates of deposit ("CD") are generally a safe type of investment since
they are insured by the Federal Deposit Insurance Company ("FDIC") up to a certain amount.
However, because the returns are generally low, there is risk that inflation outpaces the return of the
CD. Certain CDs are traded in the marketplace and not purchased directly from a banking institution. In
addition to trading risk, when CDs are purchased at a premium, the premium is not covered by the
FDIC.
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Municipal Securities: Municipal securities, while generally thought of as safe, can have significant
risks associated with them including, but not limited to: the credit worthiness of the governmental entity
that issues the bond; the stability of the revenue stream that is used to pay the interest to the
bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same amount of interest or yield to maturity.
Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities,
but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer
might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to
maturity. When a bond is called, it may not be possible to replace it with a bond of equal character
paying the same rate of return.
Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as
"equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the
company issuing it. However, stock prices can be affected by many other factors including, but not
limited to the class of stock (for example, preferred or common); the health of the market sector of the
issuing company; and the overall health of the economy. In general, larger, better established
companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the
mere size of an issuer is not, by itself, an indicator of the safety of the investment.
Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are
professionally managed collective investment systems that pool money from many investors and invest
in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any
combination thereof. The fund will have a manager that trades the fund's investments in accordance
with the fund's investment objective. While mutual funds and ETFs generally provide diversification,
risks can be significantly increased if the fund is concentrated in a particular sector of the market,
primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a
significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing
the fund with different types of securities. ETFs differ from mutual funds since they can be bought and
sold throughout the day like stock and their price can fluctuate throughout the day. The returns on
mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual
funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds
do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open
end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas
"closed end" funds have a fixed number of shares to sell which can limit their availability to new
investors.
ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to
cause the ETF's performance to match that of its Underlying Index or other benchmark, which may
negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track
the performance of their Underlying Indices or benchmarks on a daily basis, mathematical
compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an
ETF may not have investment exposure to all of the securities included in its Underlying Index, or its
weighting of investment exposure to such securities may vary from that of the Underlying Index. Some
ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but
which are expected to yield similar performance.
Closed-End Interval Funds: An interval fund is a type of closed-end fund that is not listed on an
exchange that periodically offers to repurchase a limited percentage of outstanding shares, as defined
in its prospectus, from its shareholders. Interval funds can provide investors with access to less liquid
investment strategies than open-end funds in an attempt to enhance risk-adjusted returns and can be
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used as an alternative source of return and/or income. Interval funds are legally classified as closed-
end funds, and are registered under the Investment Company Act of 1940 and typically subject to the
Securities Act of 1933 and the Securities Exchange Act of 1934. Interval funds can expose investors
to liquidity risk, and that risk is greater in funds that invest in securities of companies with smaller
market capitalizations, derivatives or securities with substantial market and/or credit risk. Even though
interval funds make periodic offers to repurchase a portion of outstanding shares, investors should
consider interval fund shares to be an illiquid investment. There is no guarantee that investors will be
able to sell interval fund shares at any given time or in the quantity that they desire.
Before investing in an interval fund, investors should be knowledgeable to the unique risks associated
with the investment vehicle and carefully read all of the fund's available information, including its
prospectus and most recent shareholder report.
Leveraged Exchange Traded Funds:
Leveraged Exchange Traded Funds ("Leveraged ETFs" or "L-ETF") seeks investment results for a
single day only, not for longer periods. A "single day" is measured from the time the L-ETF calculates
its net asset value ("NAV") to the time of the L-ETF's next NAV calculation. The return of the L-ETF for
periods longer than a single day will be the result of each day's returns compounded over the period,
which will very likely differ from multiplying the return by the stated leverage for that period. For periods
longer than a single day, the L-ETF will lose money when the level of the Index is flat, and it is possible
that the L-ETF will lose money even if the level of the Index rises. Longer holding periods, higher index
volatility and greater leverage both exacerbate the impact of compounding on an investor's returns.
During periods of higher Index volatility, the volatility of the Index may affect the L-ETF's return as
much as or more than the return of the Index. Leveraged ETFs are different from most exchange-
traded funds in that they seek leveraged returns relative to the applicable index and only on a daily
basis. The L-ETF also is riskier than similarly benchmarked exchange-traded funds that do not use
leverage. Accordingly, the L-ETF may not be suitable for all investors and should be used only by
knowledgeable investors who understand the potential consequences of seeking daily leveraged
investment results.
