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Item 1 – Cover Page
3200 Windy Hill Rd, SE
Suite 1550E
Atlanta, GA 30339
404·364·2188
877·428·6956
www.globalt.com
This Brochure provides information about the qualifications and business practices of Globalt
Investments LLC (“Globalt”). If you have any questions about the contents of this Brochure,
please contact Annette M. Marshall, Chief Compliance Officer at 678-802-4433 or by email at
amarshall@globalt.com. The information in this Brochure has not been approved or verified by
the United States Securities and Exchange Commission (the “SEC”) or by any state securities
authority.
Globalt is a federally registered investment adviser. Registration of an Investment Adviser does
not imply any level of skill or training. The oral and written communications of an Adviser
provide you with information about which you determine to hire or retain an Adviser.
This disclosure Brochure describes the business practices of Globalt. It is intended to provide
clients and prospective clients with an understanding of the investment management services
offered by Globalt, and to provide full and fair disclosure of any conflicts or potential conflicts of
interest associated with those services. Globalt may, at the request of a client, provide
investment advice or other services not discussed in this Brochure. In such cases, any additional
disclosures will be provided to the client, as necessary. Clients can also refer to their investment
management agreement for information specific to the management of their account.
information about Globalt
Investments
Additional
is available on the SEC’s website
www.adviserinfo.sec.gov. The SEC’s website also provides information about persons affiliated
with Globalt who are registered as Investment Adviser Representatives of Globalt.
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Item 2 – Material Changes
This Brochure dated October 1, 2025, is a revised document prepared according to the SEC’s
requirements and rules. This Item will discuss only specific material changes that are made to
the Brochure since the last update on July 1, 2025, and will provide clients with a summary of
such changes.
Pursuant to SEC Rules, Globalt will ensure that clients receive a summary of any material
changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal
year. We may further provide other ongoing disclosure information about material changes as
necessary.
Since the last update, the following changes have been made.
• Further amended the disclosure language regarding Globalt’s usage of AI.
We will further provide clients with a new Brochure as necessary based on changes or new
information, at any time, without charge. Copies of this Brochure may be requested by
contacting Annette M. Marshall, Chief Compliance Officer at 678-802-4433 or
amarshall@globalt.com. It is also available free of charge via our website www.globalt.com.
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Item 3 – Table of Contents
Item 1 – Cover Page .......................................................................................................................................................... 1
Item 2 – Material Changes .......................................................................................................................................... 2
Item 3 – Table of Contents .......................................................................................................................................... 3
Item 4 – Advisory Business ......................................................................................................................................... 4
Item 5 – Fees and Compensation ......................................................................................................................... 10
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................. 13
Item 7 – Types of Clients.............................................................................................................................................. 13
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 14
Item 9 – Disciplinary Information........................................................................................................................... 17
Item 10 – Other Financial Industry Activities and Affiliations ................................................................ 17
Item 11 – Code of Ethics ................................................................................................................................................18
Item 12 – Brokerage Practices ..................................................................................................................................18
Item 13 – Review of Accounts .................................................................................................................................. 22
Item 14 – Client Referrals and Other Compensation ................................................................................. 23
Item 15 – Custody............................................................................................................................................................ 23
Item 16 – Investment Discretion ............................................................................................................................ 23
Item 17 – Voting Client Securities..........................................................................................................................24
Item 18 – Financial Information ..............................................................................................................................24
Appendix A: Risk Definitions ................................................................................................................................... 25
ADV Part 2B - Brochure Supplement(s)
ADV Part 3, Form CRS - Customer Relationship Summary
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Item 4 – Advisory Business
Globalt Investments LLC (“Globalt” or the “Firm”) was founded in 1990. It has been registered
with the SEC as an Investment Adviser pursuant to the Investment Advisers Act of 1940 since
1991. Effective October 1, 2023, Globalt is a limited liability company owned by the employees
and succeeding the “Globalt Investments” which had been a separately identifiable division of
Synovus Trust Co. N.A. (its affiliate since 2002). Globalt is no longer affiliated with Synovus. As of
November 6, 2023, Globalt’s successor registration was declared effective by the SEC, and
reliance on the predecessor’s registration was no longer needed. The SEC declaring Globalt’s
successor registration effective should not be mistaken for an endorsement.
