Overview
- Headquarters
- Raleigh, NC
- Total Firm Assets
- $112 million
- Average High-Net-Worth Client Portfolio Size
- $7.3 million
- Stated Minimum Account Size
- $100,000
Fee Disclosure
EVERGREEN WEALTH ADVISORS CORPORATION - FORM ADV PART 2A & 2B
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $1,000,000 | 0.39% |
| $1,000,001 | $5,000,000 | 0.29% |
| $5,000,001 | and above | 0.19% |
Estimated Annual Advisory Fees
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $3,900 | 0.39% |
| $5 million | $15,500 | 0.31% |
| $10 million | $25,000 | 0.25% |
| $50 million | $101,000 | 0.20% |
| $100 million | $196,000 | 0.20% |
Actual fees may vary; other investment costs may apply.
Clients
- High-Net-Worth Share of Firm Assets
- 51.95%
- Number of High-Net-Worth Clients
- 8
- Total Client Accounts
- 357
- Discretionary Accounts
- 357
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 326535
Additional Brochure: EVERGREEN WEALTH ADVISORS CORPORATION - FORM ADV PART 2A & 2B (2026-09-16)
View Document Text
Part 2A of Form ADV Brochure
for:
Evergreen Wealth Advisors
www.evergreenwealth.com
Office Addresses:
1 Glenwood Ave.,
Office 04-113
Raleigh, NC 27603
120 NE 27th St.,
Suite 100,
Miami, FL 33137
Telephone:
+1 (888) 884-0557
Mailing Address:
5540 Centerview Dr., Ste 204
PMB #48153
Raleigh, NC 27606
September 16, 2026
This Brochure provides information about the qualifications and business practices of
Evergreen Wealth Advisors Corporation (“Evergreen Wealth Advisors” or “Evergreen” or the
“Advisor”). If you have any questions about the contents of this Brochure, please contact the
Advisor at the telephone number or addresses listed above. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority.
Evergreen is a registered investment adviser with the SEC. Registration of an investment
adviser does not imply any certain level of skill or training.
Additional information about Evergreen is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Form ADV Part 2A
Evergreen Wealth Advisors
Item 2 – Material Changes
This Brochure provides Clients with a summary of Evergreen’s advisory services and fees, certain business
practices and policies, professionals, as well as actual or potential conflicts of interest, among other things. This
Item is used to provide the Clients (as defined below) with a summary of new and/or updated information; the
Advisor will inform Clients of the revision(s) based on the nature of the information as follows.
1. Annual Update: The Advisor is required to update certain information at least annually, within 90 days of
the Advisor’s fiscal year end (“FYE”) of December 31. The Advisor will provide Clients with either a
summary of the revised information with an offer to deliver the full revised Brochure within 120 days of the
Advisor’s FYE or the Advisor will provide each Client with a revised Brochure with a summary of those
changes in this Item.
2. Material Changes: Should a material change in the Advisor’s operations occur, depending on its nature the
Advisor will promptly communicate this change to Clients (and it will be summarized in this Item).
This Brochure is being updated as part of an other than annual amendment. The following changes were made
to this Brochure:
● Evergreen has moved its Raleigh office location and its new address is reflected above
●
Item 4 – Advisory Business: Added description of new service, Evergreen.ai, a free self-service Artificial
Intelligence (“AI”) platform offered by Evergreen Wealth Advisors that provides general education,
illustrations and calculators to all Users and provides personalized advice to Registered Users who share
sufficient information about their finances.
●
Item 5 – Fees and Compensation: Added disclosure that Evergreen.ai is free, and the related conflict of
interest from Evergreen's incentive to convert users into fee-paying Clients.
●
Item 7 – Types of Clients: Added disclosure that Evergreen.ai has no minimum balance requirement.
●
Item 10 – Other Financial Industry Activities and Affiliations: Updated to reflect that Evergreen.ai is
provided by Evergreen Wealth Advisors, not offered independently by the parent company.
●
Item 14 – Client Referrals and Other Compensation: Removed disclosure regarding compensation paid to
unaffiliated third parties for client leads, as Evergreen no longer engages in this practice.
●
Item 16 – Investment Discretion: Included clarification that Evergreen.ai does not involve discretionary
trading authority.
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Form ADV Part 2A
Evergreen Wealth Advisors
Item 3 – Table of Contents
Item 2 – Material Changes...........................................................................................................................1
Item 3 – Table of Contents.......................................................................................................................... 2
Item 4 – Advisory Business........................................................................................................................ 3
Item 5 – Fees and Compensation............................................................................................................... 6
Item 6 – Performance-Based Fees and Side-By-Side Management........................................................8
Item 7 – Types of Clients............................................................................................................................. 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss................................................ 8
Item 9 – Disciplinary Information............................................................................................................. 14
Item 10 – Other Financial Industry Activities and Affiliations............................................................... 14
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading..... 15
Item 12 – Brokerage Practices..................................................................................................................16
Item 13 – Review of Accounts.................................................................................................................. 17
Item 14 – Client Referrals and Other Compensation.............................................................................. 17
Item 15 – Custody...................................................................................................................................... 18
Item 16 – Investment Discretion............................................................................................................... 18
Item 17 – Voting Client Securities............................................................................................................ 18
Item 18 – Financial Information................................................................................................................ 19
Separate Supplements:
Part 2A of Form ADV Wrap Fee Brochure Supplement
Part 2B of Form ADV Brochure Supplement
Part 2B of Form ADV Brochure Supplement - Appendix 1
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Form ADV Part 2A
Evergreen Wealth Advisors
Item 4 – Advisory Business
A.
Description of the Advisory Firm
Evergreen Wealth Advisors (“Evergreen” or the “Advisor”) is a Delaware corporation and is a wholly owned
subsidiary of Evergreen Wealth Corporation. The Advisor was formed in 2023. Bill Harris, Chief Executive
Officer, is the controlling owner of the Advisor.
Evergreen is an investment adviser registered with the SEC. Evergreen provides digital wealth advisory
services including investment advisory and portfolio management services to individuals, high-net-worth
individuals, and corporations.
Evergreen offers two services: Evergreen.ai, an artificial intelligence service available to the public that
provides general financial education, illustrations, and calculators, and personalized financial advice to
Registered Users who share sufficient information about their finances (“Evergreen.ai”); and the Evergreen
Wrap Fee Program (the "Program"), under which Evergreen manages Client investments on a fully
discretionary basis. For Clients of the Program, Evergreen assesses each Client's financial situation and risk
profile, then builds and manages a customized portfolio using tax-focused investment strategies.
Evergreen Wealth Advisors' parent company, Evergreen Wealth Corporation, provides technology,
marketing, and administrative support to Evergreen Wealth Advisors.
B.
Types of Advisory Services
Evergreen Wealth Advisors provides the Program to Clients (each a “Client” and collectively the “Clients”) on
a fully discretionary basis. Clients who enter into an Evergreen Investment Advisory Agreement will have
access to Evergreen’s Investment Accounts as defined below (“Investment Accounts”) and Financial
Planning assistance. Evergreen also offers access to charitable giving programs through unaffiliated third
parties. The Program imposes a minimum relationship amount as noted in Item 7. There is no account
minimum to use Evergreen.ai.
Additionally, Evergreen provides Evergreen.ai, which does not require a Client to enter into an Investment
Advisory Agreement. Evergreen.ai is available to two categories of individuals who have not entered into an
Investment Advisory Agreement: (i) visitors who access Evergreen.ai without creating an account
("Anonymous Users"), and (ii) individuals who create an account with Evergreen.ai ("Registered Users," and
together with Anonymous Users, "Users"). Individuals who enter into an Investment Advisory Agreement
for the Program are "Clients," as defined above.
Evergreen.ai
Evergreen.ai is a self-service digital platform, provided by Evergreen at no charge, offering general financial
education and calculators to all Users. Personalized financial advice, generated by an automated AI system
based on information a User provides and any accounts a Registered User chooses to link, is available to
Registered Users. Anonymous Users receive non-personalized general advice, since Evergreen.ai does not
have access to identifying or account information for Anonymous Users.