Leveraged ETF Leveraged Risk: The L-ETF obtains investment exposure in excess of its assets
in seeking to achieve its investment objective — a form of leverage — and will lose more money in
market environments adverse to its daily objective than a similar fund that does not employ such
leverage. The use of such leverage could result in the total loss of an investor's investment. For
example: a 2X fund will have a multiplier of two times (2x) the Index. A single day movement in the
Index approaching 50% at any point in the day could result in the total loss of a shareholder's
investment if that movement is contrary to the investment objective of the L-ETF, even if the Index
subsequently moves in an opposite direction, eliminating all or a portion of the earlier movement.
This would be the case with any such single day movements in the Index, even if the Index
maintains a level greater than zero at all times.
Leveraged ETF Compounding Risk: Compounding affects all investments, but has a more
significant impact on a leveraged fund. Particularly during periods of higher Index volatility,
compounding will cause results for periods longer than a single day to vary from the stated
multiplier of the return of the Index. This effect becomes more pronounced as volatility increases.
Leveraged ETF Use of Derivatives: The L-ETF obtains investment exposure through derivatives.
Investing in derivatives may be considered aggressive and may expose the L-ETF to greater risks
than investing directly in the reference asset(s) underlying those derivatives. These risks include
counterparty risk, liquidity risk and increased correlation risk (each as discussed below). When the
L-ETF uses derivatives, there may be imperfect correlation between the value of the reference
asset(s) and the derivative, which may prevent the L-ETF from achieving its investment objective.
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Because derivatives often require only a limited initial investment, the use of derivatives also may
expose the L-ETF to losses in excess of those amounts initially invested. The L-ETF may use a
combination of swaps on the Index and swaps on an ETF that is designed to track the
performance of the Index. The performance of an ETF may not track the performance of the Index
due to embedded costs and other factors. Thus, to the extent the L-ETF invests in swaps that use
an ETF as the reference asset, the L-ETF may be subject to greater correlation risk and may not
achieve as high a degree of correlation with the Index as it would if the L-ETF only used swaps on
the Index. Moreover, with respect to the use of swap agreements, if the Index has a dramatic
intraday move that causes a material decline in the L-ETF's net assets, the terms of a swap
agreement between the L-ETF and its counterparty may permit the counterparty to immediately
close out the transaction with the L-ETF. In that event, the L-ETF may be unable to enter into
another swap agreement or invest in other derivatives to achieve the desired exposure consistent
with the L-ETF's investment objective. This, in turn, may prevent the L-ETF from achieving its
investment objective, even if the Index reverses all or a portion of its intraday move by the end of
the day. Any costs associated with using derivatives will also have the effect of lowering the L-
ETF's return.
Commercial Paper: Commercial paper ("CP") is, in most cases, an unsecured promissory note that is
issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer
may default. There is less risk in asset based commercial paper (ABCP). The difference between
ABCP and CP is that instead of being an unsecured promissory note representing an obligation of the
issuing company, ABCP is backed by securities. Therefore, the perceived quality of the ABCP
depends on the underlying securities.
Variable Annuities: A variable annuity is a form of insurance where the seller or issuer (typically an
insurance company) makes a series of future payments to a buyer (annuitant) in exchange for the
immediate payment of a lump sum (single-payment annuity) or a series of regular payments (regular-
payment annuity). The payment stream from the issuer to the annuitant has an unknown duration
based principally upon the date of death of the annuitant. At this point, the contract will terminate and
the remainder of the funds accumulated forfeited unless there are other annuitants or beneficiaries in
the contract. Annuities can be purchased to provide an income during retirement. Unlike fixed annuities
that make payments in fixed amounts or in amounts that increase by a fixed percentage, variable
annuities pay amounts that vary according to the performance of a specified set of investments,
typically bond and equity mutual funds. Many variable annuities typically impose asset-based sales
charges or surrender charges for withdrawals within a specified period. Variable annuities may impose
a variety of fees and expenses, in addition to sales and surrender charges, such as mortality and
expense risk charges; administrative fees; underlying fund expenses; and charges for special features,
all of which can reduce the return. Earnings in a variable annuity do not provide all the tax advantages
of 401(k)s and other before-tax retirement plans. Once the investor starts withdrawing money from
their variable annuity, earnings are taxed at the ordinary income rate, rather than at the lower capital
gains rates applied to other non-tax-deferred vehicles which are held for more than one year. Proceeds
of most variable annuities do not receive a "step-up" in cost basis when the owner dies like stocks,
bonds and mutual funds do. Some variable annuities offer "bonus credits." These are usually not free.