Globalt offers investment advisory services to individuals, high net worth individuals,
corporations and institutions, banks and trust companies, pension and profit-sharing plans,
estates and trusts, charitable organizations, and other investment advisers. Clients select (or
Globalt recommends) a particular investment strategy. The investment advisory services are
offered in the following manner:
• Separately Managed Accounts
• Wrap Fee Programs
• Model Portfolio Provider Platforms
Discretionary accounts are managed in accordance with the selected strategy, subject to any
specific and reasonable guidelines and restrictions imposed by the client, subject to Globalt’s
acceptance of those restrictions. Client imposed restrictions may have an impact, perhaps
materially so, on account performance. Additionally, Globalt participates as a portfolio manager
in wrap-fee programs and also provides model portfolio recommendations to banks, broker
dealers, investment advisers, or other financial services companies, who, in turn, offer the model
portfolio to their respective clients. Certain strategies that we manage are offered under
different names through different firms, but the underlying strategies are the same, within
restrictions. Not all firms that hire us as a portfolio manager or model provider offer all of the
strategies described.
Business Continuity
Globalt has a business continuity plan in place for the recovery of essential business functions
and systems, in the event of a business disruption. Globalt’s Disaster Recovery and Business
Continuity Plan consists of a cloud-based network, the full suite of Microsoft 365 services, and
the firm also uses cloud native solutions for other key systems used. Redundant internet
connections are maintained in the office with battery backup. The staff also works remotely as
needed via a VPN and are not reliant on the network at our headquarters or any other single
location.
Use of Artificial Intelligence (“AI”)
For purposes of this brochure, “artificial intelligence” (AI) refers to software systems created by
third-party providers that generate text, code, or research output in response to human input.
We use AI tools to support our firm operations, including rewriting and proofing content,
assisting with algorithmic code development, and conducting broad research. These tools are
not used to provide investment advice, make portfolio decisions, or communicate directly with
clients. We conduct due diligence upfront and ongoing assessments of our AI tools' privacy and
cybersecurity protocols to ensure they meet standards of security and confidentiality. These AI
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tools do not replace human oversight; we review and monitor AI-generated outputs for
accuracy and compliance with regulatory standards, but there is no guarantee they will be error-
free. Use of AI involves risks such as inaccuracies, data limitations, or bias.
Separately Managed Accounts (“SMA”)
Globalt provides discretionary investment advisory services to separately managed account
clients directly or through third party financial intermediary agreements, including accounts on
behalf of non-affiliated broker dealers, banks, investment advisers and other financial
intermediaries (collectively, “other advisers”). When clients engage Globalt’s services, they enter
into a written Investment Management Agreement with Globalt; the Agreement outlines the
nature of Globalt’s duties, provides required disclosures and the applicable fees. Clients who
select Globalt to manage their SMA assets will typically do so under either a “single contract” or
“dual contract” agreement. Under a dual contract agreement, the client typically has one
contract with Globalt for investment advisory services and a separate and distinct agreement
with another advisor or party for their services, apart from Globalt.
Clients select investment strategies offered by Globalt, after consultation with Globalt or the
client’s primary adviser in the other adviser relationship(s). It is generally the client’s
responsibility or that of the associated other adviser to periodically provide updated information
regarding changes in the client’s financial and investment needs, risk tolerance, time horizon,
goals and objectives, and as appropriate, provides or recommends changes to the investment
strategy to Globalt. Investment strategy changes must be provided in writing to Globalt.
Globalt’s role is to manage the client’s account in accordance with the investment strategy
selected, subject to any reasonable and accepted restrictions imposed by the client.
The client may also appoint or direct a custodial broker dealer to maintain custody of the client’s
account assets and to execute securities transactions. Typically, the broker dealer custodian is
the broker dealer available to the client through the other adviser’s investment advisory
platform or financial intermediary. Globalt will receive a separate investment management fee,
or a portion of the program fee, for providing these investment management services. In some
SMA accounts, clients pay a single fee to the other adviser, who covers some or all of the
following services: portfolio management, custody, administration, commissions and other
costs incurred for trades executed.