Evergreen.ai does not recommend specific securities or provide legal, tax, insurance, or estate planning
advice. It analyzes information only at the time of each inquiry, so a User’s advice can become outdated if
their circumstances, linked accounts, or market conditions change between visits. Users are encouraged to
keep their profile updated and share any changes to their finances.
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Form ADV Part 2A
Evergreen Wealth Advisors
Evergreen.ai uses Artificial Intelligence (“AI”) technology, including large language models (“LLMs”), built
with rules and logic designed by Evergreen Wealth Advisors. Before anything new is added, it undergoes
human design and testing review before deployment, and the advice it generates is subject to ongoing
post-delivery auditing.
Evergreen.ai does not provide the ongoing, discretionary investment management services available under
Evergreen's Investment Advisory Agreement; see Item 5 for fee information applicable to that service.
Investment Accounts
Evergreen provides discretionary investment management services to Clients. Under the Investment
Advisory Agreement, Evergreen has authority to select brokers or dealers to execute securities transactions
for Client Investment Accounts.
Client
investment objectives are established through Evergreen’s risk tolerance and suitability
questionnaire, information provided by the Client, and other communications with the Client. Evergreen
manages portfolios based on each Client’s investment objectives and Evergreen’s investment principles, as
described in Item 8, and provides continuous and regular supervisory or management services for assets
held in Client accounts.
Based on client-provided information and other information obtained by Evergreen, Evergreen determines
and implements an asset allocation for each Client’s portfolio on a discretionary basis. Portfolio rebalancing
is conducted at Evergreen’s discretion to manage drift from target allocations based on portfolio drift, cash
activity, tax optimization opportunities, or changes in Client circumstances.
Although Evergreen generally earns advisory fees on assets invested in Investment Accounts, Evergreen has
a financial incentive to recommend that Clients allocate available cash to investment portfolios. This creates
a conflict of interest, which Evergreen addresses through its fiduciary duty and by considering each Client’s
objectives, circumstances, and instructions.
Financial Information and Planning
Evergreen provides financial planning and educational information on investment, tax, and other financial
topics at a Client's request through its Advisors. Advisors provide personalized financial planning tailored to
a Client's individual circumstances, and Evergreen uses technology and third-party resources in preparing
and delivering certain communications.
Evergreen also makes financial planning and educational information available on a self-service basis
through Evergreen.ai, which is available to Anonymous Users, Registered Users, and Clients of Evergreen
Wealth Advisors. Evergreen.ai provides personalized financial advice based on the financial information a
registered user shares and any accounts they choose to link, rather than through direct interaction with an
Advisor.
Evergreen provides tax-aware investment management services, including tax-loss harvesting, asset
location, gain deferral, and use of tax-advantaged and tax-exempt securities. Clients should consult their tax
preparer, accountant, or attorney regarding such matters.
Donor Advised Funding
Evergreen facilitates access to donor-advised fund (“DAF”) accounts through unaffiliated third parties to
assist Clients with charitable giving and related tax considerations. Clients can contribute cash or eligible
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Form ADV Part 2A
Evergreen Wealth Advisors
securities to a DAF account and may be eligible for tax benefits in the year of contribution. Once accepted,
contributions are irrevocable, non-refundable, and become the property of the DAF sponsor.
Evergreen receives no compensation or benefits related to DAF arrangements. If a Client terminates the
advisory relationship while a DAF allocation is in place, Evergreen will prorate the final month’s advisory
fee, and the Client will be responsible for any DAF-related fees thereafter.
Evergreen does not provide tax, legal, or accounting advice. Clients should review the DAF sponsor’s terms
and consult their tax, legal, and accounting advisers before participating.
C.
Client Tailored Services and Client Imposed Restrictions
The Program is tailored based on each Client’s investment objectives, which are established through
Evergreen’s risk tolerance and suitability questionnaire, information provided by the Client, and other
communications with the Client. Clients may impose reasonable restrictions on Evergreen’s management of
their accounts. If a requested restriction is fundamentally inconsistent with Evergreen’s recommended
allocation, Evergreen reserves the right to reject a new Client account or terminate an existing Client.
D.
Wrap Fee Programs
Participation in the Program is required for all Evergreen Clients. Clients pay a single management fee that
covers the investment management services provided by Evergreen, as well as the brokerage and
transaction costs associated with securities transactions in Client accounts. The Wrap Fee is calculated as a
percentage of assets under management (“AUM”) in the Client’s Investment Accounts and varies based on
asset type, relationship size, and any promotional or negotiated reductions. Brokerage services for the
Program are provided through Evergreen’s Clearing Brokers. Additional information regarding Program
fees including a description of services included in the Wrap Fee, is provided in the Wrap Fee Program
Brochure and Item 5.
E.
Assets Under Management
As of December 31, 2025, Evergreen has $112,481,708 of assets under management on a discretionary basis
and $0 of Client assets on a non-discretionary basis.
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Form ADV Part 2A
Evergreen Wealth Advisors
Item 5 – Fees and Compensation
The specific manner in which Evergreen charges fees is established in the Investment Advisory Agreement.
The fees applicable to each service are described below.
A.
Advisory Fees and Compensation
Evergreen.ai is provided at no additional charge to Users. Evergreen has an incentive to use Evergreen.ai to
encourage Users to become Clients and enroll in the Program. This creates a conflict of interest, which
Evergreen addresses through its fiduciary duty to ensure that guidance provided through Evergreen.ai serves
the User's best interest independent of whether it results in the User becoming a Client.
Evergreen provides fully discretionary investment management services under the Program. Under the
Program, Clients pay a single monthly management fee based on assets held in their Investment Accounts.
This fee covers investment management services as well as applicable securities transaction fees, custodial
costs, and other administrative expenses related to the management of Client accounts. Evergreen.ai is not
included in, or covered by, the Wrap Fee, but remains available at no additional charge to Program
participants and non-participants alike.
The Wrap Fee charged by Evergreen may be more or less expensive than a separate advisory and brokerage
fee arrangement at other financial institutions, depending on the total assets under management and the
volume of trading in the account. Clients who trade infrequently may pay more under the Wrap Fee
arrangement than they would under a separately structured fee arrangement. The Wrap Fee is asset-based,
meaning the more assets held in a Client's account, the more the Client will pay in fees. This creates an
incentive for Evergreen to encourage Clients to increase the assets in their accounts. Depending on the
frequency and volume of trades, Evergreen receives all, a portion, or none of the Wrap Fee as compensation
for the Program.
Fees are assessed monthly based on the average daily balance of assets under management during the billing
period, including any cash and cash equivalents held within the portfolio. The applicable fee rate is
determined by aggregating total assets across all of a Client's Investment Accounts, as follows:
Management Fee Based on Account Type(s) Held by Client
Account Type
Value of Assets
Monthly AUM Fee
Annual AUM Fee
First $1,000,000
.0325%
.39%
Investment Accounts
.0242%
.29%
Next $4,000,000
(over $1M up to $5M)
Assets over $5,000,000
.0158%
.19%
*The fees above do not apply to use of Evergreen.ai, which is provided at no charge.
As the Wrap Fee covers transaction costs, Evergreen has an incentive to limit trading in Client accounts.
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Form ADV Part 2A
Evergreen Wealth Advisors
Evergreen addresses this conflict by monitoring account activity to ensure wrap fee arrangements remain in
each Client's best interest.
Evergreen reserves the right, at its sole discretion, to reduce, waive, or negotiate fees for the Program with
individual Clients or groups of Clients. Fee adjustments are based on factors including, but not limited to,
account size, length of relationship, affiliation with the Advisor, or participation in a promotional or
application testing program. As a result, similarly situated Clients may pay different fees.
B.
Payment of Fees
Fees are collected monthly in arrears by direct debit from Client accounts, based on the average daily balance
and the number of days the account was open during the billing period.
Fees are calculated based on the average daily account balance provided by the Clearing Broker. Evergreen
submits fee invoices directly to the Clearing Broker for debit from the appropriate Client account. If
insufficient cash is available, Evergreen can sell securities in the Client's account to generate proceeds
sufficient to satisfy the fee obligation. Evergreen reserves the right to collect Fees from any account held by
the Client.