In order to fund them, insurance companies typically impose mortality and expense charges and
surrender charge periods. In an exchange of an existing annuity for a new annuity (so-called 1035
exchanges), the new variable annuity may have a lower contract value and a smaller death benefit;
may impose new surrender charges or increase the period of time for which the surrender charge
applies; may have higher annual fees; and provide another commission for the broker.
Real Estate: Real estate is increasingly being used as part of a long-term core strategy due to
increased market efficiency and increasing concerns about the future long-term variability of stock and
bond returns. In fact, real estate is known for its ability to serve as a portfolio diversifier and inflation
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hedge. However, the asset class still bears a considerable amount of market risk. Real estate has
shown itself to be very cyclical, somewhat mirroring the ups and downs of the overall economy. In
addition to employment and demographic changes, real estate is also influenced by changes in
interest rates and the credit markets, which affect the demand and supply of capital and thus real
estate values. Along with changes in market fundamentals, investors wishing to add real estate as part
of their core investment portfolios need to look for property concentrations by area or by property type.
Because property returns are directly affected by local market basics, real estate portfolios that are too
heavily concentrated in one area or property type can lose their risk mitigation attributes and bear
additional risk by being too influenced by local or sector market changes.
Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which
invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate
income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock
exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually
pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip
into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012,
the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts
periodically. The credit markets are no longer frozen, but banks are demanding, and getting, harsher
terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay
debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can
affect the REIT's value and dividends.
Limited Partnerships: A limited partnership is a financial affiliation that includes at least one general
partner and a number of limited partners. The partnership invests in a venture, such as real estate
development or oil exploration, for financial gain. The general partner has management authority and
unlimited liability. The general partner runs the business and, in the event of bankruptcy, is responsible
for all debts not paid or discharged. The limited partners have no management authority and their
liability is limited to the amount of their capital commitment. Profits are divided between general and
limited partners according to an arrangement formed at the creation of the partnership. The range of
risks is dependent on the nature of the partnership and disclosed in the offering documents if privately
placed. Publicly traded limited partnership have similar risk attributes to equities. However, like
privately placed limited partnerships their tax treatment is under a different tax regime from equities.
You should speak to your tax adviser in regard to their tax treatment.
Structured Products: A structured product, also known as a market-linked product, is generally a pre-
packaged investment strategy based on derivatives, such as a single security, a basket of securities,
options, indices, commodities, debt issuances, and/or foreign currencies, and to a lesser extent,
swaps. Structured products are usually issued by investment banks or affiliates thereof. They have a
fixed maturity, and have two components: a note and a derivative. The derivative component is often
an option. The note provides for periodic interest payments to the investor at a predetermined rate, and
the derivative component provides for the payment at maturity. Some products use the derivative
component as a put option written by the investor that gives the buyer of the put option the right to sell
to the investor the security or securities at a predetermined price. Other products use the derivative
component to provide for a call option written by the investor that gives the buyer of the call option the
right to buy the security or securities from the investor at a predetermined price. A feature of some
structured products is a "principal guarantee" function, which offers protection of principal if held to
maturity. However, these products are not always Federal Deposit Insurance Corporation insured; they
may only be insured by the issuer, and thus have the potential for loss of principal in the case of a
liquidity crisis, or other solvency problems with the issuing company. Investing in structured products
involves a number of risks including but not limited to: fluctuations in the price, level or yield of
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underlying instruments, interest rates, currency values and credit quality; substantial loss of principal;
limits on participation in any appreciation of the underlying instrument; limited liquidity; credit risk of the
issuer; conflicts of interest; and other events that are difficult to predict.
Private Placements: A private placement (non-public offering) is an illiquid security sold to qualified
investors and is not publicly traded nor registered with the Securities and Exchange Commission.
Risk: Private placements generally carry a higher degree of risk due to illiquidity. Most securities
that are acquired in a private placement will be restricted securities and must be held for an
extended amount of time and therefore cannot be sold easily. The range of risks is dependent on
the nature of the partnership and are disclosed in the offering documents.