Wrap Fee Programs
Globalt provides its investment strategies on a discretionary basis to accounts under wrap fee
programs sponsored by other firms. With respect to wrap fee programs, the program sponsors
recommend and assist clients in selecting the appropriate investment strategy, including
Globalt, that take into account the client’s financial situation, experience, and investment
objectives. Globalt relies on program sponsors and their financial advisors to fulfill certain
responsibilities with regard to program clients. Generally, program sponsors assume tasks such
as: (1) client identification; (2) delivery of Globalt’s Brochure; (3) delivery of Globalt’s privacy
notice; and (4) ensuring Globalt’s products and services are suitable to the client’s investment
objectives. Globalt’s role is to manage the client’s account according to the investment strategy
selected by the client. Clients are permitted to impose reasonable investment restrictions, but
these restrictions may impact performance of their accounts. In these wrap fee programs,
clients generally pay a single “wrap” fee to the program sponsor, who covers some or all of the
following services: portfolio management, custody, administration, commissions and other
costs incurred for trades executed by the sponsor. Globalt receives a portion, generally .10% to
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.45% of this wrap fee. Subject to its duty to seek best execution for client transactions, Globalt
will generally execute trades through the sponsor since the fee paid by the client generally
includes the cost of transactions. Wrap fee clients should review the program sponsor’s ADV
Part 2A - Appendix 1, Wrap Fee Program Brochure, for program details, minimum portfolio size,
conflicts of interest, fees and disclosures.
implementing
Model Portfolio Provider Platform
Globalt has been retained as a Model Portfolio Provider for several model portfolio provider
platforms. Under these arrangements, Globalt makes available its model portfolios or
investment strategies to other investment advisers, broker dealers, banks and other financial
intermediaries, through a Unified Managed Account (UMA) platform, model strategist program
overlay manager or similar structure (together, the “platform”). As a model portfolio provider,
Globalt designs, monitors and updates the portfolio. Globalt then provides model changes and
rebalancing triggers to these platforms, but generally does not provide
investment
management services or oversight directly to any client that participates in the platform, nor
its
will Globalt have any discretionary authority or responsibility for
recommendations or placing trades on behalf of participating accounts. The platforms
determine the applicability, timing and execution of implementation of the model portfolios for
their applicable clients. Globalt anticipates that the platform will generally follow the model
portfolio allocations and directions from Globalt. However, the platform has investment
discretion to invest and may deviate from the model portfolios or client directions provided.
These factors of discretion, security selection, direction or trading timing may result in
associated account performance discrepancies from those accounts managed via SMA or wrap
fee program, as well as from other platforms.
In these arrangements, Globalt generally will not have an advisory agreement directly with the
client and assets are classified as under advisement. In exchange for providing services, Globalt
receives a portion of the fees paid by the clients to the platform. In some cases, Globalt may
agree to provide to retirement plan sponsors or third-party providers an Investment Objective
Questionnaire or Risk Tolerance Questionnaire that may assist the participants in identifying the
appropriate investment strategy to select. The model provider platforms or strategist programs
determine the documents, terms and conditions of the programs, which may vary from
program to program. For more information about each platform, clients should review the
model provider platform’s ADV Part 2A - Appendix 1, Program Brochure, for program details,
minimum portfolio size, conflicts of interest, fees and disclosures.
Types of Investments (Strategies)
innovatETF Strategies®
The innovatETF Strategies seek to reduce portfolio volatility and minimize downside risk
when possible, while delivering competitive risk-adjusted returns over a full market cycle.
The strategies start with a long-term strategic neutral allocation to five asset classes (U.S.
Equities, Non-U.S. Equities, Fixed Income, Real Estate, Alternative Investments, and Cash)
based on long-term (strategic) risk tolerance and return requirements that can be over or
under weighted on a shorter-term (tactical, dynamic) basis. The investment process for
making asset allocation and security selection decisions includes a proprietary quantitative
model, as well as qualitative analysis evaluated by an experienced team of portfolio
managers. There are seven strategies segmented by strategic risk/return objectives --
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Defensive, Conservative, Balanced, Growth, and High Growth. Exchange Traded Funds
(ETFs) are the securities that are used to express the asset allocations underlying positions.