Fees are billed in accordance with the schedule above and the terms of the Investment Advisory Agreement.
The Clearing Broker does not verify the fee calculation or amount deducted. Clients are responsible for
reviewing fee deductions on their account statements and notifying Evergreen of any suspected errors.
C.
Additional Fees and Expenses
Client accounts invested into ETFs, mutual funds, and money market funds will pay additional Fees and
expenses charged by those investment vehicles, in addition to the Wrap Fee assessed by the Advisor. The
Advisor considers the fees and expenses of any investment vehicle when evaluating its appropriateness for
the Client.
D.
Prorated and Prepayment of Fees
Under no circumstances does Evergreen require or solicit payment of Fees in advance of services rendered.
Either party may terminate the Investment Advisory Agreement pursuant to its terms and conditions.
Evergreen does not charge a termination fee. Accounts initiated or terminated during a billing period will be
charged a prorated Fee based on the number of days the account was open during the month. Upon
termination or full liquidation of any account, any earned, unpaid fees will be due and payable upon
termination.
E.
Compensation and Commission
Evergreen does not accept compensation, commissions, 12b-1 fees, or any other form of economic benefit,
whether direct or indirect, in connection with the sale, recommendation, or placement of securities, mutual
funds, ETFs, or other investment products. Evergreen’s only source of compensation is the advisory fees paid
by clients, as detailed in this Brochure.
7
Form ADV Part 2A
Evergreen Wealth Advisors
Item 6 – Performance-Based Fees and Side-By-Side Management
Evergreen does not charge any performance-based fees (fees based on a share of capital gains or capital
appreciation of the assets of a Client). The Advisor manages multiple Client accounts which creates a conflict
of interest because Evergreen may have an incentive to favor one Client account over another. Evergreen
addresses this conflict through its policies and procedures, which are designed to ensure that investment
decisions and trade allocations are made in a fair and equitable manner across all Client accounts.
Item 7 – Types of Clients
Evergreen.ai is available to Users without a minimum balance requirement.
Evergreen provides the Program to high net worth individuals, individuals, and corporations. Evergreen has a
$100,000 minimum balance requirement to establish a relationship for the Program, which may be changed
at the Firm's discretion. Evergreen reserves the right to decline or discontinue engagements at its sole
discretion if it determines that the relationship is not appropriate or aligned with its service.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A.
Methods of Analysis
Evergreen.ai
Evergreen.ai applies an advice methodology that is developed, tested, and approved prior to deployment.
The methodology is grounded in curated knowledge sources maintained by Evergreen rather than
open-ended model output. Calculations and other figures are produced by deterministic systems using
inputs and constants reviewed and dated by Evergreen subject-matter experts, not generated by the
underlying language model. Evergreen's Advisory team is ultimately responsible for analyzing the platform,
evaluating its advice outputs, and recommending any adjustments to how the system provides advice.
Advice related to investment strategies provided by Evergreen.ai is not a guarantee of future results, and
actual results may differ. See "Artificial Intelligence Risk" below for a discussion of the material risks
associated with Evergreen.ai's methodology.
The Program Investment Accounts
Evergreen provides fully managed investment portfolios tailored to each Client's specific financial situation
and investment objectives. Evergreen’s investment approach begins with a Client assessment to ensure all
portfolios are suitable based upon the Client’s investment objectives. Except in special circumstances,
portfolios are broadly diversified across hundreds of securities, including equities, fixed income
instruments, and cash equivalents. While the specific allocation varies by Client, Evergreen’s investment
strategy typically emphasizes equity holdings to pursue long-term growth objectives and tax optimization
opportunities.
Evergreen's tax optimization strategies are customized to each Client's unique tax situation and may include
tax loss harvesting to offset capital gains, strategic asset location across taxable and tax-advantaged
accounts, systematic gain deferral techniques to minimize current-year tax liabilities, and incorporation of
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Form ADV Part 2A
Evergreen Wealth Advisors
tax-exempt securities such as municipal bonds for Clients in higher tax brackets.
Portfolio rebalancing is conducted at Evergreen’s discretion to manage drift from target allocations based
on portfolio drift, cash activity, tax optimization opportunities, or changes in Client circumstances.
Investing in securities involves risk of loss that Clients should be prepared to bear. The material risks
associated with Evergreen's investment strategies including tax optimization risks are described below.
B.
Investment Strategies
Evergreen.ai
Once a User links accounts and fills out their profile, Evergreen.ai can provide advice upon request related
to a User's investment strategy, such as tax optimization, retirement planning, and portfolio management.
Evergreen.ai doesn't implement any strategy it advises on and Users who act on this advice are responsible
for carrying it out themselves.
The Program Investment Accounts
Evergreen's investment methodology is rooted in Modern Portfolio Theory ("MPT"), a framework for
portfolio construction that seeks to maximize expected returns for a given level of risk through
diversification across a large number of securities and asset classes. Evergreen combines MPT with tax
reduction strategies to construct portfolios that align with each Client's investment objectives while seeking
to reduce current and future income taxes on the Client's portfolio.
Evergreen employs the following strategies in the construction and management of Client Investment
Accounts for the Program:
Custom Portfolio Construction
Evergreen builds custom portfolios based on securities from a diversified index and tailored to individual
Client preferences. This approach maintains exposure to a diversified set of securities while allowing for
customization across a variety of Client-specific factors.
Diversification
Diversification is a cornerstone of Evergreen’s investment approach. Evergreen allocates assets across
various sectors, styles, and asset classes to reduce risk. By spreading investments across a broad set of
securities, Evergreen seeks to mitigate volatility and enhance risk-adjusted returns.
Tax Loss Harvesting
Evergreen attempts to offset capital gains by selling tax lots that have declined in value, which can help
reduce Client’s overall tax liability. Tax loss harvesting is an ongoing process that is employed across the
portfolio and is designed to minimize taxable gains while limiting drift from the target asset allocation.
Gain Deferral
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Form ADV Part 2A
Evergreen Wealth Advisors
To minimize the impact of capital gains taxes, Evergreen generally avoids selling tax lots with unrealized
capital gains (i) for at least twelve months from the date of purchase to avoid short-term capital gains
treatment and (ii) indefinitely unless a sale is required to raise funds or reduce the drift from the target
asset allocation.
Asset Location
Evergreen attempts to place securities into taxable and tax-advantaged accounts in a manner that can
optimize after-tax returns. This typically involves placing capital-gain-assets preferentially in taxable
accounts and ordinary-income-assets preferentially in tax deferred accounts.
Tax Advantaged Accounts
Evergreen assists Clients in the use of tax-advantaged vehicles such as IRAs and Roth accounts when
appropriate. These accounts offer various tax benefits including tax-deferred growth, tax-free growth, or
immediate tax deductions.
Tax Exempt Securities
For Clients in higher tax brackets, Evergreen may recommend tax-exempt Treasury or municipal bonds as a
part of their diversified portfolio. This approach helps to minimize taxable income while providing
necessary portfolio diversification.
Charitable Giving
For Clients who wish to incorporate philanthropy into a financial plan, Evergreen offers strategies for
donating appreciated securities to qualified charitable organizations. This allows Clients to potentially avoid
capital gains taxes on donated assets while receiving a charitable deduction, creating a tax-efficient
approach to giving.
C.
Risks of Investments and Strategies Utilized
Evergreen’s strategies are subject to investment and system risks; therefore, Clients may lose money. There
can be no assurance that any of the strategies will be successful in meeting the Client’s investment objective
as investing in securities involves risk of loss that Clients should be prepared to bear. The following list of
risk factors does not purport to be a complete enumeration or explanation of every risk involved in an
investment with Evergreen. Clients should read the entire Brochure, investment agreement and other
materials that may be provided by Evergreen. Generally, Evergreen’s strategies will be subject to the
following risks:
Market Risk
All investments involve the risk of loss, and securities held in Client portfolios are subject to various market
risks that may cause their value to fluctuate. The prices of equity securities, including common and
preferred stocks, warrants, exchange-traded funds (ETFs), mutual funds, and other securities, may rise or
fall based on company performance, industry trends, general market conditions, and investor sentiment.