Disciplinary Information
On July 26, 2023, EagleStone Wealth Advisors, Inc., James Warring, and Tarun Mehta settled a legal
action in the State of Maryland where client alleged fraud, conversion and breach of fiduciary duty.
This action was settled for a total amount of $5,000,000. In order to resolve a disputed claim, and not
as an admission of any fault or liability, EWA agreed to return collected fees to claimant in the amount
of$1,161,388. The remainder of the settlement amount is attributable to other entities named and
included in the claim.
In July 2025, an IAR associated with our firm was permitted to resign during the course of a regulatory
investigation conducted by the U.S. Securities and Exchange Commission (SEC). The SEC
investigation concerned allegations related to fiduciary duty, fee practices, and the management of
client accounts. A related civil action brought by a former client was resolved through a settlement
agreement without any admission of fault or liability by the individual or the firm. Although EagleStone
was named in the civil action, it is not subject to any disciplinary proceedings as a result of the
regulatory investigation. The SEC is expected to conclude its investigation through a settlement
agreement with the individual, and no charges are anticipated against the firm or any other EagleStone
personnel.
On September 8, 2025, the Securities and Exchange Commission ("SEC") issued an Order Instituting
Administrative and Cease-and-Desist Proceedings against James D. Warring, the firm's former CEO
and founder. The SEC found that Mr. Warring knowingly and/or recklessly breached his fiduciary duty
to a client, violating Sections 206(1) and 206(2) of the Investment Advisers Act of 1940. According to
the Order, his conduct included arranging for the client to make and forgive loans to his family
members without adequate disclosure; charging unauthorized and undisclosed fees; and advising the
client to enter into agreements purporting to authorize or waive problematic transactions and fees.
Mr. Warring consented to the entry of the SEC's Order without admitting or denying the SEC's findings.
As part of the SEC's Order, Mr. Warring was barred from the industry, prohibiting future association
with any investment adviser, broker-dealer, or other regulated entity. Mr. Warring was permitted to
resign from the firm shortly before the SEC issued its Order. He has no role at EagleStone, no
involvement in its operations or clients, and is no longer active in the investment advisory industry.
Neither the firm nor any other EagleStone personnel were subject to disciplinary proceedings.
In October 2025, the Maryland Securities Division is expected to enter a Consent Order against James
D. Warring (Case No. 2024-0057) resolving allegations that he violated the antifraud and investment-
advisory provisions of the Maryland Securities Act. The proposed order states that Mr. Warring
recommended that a client make a $350,000 loan to a limited-liability company owned by his mother
and son without disclosing his conflict of interest, failed to disclose material facts concerning the
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transaction, and caused EagleStone Wealth Advisors to charge unauthorized and undisclosed
consulting and advisory fees to that client and a related trust. The Division found that Mr. Warring also
caused invoices to misrepresent assets under management and advisory fees owed. The Maryland
Securities Commissioner determined that this conduct constituted violations of Sections 11-302(a)(1)–
(3), 11-302(c), and 11-306 of the Maryland Securities Act, reflecting fraudulent and unethical practices.
Without admitting or denying the findings, Mr. Warring consented to the entry of the order, waived his
right to a hearing and appeal, and agreed to sanctions including a permanent cease-and-desist,
revocation of his Maryland registrations as an investment-adviser representative (effective August 26,
2025) and agent (effective August 1, 2025), and a permanent bar from the securities and investment-
advisory business in Maryland. He was also assessed a $450,000 civil monetary penalty under Section
11-702, offset by the amount paid under a related SEC Consent Order arising from the same
underlying conduct. The conduct and penalties mirror those of the SEC Order issued on October 8,
2025.
Mr. Warring is also the subject of a FINRA investigation relating to the same underlying conduct.
FINRA has not instituted any formal disciplinary proceeding or issued findings in that matter, and it
remains unclear whether or when FINRA will do so in light of the SEC Order and the sanctions already
imposed for the same conduct. As of the date of this brochure, there is no FINRA proceeding to report.
Mr. Warring has retired from the industry and has no role or affiliation with EagleStone and no
involvement in its operations or clients. The firm itself has not been named as a respondent or subject
to any disciplinary proceeding by the SEC, FINRA, or any state securities authority in connection with
these matters. EagleStone is providing this disclosure because it believes it is material to a client's
evaluation of the firm's advisory business and the integrity of its personnel.
Other Financial Industry Activities and Affiliations
EagleStone Wealth Advisors has entered into an asset purchase agreement with an unaffiliated
registered investment adviser pursuant to which certain client relationships and assets may transition
to that firm over time. Some client transitions remain in process. EagleStone and certain of its
personnel may receive compensation or other consideration in connection with the transaction.
EagleStone is not actively providing advisory services during the transition, but continues to meet its
regulatory and client obligations.
Registrations with Broker-Dealer
Persons providing investment advice on behalf of our firm are registered representatives with Emerson
Equity, a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. See the Fees and Compensation section in this brochure
for more information on the compensation received by registered representatives who are affiliated
with our firm.
Arrangements with Affiliated Entities
EagleStone Tax and Accounting, LLC
We are affiliated with EagleStone Tax and Accounting, LLC ("EagleStone") through common control
and ownership. If you require accounting services, we will recommend that you use the services of our
affiliate. Our advisory services are separate and distinct from the compensation paid to our affiliate for
their services. This affiliated firm is otherwise regulated by the professional organizations to which it
belongs and must comply with the rules of those organizations. These rules may prohibit paying or
receiving referral fees to or from investment advisers that are not members of the same organization.
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On December 1, 2022, EagleStone acquired the firms of Polan & Hollis, LLC, of Rockville, MD, and
Benz Guardia Associates, PC, of Tysons Corner, VA. If you require accounting services, we will
recommend that you use the services of our affiliate. Our advisory services are separate and distinct
from the compensation paid to our affiliate for their services. This affiliated firm is otherwise regulated
by the professional organizations to which it belongs and must comply with the rules of those
organizations. These rules may prohibit paying or receiving referral fees to or from investment advisers
that are not members of the same organization.
Referral arrangements with an affiliated entity present a conflict of interest for us because we may
have a direct or indirect financial incentive to recommend an affiliated firm's services. While we believe
that compensation charged by an affiliated firm is competitive, such compensation may be higher than
fees charged by other firms providing the same or similar services. You are under no obligation to use
the services of any firm we recommend, whether affiliated or otherwise, and may obtain comparable
services and/or lower fees through other firms.
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for persons associated with our
firm. Our goal is to protect your interests at all times and to demonstrate our commitment to our
fiduciary duties of honesty, good faith, and fair dealing with you. All persons associated with our firm
are expected to adhere strictly to these guidelines. Persons associated with our firm are also required
to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies
reasonably designed to prevent the misuse or dissemination of material, non-public information about
you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any persons associated with our firm has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Brokerage Practices
While you are free to choose any broker-dealer or other service provider as your custodian, we
recommend that you establish an account with Emerson Equity LLC, a brokerage firm with which we
have an existing relationship. Such relationships may include benefits provided to our firm, including
but not limited to market information and administrative services that help our firm manage your
account(s). We believe that the recommended broker-dealers provide quality execution services for
our clients at competitive prices. Price is not the sole factor we consider in evaluating best execution.
We also consider the quality of the brokerage services provided by recommended broker-dealers,
including the value of the firm's reputation, execution capabilities, commission rates, and
responsiveness to our clients and our firm. In recognition of the value of the services recommended
broker-dealers provide, you may pay higher commissions and/or trading costs than those that may be
available elsewhere.
Research and Other Soft Dollar Benefits
We do not have any soft dollar arrangements.
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Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products are in addition to any benefits or research we
pay for with soft dollars, and may include financial publications, information about particular companies
and industries, research software, and other products or services that provide lawful and appropriate
assistance to our firm in the performance of our investment decision-making responsibilities. Such
research products and services are provided to all investment advisers that utilize the institutional
services platforms of these firms, and are not considered to be paid for with soft dollars. However, you
should be aware that the commissions charged by a particular broker for a particular transaction or set
of transactions may be greater than the amounts another broker who did not provide research services
or products might charge.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
Persons providing investment advice on behalf of our firm who are registered representatives of
Emerson Equity, LLC ("Emerson") will recommend Emerson to you for brokerage services. These
individuals are subject to applicable rules that restrict them from conducting securities transactions
away from Emerson unless Emerson provides the representative with written authorization to do so.