ETFs are also subject to risks related to liquidity, tracking error, and management fees that may affect their
performance relative to the underlying index or assets they seek to track.
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Form ADV Part 2A
Evergreen Wealth Advisors
Markets can experience periods of significant volatility due to changing interest rates, inflation, geopolitical
events, fiscal and monetary policy decisions, and broader economic developments.
Investing in foreign and emerging markets introduces additional considerations, including political and
economic instability, currency fluctuations, limited regulatory oversight, and differences in financial
reporting and disclosure standards. Emerging markets, in particular, may be more susceptible to abrupt and
severe price declines, limited liquidity, and government intervention. These factors can contribute to
increased volatility and potential losses in Client accounts.
Factor Risk
Factor risk is the possibility that securities with similar attributes (such as industry, size, style, geography,
volatility, maturity or asset class) may decline in price due to factor-specific market or economic
developments. If a portfolio invests more heavily in a particular factor, the value of its shares may be
sensitive to factors and economic risks that specifically affect that factor.
Cybersecurity Risk
The Advisor and its key service providers (including custodians, broker-dealers, and banks) rely on
technology systems that may be vulnerable to cybersecurity threats. These include hacking, data breaches,
system failures, and other disruptions that could compromise Client data, delay transactions, or disrupt
operations. Such incidents may result in financial loss, regulatory consequences, or reputational damage.
Similar risks apply to companies in which Clients invest, potentially affecting investment performance.
While the Advisor has implemented controls to manage these risks, no system is fully immune to cyber
threats.
Risk of Health Crises and Other Disruptive Events
Events such as pandemics, natural disasters, terrorism, and geopolitical conflict can disrupt global markets
and the operations of the Advisor and its service providers. These disruptions may impair trading,
valuation, and other investment-related activities, and may negatively impact the performance of Client
portfolios. Broader economic effects from such events may also reduce the value of investments or increase
volatility.
Software Risk
Evergreen delivers the Program through proprietary software. While Evergreen designs, tests, and monitors
its software prior to and following deployment, software may not always perform exactly as intended,
particularly in unusual or unforeseen circumstances. Such failures could affect investment management
activities and may negatively impact Client accounts. Evergreen monitors its systems and works to correct
any software that does not perform as expected. Evergreen's Advisors periodically evaluate the advice
generated by Evergreen.ai as part of this monitoring process.
Artificial Intelligence Risk
Evergreen uses artificial intelligence (“AI”) tools to power Evergreen.ai and to support investment research,
portfolio management, wealth management advice, and business operations. While AI has the potential to
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Evergreen Wealth Advisors
enhance efficiency and insight, it may also generate inaccurate, incomplete, or biased advice or outputs (i.e.
it can sometimes get things wrong, whether that's missing context, misunderstanding what a User shared,
or relying on assumptions that don't quite fit someone's situation). Reliance on improper AI-generated
content could lead to inappropriate counsel and/or errors in investment decisions, negatively affecting
Client portfolios and Users of Evergreen.ai alike. Evergreen.ai does not implement any advice it provides, so
a User who acts on it is responsible for correctly carrying it out, including selecting the right account,
timing, and transaction type; errors such as a wash sale, a missed deadline, or an incorrect account can
result from a User's own implementation. In addition, rapid changes in AI technology or its adoption by
competitors may impact the Advisor’s ability to adapt or remain competitive. Mismanagement or misuse of
AI could also result in legal, operational, or reputational risks.
Tax Optimization Risk
Clients and Users should consult their personal tax advisor to understand the tax implications of investing
with the Advisor, using tax optimization strategies, or acting on tax efficiency advice from Evergreen.ai, as
outcomes depend on individual circumstances. Taxes should not be the sole driver of investment decisions.
Clients, Users, and their tax advisors are responsible for how transactions are reported to the IRS or other
tax authorities. Tax outcomes are not guaranteed and may be challenged by the IRS. The Advisor does not
provide personalized tax, legal, or accounting advice, and Evergreen.ai's tax efficiency advice does not
replace the advice of a qualified tax professional. Neither the Advisor nor Evergreen.ai assumes
responsibility for tax consequences, including capital gains or wash sales resulting from tax-loss harvesting.
As a result of tax optimization, the Client’s actual allocations and securities may differ from the target
allocations and securities, which may result in pre-tax performance that is better or worse than the target
allocations and securities would have generated. Evergreen’s tax optimization is generally limited to the
securities within the Client’s Investment Accounts; therefore, it may not take into account any securities
held elsewhere or any tax considerations outside of the Client’s Investment Accounts.
The benefits of tax loss harvesting may diminish over time as a Client's portfolio matures. As unrealized
losses are harvested and tax lots are replaced, the portfolio's cost basis increases, reducing the availability
of future harvesting opportunities. Clients with longer investment horizons or portfolios that have
appreciated significantly may experience fewer tax loss harvesting opportunities than in earlier periods of
the relationship. As a result, the after-tax benefits attributable to tax loss harvesting may be greater in the
early years of a Client's relationship with Evergreen and may decrease over time.
Clients and Users are encouraged to consult their tax preparer, accountant, or attorney to evaluate how
these strategies interact with their individual tax circumstances.
Concentration Risk
Although Evergreen seeks to build broadly diversified portfolios, Client-imposed restrictions, tax
optimization strategies such as gain deferral, or other factors may result in portfolios that are more
12
Form ADV Part 2A
Evergreen Wealth Advisors
concentrated in certain securities, sectors, or asset classes than the target allocation would otherwise
reflect. A more concentrated portfolio may experience greater volatility and larger losses than a fully
diversified portfolio, particularly if the concentrated positions decline in value.
Wrap Fee Program Risk
Clients participate in the Program, under which a single fee covers investment management, brokerage, and
transaction costs. Depending on the frequency and volume of trading in a Client's account, the Wrap Fee
may cost more than if the Client had arranged for investment management and brokerage services
separately. Clients who have lower trading activity may pay more in wrap fees than they would under an
alternative fee arrangement. Additionally, because transaction costs are covered by the Wrap Fee, Evergreen
may have an incentive to limit trading, which could affect portfolio management decisions. Clients should
carefully consider whether the Program is appropriate for their individual circumstances.
13
Form ADV Part 2A
Evergreen Wealth Advisors
Item 9 – Disciplinary Information
The Advisor and its management persons have not been a party to any legal or disciplinary events that
would be material to a Client’s or prospective Client’s evaluation of the Advisor’s investment advisory
business or the integrity of the Advisor’s management.
Item 10 – Other Financial Industry Activities and Affiliations
A. Registration as a Broker-Dealer or Broker-Dealer Representative
Neither Evergreen nor its management persons are registered as a broker-dealer or broker-dealer
representative.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading
Adviser
Neither Evergreen nor its management persons are registered as a futures commission merchant,
commodity pool operator, or a commodity trading adviser.
C. Relationships Material to this Advisory Business and Possible Conflicts of Interest
Evergreen Wealth Corporation is the parent company of Evergreen and provides technology,
marketing, and administrative services in support of Evergreen, including the technology underlying
Evergreen.ai. See Item 4 for additional information regarding the Program and Evergreen.ai.
This relationship creates a conflict of interest, as Evergreen may have an incentive to use its parent
company's services rather than seeking alternative providers. Evergreen manages this conflict by
ensuring that services obtained from Evergreen Wealth Corporation are fair, reasonable, and in the
best interests of Clients and Users of Evergreen.ai. Evergreen also has an incentive to use Evergreen.ai
to encourage Users to become Clients and enroll in the Program. See Item 5 for additional
information regarding this conflict.
Financial professionals, along with other Evergreen employees, are eligible for equity option grants in
the parent company.
D. Selection of Other Advisors or Managers
Evergreen does not utilize or select other advisors or third-party managers. All assets are managed by
Evergreen.
14
Form ADV Part 2A
Evergreen Wealth Advisors
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Evergreen has adopted a code of ethics pursuant to Rule 204A-1 under the Advisers Act (the “Code of
Ethics” or “the Code”) that governs a number of conflicts of interest that can arise when providing the
Program and Evergreen.ai to Clients. The Code is designed to ensure the Advisor meets its fiduciary
obligation to Clients (or prospective Clients), to detect and prevent violations of securities laws, and to
promote a culture of compliance within Evergreen.