Therefore, these individuals are generally limited to conducting securities transactions through
Emerson. It may be the case that Emerson charges higher transactions costs and/or custodial fees
than another broker charges for the same types of services. If transactions are executed though
Emerson, these individuals (in their separate capacities as registered representatives of Emerson) may
earn commission-based compensation as result of placing the recommended securities transactions
through Emerson. This practice presents a conflict of interest because these registered representatives
have an incentive to effect securities transactions for the purpose of generating commissions rather
than solely based on your needs. You may utilize the broker-dealer of your choice and have no
obligation to purchase or sell securities through such broker as we recommend. However, if you do not
use Emerson, we may not be able to accept your account. See the Fees and Compensation section in
this brochure for more information on the compensation received by registered representatives who
are affiliated with our firm.
Aggregated Trades
We do not combine multiple orders for shares of the same securities purchased for advisory accounts
we manage (the practice of combining multiple orders for shares of the same securities is commonly
referred to as "aggregated trading"). Accordingly, you may pay different prices for the same securities
transactions than other clients pay. Furthermore, we may not be able to buy and sell the same
quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs
than other clients.
Review of Accounts
We will not provide you with regular written reports. You will receive trade confirmations and monthly or
quarterly statements from your account custodian(s).
While reviews and updates to the financial plan are not part of the contracted services, at your request
we will review your financial plan to determine if the investment advice provided is consistent with your
investment needs and objectives. We will also update the financial plan at your request. At our sole
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discretion, reviews and updates may be subject to our then-current hourly rate. If you implement the
financial planning advice provided by our firm, you will receive trade confirmations and monthly or
quarterly statements from relevant custodians.
While reviews of your investment account(s) are not part of the contracted services, at your request we
will review your investment account(s). Otherwise, we do not review or monitor your investment
account(s) or review statements you receive from any third-party money manager or account
custodian. At your request, we may meet with you and/or your other professionals to discuss asset
allocation, but we will not make recommendations regarding specific investments or provide any
regular written reports to you. At our sole discretion, reviews and meetings may be subject to our then-
current hourly rate.
Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing investment
advice to you nor do we compensate any individual or firm for client referrals.
Refer to the Brokerage Practices section above for disclosures on research and other benefits we may
receive resulting from our relationship with your account custodian.
Custody
Debiting of Fees
Your independent custodian will directly debit your account(s) for the payment of our advisory fees.
This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody
over your funds or securities. We do not have physical custody of any of your funds and/or securities.
In accordance with Rule 206(4)-2 of the Investment Adviser Act of 1940, all funds and securities will be
held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from
the qualified custodian(s) holding your funds and securities at least quarterly. The account statements
from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s)
each billing period. You should carefully review account statements for accuracy.
We will also provide statements to you reflecting the amount of the advisory fee deducted from your
account. You should compare our statements with the statements from your account custodian(s) to
reconcile the information reflected on each statement. If you have a question regarding your account
statement, or if you did not receive a statement from your custodian, contact us immediately at the
telephone number on the cover page of this brochure.
EagleStone Tax and Accounting, LLC
We are affiliated with EagleStone Tax and Accounting, LLC ("EagleStone Tax") through common
control and ownership. If you require accounting services, we will recommend that you use the
services of our affiliate. To the extent that our affiliate has access to funds and securities in client
accounts, EagleStone Tax and Wealth Advisors may be deemed to have custody. EagleStone
identifies client accounts subject to a surprise examination and engages an independent public
accountant to perform a surprise examination on an annual basis as required by the Custody Rule.
The independent public accountant is required to file an ADV-E with the Securities and Exchange
Commission within 120 days of the surprise exam documenting the results of such examination.
Standing Letter of Authorization
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Your account may permit our firm, or persons associated with our firm, to effect wire transfers from
client accounts to one or more third parties designated, in writing, by the client without obtaining written
client consent for each separate or individual transaction, as long as the client has provided us with
written authorization to do so. Such written authorization is known as a Standing Letter of
Authorization.
An adviser with authority to conduct such third party wire transfers has access to the client's assets,
and therefore has custody of the client's assets in any related accounts. However, we do not have to
obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as
long as we meet the following criteria:
1. You provide a written, signed instruction to the qualified custodian that includes the third party's
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from
time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of
funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the address, or
any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the same
address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria.
Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement and the appropriate trading authorization forms.
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Refer to the Advisory
Business section in this brochure for more information on our discretionary management services.
Voting Client Securities
EagleStone Wealth Advisors, Inc. will not vote (by proxy or otherwise) in any matter for which a
shareholder vote is solicited by, or with respect to, issuers of securities beneficially held in the client's
account. With regard to all other matters for which shareholder action is required or solicited with
respect to securities beneficially held by the Client's account such as (i) all matters relating to class
actions, including without limitation, matters relating to opting in or opting out of a class and approval of
class settlements and (ii) bankruptcies or reorganizations. EagleStone Wealth Advisors, Inc.
affirmatively disclaims responsibility for voting (by proxies or otherwise) on such matters and will not
take any action with regard to such matters.
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Financial Information
We have not filed a bankruptcy petition at any time in the past ten years.
Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Additional Information
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets
from your employer's retirement plan and roll the assets over to an individual retirement account
("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our
management, we will charge you an asset based fee as set forth in the agreement you executed with
our firm. This practice presents a conflict of interest because persons providing investment advice on
our behalf have an incentive to recommend a rollover to you for the purpose of generating fee based
compensation rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no
obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also,
current employees can sometimes move assets out of their company plan before they retire or change
jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options
are available, you should consider the costs and benefits of:
1. Leaving the funds in your employer's (former employer's) plan.
2. Moving the funds to a new employer's retirement plan.
3. Cashing out and taking a taxable distribution from the plan.
4. Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage
you to speak with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few
points to consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your
needs or whether you might want to consider other types of investments.
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2. Employer retirement plans generally have a more limited investment menu than IRAs.
3. Employer retirement plans may have unique investment options not available to the public such
as employer securities, or previously closed funds.
4. Your current plan may have lower fees than our fees.
5. If you are interested in investing only in mutual funds, you should understand the cost structure
of the share classes available in your employer's retirement plan and how the costs of those
share classes compare with those available in an IRA.
6. You should understand the various products and services you might take advantage of at an
IRA provider and the potential costs of those products and services.
7. Our strategy may have higher risk than the option(s) provided to you in your plan.
8. Your current plan may also offer financial advice.
9. If you keep your assets titled in a 401k or retirement account, you could potentially delay your
required minimum distribution beyond age 72.
10.Your 401k may offer more liability protection than a rollover IRA; each state may vary.
11.Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies. However, there can be some
exceptions to the general rules so you should consult with an attorney if you are concerned
about protecting your retirement plan assets from creditors.
12.You may be able to take out a loan on your 401k, but not from an IRA.
13.IRA assets can be accessed any time; however, distributions are subject to ordinary income tax
and may also be subject to a 10% early distribution penalty unless they qualify for an exception
such as disability, higher education expenses or the purchase of a home.
14.If you own company stock in your plan, you may be able to liquidate those shares at a lower
capital gains tax rate.
15.Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide
whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment
adviser representative, or call our main number as listed on the cover page of this brochure.
Firm Biographies
Firm Biographies
Education, Business Standards & Professional Certification
EagleStone requires professional staff to hold a Bachelor of Arts, Bachelor of Science, or Bachelor of
Business Administration. EagleStone prefers a Bachelor of Science in Business, Economics, or
Finance or Bachelor of Business Administration. MBA, CPA, CFA, CFP, ChFC, PFS, JD are preferred,
but not required. Advisor requires appropriate securities licenses including, but not limited to the
Series 6, 7, 63, 65, or 66, as required by law.
Tarun Mehta, JD/MBA- President & Chief Compliance Officer
Tarun Mehta is the President & Chief Compliance Officer and Chief Operating Officer for EagleStone
Wealth Advisors. His date of birth is December 14, 1976. As CCO, Tarun manages the firm's
compliance program and requirements as they pertain to the SEC & FINRA and monitors ongoing
regulatory developments in the industry. As President, Tarun oversees the firm's operations and
business practices. Tarun also acts as the informal in-house counsel to EagleStone Wealth Advisors,
assisting with document/agreement preparation, document review and other legal matters.