The Code is distributed to each employee at the time of hire and upon any material changes. Employees are
required to attest annually that they have read, understood, and observed the Code. The Code is reinforced
through annual training and ongoing monitoring of employee activity.
Evergreen’s Code includes the following:
● Requirements related to the confidentiality of Client personal information;
● Prohibitions on:
Insider trading while in possession of material, non-public information;
○
○ Providing or accepting gifts and entertainment that exceed the Advisor’s policy standards;
○ Outside business activities that are inconsistent with the Advisor’s policy standards.
● Pre-clearance of employee securities transactions;
● Pre-clearance of political contributions;
● Reporting of investment holdings on an annual basis;
● Quarterly (and annual) reporting all personal securities transactions (“covered securities” as
mandated by regulation); and
● Quarterly (and annual) reporting of all personal brokerage accounts.
Evergreen employees may buy or sell securities for their personal accounts identical to or different from
those recommended to Clients. A conflict of interest arises when an employee buys or sells a security in the
same, or close proximity to the date of a purchase or sale of the same security on a Client’s behalf. There
could be an incentive for an employee to take advantage of the market effect of a Client’s trade, or the market
effect of an employee’s trade can negatively affect a subsequent purchase or sale price obtained for a Client.
Evergreen addresses this conflict through its Code of Ethics.
Evergreen's Code of Ethics subjects all employees to procedures and restrictions relating to their personal
securities transactions, including those outlined above. These procedures are overseen by the Chief
Compliance Officer or a designee.
The provisions of the Code of Ethics are intended to avoid or mitigate material conflicts of interest that can
arise between employees' personal conduct and their fiduciary duty to Evergreen Clients. Evergreen reserves
the right to refine and modify the Code of Ethics and its policies and procedures over time. Clients and
prospective Clients may obtain a copy of Evergreen's Code of Ethics upon request by contacting Evergreen at
Clientservice@evergreenwealth.com.
15
Form ADV Part 2A
Evergreen Wealth Advisors
Item 12 – Brokerage Practices
A. Factors Used to Select or Recommend Broker-Dealers
Evergreen provides fully discretionary investment management services to Clients. In connection
with these services, Evergreen has engaged Clearing Brokers to provide brokerage services under the
Program.
The Clearing Brokers route orders to various exchanges or market centers for execution and regularly
review execution quality to ensure they are seeking best execution of Client transactions. While the
Clearing Brokers seek to obtain best execution, Clients should be aware that Evergreen's exclusive
engagement of the Clearing Brokers for all trading and rebalancing activities means the Clearing
Brokers may not always provide the lowest possible transaction cost. Evergreen believes the selection
of the Clearing Brokers is in the best interest of Clients given the expanded suite of services provided
in connection with Client accounts.
The Clearing Brokers are responsible for managing all account activities, including receipt and
delivery of securities, receipt and payment of funds owed by or to Clients, and providing custody for
securities and funds held by Clients under the Program. Evergreen is responsible for monitoring all
transactions in Client accounts and for notifying the Clearing Brokers if it believes an error has been
made.
If Evergreen identifies a trading error, it will work with the Clearing Brokers to ascertain the facts and
resolve the error. Evergreen will work with the Clearing Broker to minimize the impact of the error
on the Client. If there is a realized gain to the Client as a result of a trading error, the Client will keep
the gain. If the error is Evergreen's responsibility, the Client's transaction will be corrected and
Evergreen will be responsible for any resulting loss.
B. Research and Other Soft Dollar Benefits
Evergreen does not engage in the use of “soft dollars” or commission sharing agreements.
C. Brokerage for Client Referrals
Evergreen does not consider Client referrals from a broker-dealer in selecting or recommending
broker-dealers for Client transactions.
D. Directed Brokerage
Evergreen does not accept directed brokerage arrangements from Clients. All securities transactions
are executed by brokers selected by Evergreen in its sole discretion.
E. Aggregating Trading for Multiple Clients
Evergreen has full discretion over Client accounts and may aggregate orders (block trade) when it
believes doing so is in Clients’ best interest. Block trading can improve execution quality and reduce
transaction costs. When trades are aggregated, participating accounts receive the average price and
share costs pro rata.
Due to the customized nature of Evergreen’s portfolio management and the wide range of securities
used, aggregation may not always be feasible. In such cases, trades will be executed individually in a
manner consistent with Evergreen's duty to seek best execution for all Clients.
16
Form ADV Part 2A
Evergreen Wealth Advisors
Item 13 – Review of Accounts
A. Frequency and Nature of Periodic Review and Who Makes Those Reviews
Client accounts are monitored on at least a monthly basis to ensure consistency with each Client's
strategy and investment objectives, with consideration given to asset allocation, cash management,
portfolio drift, tax optimization opportunities, and changes to a Client's financial condition. Formal
comprehensive reviews are conducted by Evergreen's investment professionals at least annually.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may take place more frequently in the event of major unanticipated changes in economic,
market, or political conditions that may impact Client holdings. Portfolios may also be reviewed and
rebalanced when a large deposit or withdrawal materially affects a Client's target allocation.
C. Content and Frequency of Regular Reports
Each Client’s Clearing Broker provides monthly statements showing the assets in each Client account,
the market value, and account performance. Clients are encouraged to carefully review all account
statements provided by the Clearing Broker and to compare them against any reports provided by
Evergreen. Clients should promptly notify Evergreen of any discrepancies.
Item 14 – Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties
Evergreen does not receive any economic benefits, directly or indirectly, from any third party in
connection with the investment advice it provides to Clients. See Item 10 for disclosure regarding
Evergreen's relationships with affiliated entities.
B. Compensation to Non-Advisory Personnel for Client Referrals
Evergreen does not compensate unaffiliated third parties for client referrals or leads.
17
Form ADV Part 2A
Evergreen Wealth Advisors
Item 15 – Custody
All Client funds and securities are held in custody by one or more qualified custodians (the “Custodians”)
selected by Evergreen at its discretion for each Client account. The Custodians provide trade execution,
clearing, and custodial services pursuant to the authority granted to Evergreen under the applicable
Investment Advisory Agreement.
Evergreen is deemed to have custody of certain Client assets as a result of its authority to direct the
movement of funds from Client accounts to external destinations, in addition to its authority to deduct
advisory fees directly from Client accounts. This authority is subject to strict operational controls, including
independent Client verification requirements prior to any external fund movement. As a result of this
custody arrangement, Evergreen is subject to an annual surprise examination by an independent public
accountant to verify Client assets. Clients are urged to carefully review account statements received directly
from the Custodian and to promptly notify Evergreen of any discrepancies.
Clients will receive account statements from the Custodians at least quarterly, though Evergreen makes
Custodian statements available to Clients through its online platform on a monthly basis. Information
displayed on Evergreen's online platform may differ at times from Custodian statements due to pending
transactions, dividends, corporate actions, cash movements, or other account activity. Clients who access
account information through Evergreen's online platform should compare that information against their
Custodian statements and promptly notify Evergreen of any discrepancies.
Item 16 – Investment Discretion
Evergreen provides the Program on a fully discretionary basis. Clients grant Evergreen discretionary
authority to determine, without obtaining the Client's prior consent, which securities are bought or sold and
the total amount of securities bought or sold, upon signing the Investment Advisory Agreement. This
authority continues until the agreement is terminated by either party, subject to any restrictions the Client
places on the account, and any limitations described in Item 4. As part of onboarding, Clients complete a
risk tolerance and suitability questionnaire that informs how this discretionary authority is exercised. See
Item 12 for selection of Brokers.
Evergreen.ai does not involve discretionary trading authority. Evergreen does not buy or sell securities on
behalf of a User through Evergreen.ai.
Item 17 – Voting Client Securities
Evergreen, as a matter of policy and as a fiduciary to Clients, has responsibility for voting proxies for
portfolio securities consistent with the best interests of Clients. Evergreen maintains policies and
procedures for the handling, research, voting, and reporting of proxy voting. Clients grant Evergreen the
authority to vote proxies as established by the Investment Advisory Agreement. Clients do not direct
individual proxy votes, though they may request information regarding how their proxies were voted as
described below.