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Before joining EagleStone in 2008, Tarun was CEO of Outsource Compliance Resources, LLC
("OCR"), a SEC/FINRA Compliance consulting and technology/operations consulting firm. Previous
posts held by Tarun include Financial Analyst and Chief Compliance Officer with R&M Wealth
Management Services, LLC and Due Diligence Analyst at H. Beck, Inc, in Rockville, MD.
Prior to founding OCR, Mr. Mehta was a Financial Analyst and Chief Compliance Officer with R&M
Wealth Management Services, LLC from October 2005 through February 2007. In that role, Mr. Mehta
managed portfolio allocations, daily operations of the firm, prepared and managed financial statements
and data for the firm, conducted due diligence on a variety of investment vehicles (i.e. variable
annuities, fixed index annuities, REITs, Oil & Gas Limited Partnership Programs, mutual fund
platforms, 1031 tax deferred exchange programs, etc.) amongst a variety of other tasks.
From April 2004 to October 2005, Mr. Mehta was a Due Diligence Analyst at H. Beck, Inc., an
independent broker dealer in Rockville, MD. H. Beck, Inc. is perennially included in the Top 50
Independent Broker Dealers as published by Investment News magazine. As a Due Diligence Analyst,
Mr. Mehta reviewed several hundred public and private offerings similar to the programs he continued
reviewing while at R&M Wealth Management Services, LLC. Mr. Mehta was the primary contact to a
registered representative base of 500+ individuals and played an integral part in information
distribution and assisting the registered representative base with financial planning and investment
management issues for their clients.
Tarun was raised and educated in New York. He attended Bronx High School of Science, graduated
cum laude with a BS degree in Psychology from City University of New York (CUNY) – Brooklyn
College, and earned a dual JD/MBA from Fordham University.
Education, Professional Designations and Licenses
• Fordham University, JD/MBA, 2001 and 2002
• City University of New York (CUNY) - Brooklyn College, B.S. in Psychology, cum laude, 1997
• Bronx High School of Science, 1994
Olac Pallan - Director of Investments & Portfolio Management
Olac Pallan heads the Investment Committee for Eaglestone Wealth Advisors, which he joined in
2023. He has worked as a Portfolio Manager at Deutsche Bank and the Royal Bank of Canada, and
as a Vice President at JP Morgan and BBVA. Olac graduated from Intituto Tecnologico Autonomo de
Mexico with a B.A. in Economics, and from New York University with a Master of Arts in Applied
Economics.
Kevin C. Moody – Senior Wealth Advisor
Kevin Moody joined the EagleStone team in January 2022. As a Senior Wealth Advisor, Kevin assists
existing and new clients with financial planning, investment management, and long-term goal
attainment. He is a key member in aiding our clients with making the most of their resources.
Kevin was born and raised in Phoenix, Arizona, and moved to Maryland in 2017. He attended Arizona
State University, where he earned a bachelor's degree in History and Education. Kevin joined the
EagleStone team from Bank of America Merrill Lynch where he spent several years advising clients on
goals-based, outcome driven planning solutions. Prior to this he was with JP Morgan Chase where he
spent his time assisting clients in a variety of facets of their mortgage needs.
Daniel "DJ" Reeves – Junior Financial Analyst/Customer Service Associate
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Daniel "DJ" Reeves joined EagleStone as part of the wealth management team in December 2020. As
Junior Financial Analyst and Customer Service Associate, DJ works with supporting our team of
advisors in servicing our clients.
DJ grew up in Dallas, TX, before moving to Ashton, MD where he attended the University of Maryland
and received a bachelor's in Economics. While at UMD he played on the university's Men's Soccer
team and acted as the designated representative for the Student Athlete Advisory Committee.
A lifetime athlete who prefers to stay busy, DJ continues to stay active in sports and spends any extra
time he can with his friends.
Laura Cinnamon - Administrative Assistant & Bookkeeper
Laura Cinnamon joined EagleStone in April of 2019 as an Administrative Assistant & Bookkeeper. Her
date of birth is January 17, 1983. Laura assists in office administration, event planning, accounting &
bookkeeping. Prior to joining EagleStone, Laura provided bookkeeping services to a private medical
practice.
Laura attended the University of Maryland and graduated with a Bachelor of Arts in Communications
with a focus in Rhetoric & Political Communications. She later obtained her Master's degree in Health
Communications at Tufts University & Emerson College in Boston.
During her time in school, Laura was a participant in various artistic programs, such as theater, music
and dance.
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