Evergreen utilizes the proxy voting and due diligence services provided by Broadridge Financial Solutions,
Inc. ("Broadridge"), or its successors or assigns. The costs and expenses associated with this service are
paid by Evergreen. Under this arrangement, proxy votes are cast in a manner consistent with the
Shareholder Value Policy Rules developed and maintained by Broadridge. Evergreen retains discretion to
18
Form ADV Part 2A
Evergreen Wealth Advisors
override Broadridge's proxy voting recommendations consistent with its fiduciary obligations. Evergreen's
override authority does not require Evergreen to review each proxy voting decision made by Broadridge.
If Broadridge's guidelines do not specify a recommended vote, Evergreen may determine to abstain or
withhold a vote where insufficient information exists to determine which vote direction would best serve
Client interests.
Evergreen shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2(c)(2) under
the Advisers Act. Records are maintained through the Broadridge ProxyEdge System. Clients may request
information regarding how their proxies were voted, or a copy of Evergreen's proxy voting policies and
procedures, by contacting Evergreen at clientservice@evergreenwealth.com.
Item 18 – Financial Information
Evergreen has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to Clients and has not been the subject of a bankruptcy petition.
19
Part 2B of Form ADV:
Evergreen Wealth Advisors Brochure
Part 2B of Form ADV Brochure Supplement
for:
Evergreen Wealth Advisors
www.evergreenwealth.com
Office Addresses :
1 Glenwood Ave.,
Office 04-113
Raleigh, NC 27603
120 NE 27th St.,
Suite 100,
Miami, FL 33137
Telephone:
+1 (888) 884-0557
Mailing Address :
5540 Centerview Dr., Ste 204 PMB #48153
Raleigh, NC 27606
September 16, 2026
This Brochure Supplement provides information about certain Evergreen Wealth Advisors Corporation
(“Evergreen” or “Evergreen Wealth Advisors”) employees listed below that supplements the Evergreen Wealth
Advisors Brochure. Please contact Evergreen at +1 (888) 884-0557 or clientservice@evergreenwealth.com if you
did not receive Evergreen Wealth Advisors’ Brochure or if you have any questions about the contents of this
Brochure Supplement.
1
Part 2B of Form ADV:
Evergreen Wealth Advisors Brochure
Samantha Muncy
Head of Advisory Services
Year of Birth: 1980
Education
Purdue University Daniels School of Business, Global Executive MBA, 2021
TIAS School for Business and Society at Tilburg University in The Netherlands, Global Executive MBA, 2021
Mary Baldwin University, BS, 2003
Business Background
Evergreen Wealth Advisors Corporation, Head of Advisory Services, 12/2023 - Present
Open to the Public Investing, Inc., Head of Customer Experience, 05/2021 - 12/2023
Public Holdings, Inc., Director of Customer Experience, 05/2021 - 12/2023
Edward Jones, General Partner, 10/2016 - 04/2021
Edward Jones, Regional Leader, 10/2013 - 10/2015
Edward Jones, Financial Advisor, 06/2003 - 10/2015
Disciplinary Information
None
Other Business Activity
None
Additional Compensation
None
Supervision
Evergreen’s Chief Compliance Officer, Corey Gomes (888-884-0557), supervises Ms. Muncy’s advisory
activities. This supervision takes various forms, including communication and advertisement reviews,
conducting regular meetings and various supervisory controls related to supervised persons.
2
Part 2B of Form ADV:
Evergreen Wealth Advisors Brochure
Joel Anderson
Wealth Advisor
Year of Birth: 1991
Education
Golden Gate University Master of Science in Financial Planning (“MSFP”), 2023
Fox School of Business at Temple University, Master of Business Administration (“MBA"), Finance, 2019
University of Arizona, BA, 2016
Designation(s)/Certification(s):
Joel Anderson has earned the following certification and is in good standing with the granting authority:
● Registered Life Planner®: (granted by the Kinder Institute of Life Planning), 2023
Please refer to ADV Part 2B Appendix 1 for definitions of the above designation.
Business Background
Evergreen Wealth Advisors Corporation, Wealth Advisor, 12/2024 - Present
Values Added Financial, LLC, Financial Advisor, 01/2022 - 10/2024
Ameriprise Financial Services, LLC, Vice President, 08/2020 - 12/2021
Wells Fargo Clearing Services, LLC, Financial Advisor, 07/2017 - 08/2020
United States Navy, Fleet Marine Force Corpsman, 08/2009 - 07/2017
Disciplinary Information
None
Other Business Activity
None
Additional Compensation
None
Supervision
Joel Anderson reports to Samantha Muncy, Evergreen’s Head of Advisory (888-884-0557). Ms. Muncy and
Evergreen’s Chief Compliance Officer, Corey Gomes, supervise Mr. Anderson’s advisory activities. This
supervision takes various forms, including communication and advertisement reviews, conducting regular
meetings and various supervisory controls related to supervised persons.
3
Part 2B of Form ADV:
Evergreen Wealth Advisors Brochure
Part 2B of Form ADV Brochure Supplement - Appendix 1
Professional Designation Definitions
Registered Life Planner® (RLP®) designation
The Registered Life Planner® (RLP®) designation is issued by the Kinder Institute of Life Planning. It
is awarded to financial professionals who complete an intensive training program in client-centered
planning, with a focus on helping individuals clarify and pursue their most meaningful life goals
through financial advice and implementation.
The RLP® designation requires successful completion of the following components:
● EVOKE® Life Planning Training – A five-day experiential workshop that teaches the Kinder
Institute’s proprietary EVOKE® methodology, designed to guide clients through a structured process
of deep discovery, visioning, and financial goal alignment.
● Mentorship Program – A seven-month practicum during which the candidate applies Life Planning
techniques with actual clients under the supervision of an experienced RLP® mentor. The program
includes case study submissions and regular group coaching.
● Final Interview Assessment – A live, observed client interview that evaluates the candidate’s ability
to conduct a complete Life Planning engagement and apply the EVOKE® process with technical skill,
empathy, and integrity.
RLP® professionals are trained to combine traditional financial planning with in-depth discovery to
help clients articulate their core values and design financial plans that reflect their vision of a
purposeful life. The designation emphasizes fiduciary-level engagement, active listening, and
values-based decision making.
The RLP® designation does not require continuing education to maintain active status, though
practitioners are encouraged to remain engaged with the Kinder Institute community and ongoing
professional development opportunities. Additional information is available at
www.kinderinstitute.com.
4
Additional Brochure: EVERGREEN WEALTH ADVISORS CORPORATION - FORM ADV PART 2A WRAP FEE BROCHURE (2026-09-16)
View Document Text
Form ADV Part 2A - Wrap Fee Brochure
Part 2A of Form ADV Brochure - Wrap Fee Program Brochure
for:
Evergreen Wealth Advisors
www.evergreenwealth.com
Office Addresses:
1 Glenwood Ave.,
Office 04-113
Raleigh, NC 27603
120 NE 27th St.,
Suite 100,
Miami, FL 33137
Telephone:
+1 (888) 884-0557
Mailing Address:
5540 Centerview Dr., Ste 204
PMB #48153
Raleigh, NC 27606
September 16, 2026
This Brochure provides information about the qualifications and business practices of
Evergreen Wealth Advisors Corporation ("Evergreen Wealth Advisors" or "Evergreen" or
"Advisor" or “we”) and the Evergreen Wrap Fee Program. If you have any questions about
the contents of this Brochure, please contact the Advisor at the telephone number or
addresses listed above. The information in this Brochure has not been approved or
verified by the United States Securities and Exchange Commission ("SEC") or by any state
securities authority.
Evergreen is a registered investment adviser with the SEC. Registration of an investment
adviser does not imply any certain level of skill or training.
information about Evergreen
is available on
the SEC's website
Additional
www.adviserinfo.sec.gov.
1
Form ADV Part 2A - Wrap Fee Brochure
Item 2 – Material Changes
This Brochure provides Clients with a summary of the Evergreen Wrap Fee Program, including services, fees,
brokerage practices, and related conflicts of interest. This Item summarizes new and updated information.
Annual Update: The Advisor is required to update certain information at least annually, within 90 days of the
Advisor’s fiscal year end (“FYE”) of December 31. The Advisor will provide Clients with either a summary of the
revised information with an offer to deliver the full revised Brochure within 120 days of the Advisor’s FYE or
will provide each Client with a revised Brochure with a summary of those changes in this Item.
Material Changes: Should a material change in the Advisor’s operations occur, depending on its nature the
Advisor will promptly communicate this change to Clients (and it will be summarized in this Item).
● Evergreen has moved its Raleigh office location and its new address is reflected above.
●
Item 4 – Advisory Business: Added description of new service, Evergreen.ai, a free self-service Artificial
Intelligence (“AI”) platform offered by Evergreen Wealth Advisors that provides general education,
illustrations and calculators to all Users and provides personalized advice to Registered Users who share
sufficient information about their finances. Evergreen.ai is not included in, or covered by, the Wrap Fee, but
remains available at no additional charge to Wrap Fee Program Clients and non-participants alike.
●
Item 9 - Evergreen does not compensate unaffiliated third parties for client referrals or leads.
2
Form ADV Part 2A - Wrap Fee Brochure
Item 3 – Table of Contents
Item 2 – Material Changes...........................................................................................................................2
Item 3 – Table of Contents.......................................................................................................................... 3
Item 4 – Services, Fees, and Compensation............................................................................................. 3
Item 5: Account Requirements and Types of Clients............................................................................... 7
Item 6: Portfolio Manager Selection and Evaluation................................................................................ 7
Item 7: Client Information Provided to Portfolio Managers..................................................................... 8
Item 8: Client Contact with Portfolio Managers........................................................................................ 8
Item 9: Additional Information.................................................................................................................... 8
3
Form ADV Part 2A - Wrap Fee Brochure
Item 4 – Services, Fees, and Compensation
A. Services
Evergreen Wealth Advisors Corporation (“Evergreen,” “we,” or the “Advisor”) sponsors the Evergreen Wrap Fee
Program (the “Program”). Under the Program, Evergreen provides ongoing investment advisory services to
Clients (each a “Client” and collectively the “Clients”) on a fully discretionary basis. We monitor client accounts
on an ongoing basis and make investment changes as needed to keep accounts aligned with each client’s
investment objectives, risk tolerance, time horizon, and financial circumstances.
This Wrap Fee Program Brochure is a supplement to Evergreen’s Form ADV Part 2A Disclosure Brochure.
Together, these documents describe the Program, Evergreen’s business practices, and fees.
Evergreen also provides financial planning and consulting services to Program clients at no additional charge
as part of the Wrap Fee. These services may include investment planning, tax-aware planning considerations,
and general financial goal-setting.
Evergreen also provides Evergreen.ai, a self-service AI financial advice platform (“Evergreen.ai”) which does
not require an Investment Advisory relationship or the signing of an Investment Advisory Agreement.
Evergreen.ai is available to two categories of individuals who have not entered into an Investment Advisory
Agreement: (i) visitors who access Evergreen.ai without creating an account ("Anonymous Users"), and (ii)
individuals who create an account with Evergreen.ai ("Registered Users," and together with Anonymous Users,
"Users"). Evergreen.ai is not included in, or covered by, the Wrap Fee, but remains available at no additional
charge to Wrap Fee Program Clients and non-participants alike. Evergreen.ai does not provide ongoing,
discretionary investment management services included in the Wrap Fee Program described in this Brochure.
For a full description of Evergreen.ai, including its use of AI and large language model technology, its reliance
on standardized assumptions, and its scope and limitations, see Item 4 and Item 8 of Evergreen's Form ADV
Part 2A Brochure.
Portfolio Management
Evergreen provides fully discretionary portfolio management to all Program clients. Portfolios are tailored to
each client’s investment objectives, risk tolerance, time horizon, and financial circumstances based on
Evergreen’s suitability and risk-assessment process.
Portfolios are generally constructed using diversified holdings such as equities, exchange-traded funds, fixed
income instruments, money market mutual funds, and government securities. Evergreen’s investment
management may include tax-loss harvesting, gain deferral, asset location across taxable and tax-advantaged
accounts, and periodic rebalancing. Evergreen monitors accounts on an ongoing basis and adjusts portfolios
based on portfolio drift, cash activity, tax optimization opportunities, or changes in Client circumstances.
4
Form ADV Part 2A - Wrap Fee Brochure
Wrap Fee Schedule
Clients pay a single asset-based wrap fee (the “Wrap Fee”) for services provided under the Program. The Wrap
Fee covers Evergreen’s investment advisory and portfolio management services, as well as brokerage and
transaction costs, custodial costs, and certain administrative expenses associated with managing client
accounts. For further information about expenses, please read Item 4C.
Fees are assessed monthly based on the average daily balance of assets under management during the billing
period, including any cash and cash equivalents held within the portfolio. The applicable fee rate is determined
by aggregating total assets across all of a Client's Investment Accounts, as follows:
Management Fee Based on Account Type(s) Held by Client
Account Type
Value of Assets
Monthly AUM Fee
Annual AUM Fee
First $1,000,000
.0325%
.39%
Investment Accounts
.0242%
.29%
Next $4,000,000
(over $1M up to $5M)
Assets over $5,000,000
.0158%
.19%
*The fees above do not apply to use of Evergreen.ai, which is provided at no charge.
Evergreen may, in its sole discretion, reduce, waive, or negotiate fees for certain clients or groups of clients
based on factors such as account size, length of relationship, affiliation with Evergreen, or participation in a
promotional or testing program.
Portion of the Wrap Fee Paid to the Portfolio Manager
Evergreen serves as the sponsor of the Program and the sole portfolio manager for all Program accounts.
Evergreen does not use unaffiliated sub-advisers or third-party portfolio managers. After payment of
brokerage, clearing, transaction, and custodial costs, the remaining portion of the Wrap Fee is retained by
Evergreen as compensation for portfolio management services. Depending on trading activity and
account-related costs, Evergreen may retain all, a portion, or only a small portion of the Wrap Fee. No portion
of the Wrap Fee is paid to any third-party portfolio manager.
B. Program Costs
Participation in the Evergreen Wrap Fee Program may cost a client more or less than purchasing investment
advisory services and brokerage services separately. Under the Program, clients pay a single asset-based Wrap
Fee that includes investment advisory services as well as brokerage and transaction costs. If those services
were purchased separately, a client would typically pay an advisory fee in addition to transaction-based
brokerage charges.
Whether the Program is more or less expensive depends primarily on the client’s expected trading activity and
account size. Because the Wrap Fee is charged regardless of the number of transactions in the account, clients
with higher trading activity may pay less under the Program than they would under a separate advisory and
5
Form ADV Part 2A - Wrap Fee Brochure
brokerage arrangement. Clients with lower trading activity may pay more under the Program because they pay
the Wrap Fee whether or not significant transaction costs are incurred.
The total cost of the Program also increases as account assets increase because the Wrap Fee is based on
assets under management. Clients should consider the Wrap Fee in light of their anticipated account size,
trading frequency, and the nature of Evergreen’s investment approach, which may involve ongoing tax-loss
harvesting, rebalancing, and other tax-aware portfolio management techniques that can increase trading
activity.
Clients are encouraged to discuss with Evergreen whether the Wrap Fee Program is appropriate for their
circumstances.
C. Fees and Expenses in Addition to the Wrap Fee
Beyond the administrative and other expenses already included in the Wrap Fee (see Item 4.A), clients may
incur certain other fees and expenses in connection with the Program. Clients who invest in exchange-traded
funds (“ETFs”), money market mutual funds, mutual funds, or other pooled investment vehicles will bear their
proportionate share of the fees and expenses charged by those vehicles, including internal management fees
and operating expenses. These expenses are separate from, and in addition to, the Wrap Fee. Evergreen does
not receive these fees.
Clients may also incur markups, markdowns, or bid-ask spreads when purchasing or selling certain fixed
income securities, including bonds and other securities traded in principal transactions. These costs are
embedded in the transaction price, are not paid to Evergreen, and are in addition to the Wrap Fee.
Clients should review applicable account agreements, confirmations, and fund prospectuses for additional
information regarding these fees and expenses.
D. Compensation to the Person Recommending the Wrap Fee Program
Evergreen’s advisory personnel do not receive any separate commission, referral fee, finder’s fee, or other
incremental compensation as a result of a client’s enrollment in or continued participation in the Evergreen
Wrap Fee Program. Advisory personnel are compensated under Evergreen’s regular employment
arrangements, which may include salary and discretionary compensation, but no component of that
compensation is directly tied to recommending the Program.
Evergreen’s entire advisory business is conducted through a single Wrap Fee Program, and clients do not have
the option to participate in a separate non-wrap advisory program sponsored by Evergreen. As a result,
Evergreen’s personnel do not receive more compensation for recommending the Program over another
advisory program offered by Evergreen.
Neither Evergreen nor its personnel receive compensation from clearing brokers, ETF sponsors, mutual funds,
or other third parties in connection with recommending the Program or investments held in Program
accounts. Evergreen’s sole compensation is the advisory fee paid by clients.
6
Form ADV Part 2A - Wrap Fee Brochure
Like other asset-based advisory firms, Evergreen has a financial incentive to encourage clients to maintain and
increase assets in accounts managed by Evergreen because its fees increase as assets under management
increase. Evergreen is also incented to try to convert Evergreen.ai Users into Wrap Program paying Clients.
Evergreen addresses these conflicts through its fiduciary duty and its suitability and account-monitoring
processes.
Item 5: Account Requirements and Types of Clients
Evergreen provides the Program to individuals, high-net-worth individuals, and corporations who have
entered into an Investment Advisory Agreement with Evergreen. Evergreen has a $100,000 minimum balance
requirement to establish a relationship, which may be changed at the Firm's discretion. Evergreen reserves the
right to decline or discontinue engagements at its sole discretion if it is determined that the relationship is not
appropriate or aligned with its service. The Wrap Fee Program applies only to Clients under the Investment
Advisory Agreement; Evergreen.ai is not part of the Program and is available to Clients and non-Clients alike at
no charge, without a minimum balance requirement. See Item 4 above for additional information.
Item 6: Portfolio Manager Selection and Evaluation
A.
Portfolio Manager Selection and Evaluation
Evergreen is the sponsor of the Evergreen Wrap Fee Program and the sole portfolio manager for all Program
accounts. Evergreen does not select, recommend, or retain unaffiliated sub-advisers or third-party portfolio
managers. Accordingly, clients are not assigned among multiple portfolio managers, and Evergreen does not
maintain a process for selecting or replacing portfolio managers within the Program.
Because Evergreen is the only portfolio manager, all Program accounts are managed through Evergreen’s
investment process and are subject to Evergreen’s supervisory, compliance, and account review procedures.
Accounts are managed on a fully discretionary basis in light of each client’s investment objectives, risk
tolerance, time horizon, financial circumstances, tax considerations, and any applicable account restrictions.
Evergreen has a financial interest in managing Program assets itself and retaining the Wrap Fee, which creates
a conflict of interest. Evergreen addresses this conflict through its fiduciary duty, suitability process, ongoing
account monitoring, and compliance oversight.
B.
Related Persons Acting as Portfolio Manager
Evergreen, as a related person and the sponsor of the Program, has a financial interest in managing Program
assets itself and retaining the Wrap Fee. This creates a conflict of interest because Evergreen has an incentive
to recommend and maintain client assets in the Program. Evergreen addresses this conflict through its
fiduciary duty, suitability process, ongoing account monitoring, and compliance oversight.
Evergreen does not use composite or other portfolio manager performance information to select among
multiple portfolio managers for the Program, and no third party reviews portfolio manager performance for
that purpose, because no multiple-manager selection process exists. Evergreen does not charge
performance-based fees. Although Evergreen manages multiple client accounts, its policies and procedures are
designed to ensure investment decisions and trade allocations are made fairly and equitably across accounts.
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Form ADV Part 2A - Wrap Fee Brochure
C.
Standard of Conduct for Portfolio Managers
Evergreen’s investment approach is based on each client’s investment objectives, risk tolerance, time horizon,
financial circumstances, and tax considerations. Evergreen generally constructs diversified portfolios using
equities, fixed income instruments, cash equivalents, ETFs, money market mutual funds, and government
securities, and may employ tax-loss harvesting, gain deferral, asset location, and rebalancing. Investing in
securities involves risk of loss that clients should be prepared to bear.
Please refer to additional information found in the following Items of ADV Part 2A, which accompanies this
Wrap Brochure: Item 4 – Advisory Business; Item 6 – Performance-Based Fees and Side-By-Side Management;
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.
Item 7: Client Information Provided to Portfolio Managers
Evergreen is the sponsor and sole portfolio manager for the Wrap Fee Program. Because Evergreen does not
use third-party or unaffiliated portfolio managers, it does not provide client information to any outside
portfolio manager.
In managing Program accounts, Evergreen uses the client information it obtains through the account opening
process and throughout the advisory relationship, including the client’s investment objectives, risk tolerance,
time horizon, financial circumstances, tax considerations, account characteristics, and any reasonable account
restrictions communicated by the client. Evergreen updates this information as needed based on information
provided by the client, periodic reviews, and other communications or changes in the client’s circumstances.
Item 8: Client Contact with Portfolio Managers
Evergreen is the sponsor and sole portfolio manager for the Evergreen Wrap Fee Program. Clients may contact
and consult directly with Evergreen regarding the management of their accounts. Evergreen does not place
any restrictions on a client’s ability to contact or consult with Evergreen as portfolio manager.
Item 9: Additional Information
A.
Disciplinary and Other Financial Industry Activities and Affiliations
Evergreen and its management persons have not been a party to any legal or disciplinary event that would be
material to a client’s or prospective client’s evaluation of Evergreen’s advisory business or the integrity of its
management.
Neither Evergreen nor its management persons are registered as a broker-dealer, broker-dealer
representative, futures commission merchant, commodity pool operator, or commodity trading adviser.
Evergreen is a wholly owned subsidiary of Evergreen Wealth Corporation, which provides certain technology,
marketing, and administrative support services including the technology underlying Evergreen.ai, a service
offered directly by Evergreen at no charge and outside of the Wrap Fee Program. This relationship creates a
conflict of interest, as Evergreen may have an incentive to use its parent company's services rather than
seeking alternative providers. Evergreen manages this conflict by ensuring that services obtained from
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Form ADV Part 2A - Wrap Fee Brochure
Evergreen Wealth Corporation are fair, reasonable, and in the best interests of Clients as well as Users of
Evergreen.ai.
Evergreen also has an incentive to use Evergreen.ai to encourage Users to become Clients and enroll in the
Program. See Item 4 for additional information regarding this conflict.
B.
Code of Ethics, Review of Accounts, Client Referrals, and Financial Information
Evergreen has adopted a code of ethics under Rule 204A-1 designed to promote compliance with securities
laws and Evergreen’s fiduciary duty to clients. The code addresses matters such as confidentiality, insider
trading, gifts and entertainment, outside business activities, pre-clearance of employee securities transactions
and political contributions, and reporting of personal holdings, transactions, and brokerage accounts. Because
Evergreen employees may buy or sell securities for their own accounts that are the same as, or different from,
securities recommended to clients, conflicts of interest can arise, and Evergreen addresses those conflicts
through its code of ethics and related supervisory procedures. A copy of the code of ethics is available to
clients and prospective clients upon request.
Program accounts are monitored at least monthly for consistency with each client’s strategy and investment
objectives, and formal comprehensive reviews are conducted at least annually by Evergreen’s investment
professionals. Additional reviews may occur in response to significant market, economic, or political
developments or when large deposits or withdrawals materially affect an account’s allocation. Clients receive
account statements from the clearing broker and should review those statements carefully.
Evergreen does not receive economic benefits from third parties in connection with the investment advice it
provides to clients and does not compensate unaffiliated third parties for client referrals or leads.
Evergreen has no financial commitment that impairs its ability to meet its contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy petition.
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