• U.S. equities - large-cap, mid-cap, small-cap, growth, value
• Foreign equities - developed markets, emerging markets, regions and/or countries
• U.S. fixed income - corporate, government, high yield, agency, municipal
• Real estate - real estate investment trusts
• Alternatives - metals, other commodities, absolute return funds, opportunistic
investments
• Foreign debt - sovereign debt, emerging debt
• Cash - cash and short-term cash equivalents
There is a $100,000 target minimum portfolio size required for these services, which may be
negotiable under certain circumstances.
Income Growth
This portfolio may be suitable for the investor looking for current income and income
growth, with a secondary consideration of capital appreciation. This strategy seeks to
provide above market income stream and temper volatility by exposure to dividend paying
securities through investments, primarily in domestic and international Equity and Fixed
Income ETFs, REITs and some alternatives.
Defensive
This portfolio with a fixed income bias, may be appropriate for investors with a cautious risk
tolerance and/or shorter investment time horizon. The focus of the strategy, primarily
utilizing ETFs, is to mitigate overall volatility and provide downside protection, while
producing total investment returns consistent with a more conservative portfolio over a
market cycle 1.
Conservative
This portfolio may be suitable for the cautious investor, one with a lower risk tolerance and/or
shorter investment time horizon. The portfolio combines modest potential for capital
appreciation with potential for downside protection by investing in a diversified portfolio,
generally with a fixed income bias.
Balanced
This portfolio may be suitable for the investor who wants to achieve steady growth, while
limiting fluctuation to less than that of the overall stock market. The portfolio combines
investments primarily in equity and fixed income ETFs to provide investors with balanced
and varied exposure to the stock and bond markets. This portfolio may be appropriate for
investors who primarily seek long-term capital appreciation with a more moderate risk
profile.
1 Globalt defines a market cycle as the period between the two latest highs/lows of a common benchmark, highlighting a fund’s performance
through both, an up and down market.
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Growth
This portfolio may be suitable for investors with a relatively high tolerance for risk and a
longer investment time horizon. The main objective of this portfolio is capital appreciation,
and investors should be able to tolerate fluctuations in their portfolio values. While this
portfolio will experience volatility similar to that of the equity markets, exposure to fixed
income markets may lower the volatility relative to an all-equity portfolio.
Environmental Social and Governance Growth (ESGG)
This portfolio seeks long-term capital appreciation and may be suitable for an investor with
a relatively high-risk tolerance and a long-time horizon. This strategy is managed by the
same investment process as the innovatETF Growth Strategy, with the exception of the
security selection component. ETFs selected in this strategy have the ESG criteria integrated
into their investment methodology, whereas the innovatETF Growth Strategy does not
retain that requirement. Certain market segments do not allow for ESG criteria but are
included in the portfolio. Selections are based on various factors which may include
similarities to the non-ESG innovatETF Growth Strategy, alternatives, market capitalization,
trading liquidity, and expenses.
High Growth
This portfolio may be suitable for investors who have both a higher tolerance for risk and a
long-term investment time horizon. The main objective of this portfolio is to construct a high
growth portfolio. Investors should be able to tolerate substantial fluctuations in portfolio
value from year to year. The portfolio seeks long term capital appreciation through
investments primarily in domestic and international ETFs.
Fixed Income (ETF)
This fixed income portfolio may be appropriate for investors with an income investment
objective. The focus of the strategy, utilizing ETFs, is to provide a diverse fixed income
allocation with similar investments and objectives comparable to the Barclays Capital
Government/Credit Bond Index.
International Equity
This portfolio may be appropriate for the investor with a higher risk tolerance and long
investment time horizon. The portfolio is a diversified multi-country portfolio with exposure
to both developed and emerging markets through investments primarily in international
equity ETF’s. This strategy is benchmarked to the MSCI World ex-U.S. and the MSCI ACWI ex-
U.S. Indices. (This strategy is not open to new assets.)
Globalt offers equity, fixed income and asset allocation strategies, generally utilizing equities,
fixed income securities and exchange traded funds (ETFs). The goal of Globalt’s investment
process is to strive to deliver competitive returns versus the appropriate benchmark. From time
to time, Globalt may provide custom investment advisory services and portfolios to clients. The
custom advisory products include, but are not limited to, equity, fixed income or ETF portfolios.
For ongoing management of each strategy below, the minimum portfolio size is listed. In our
sole discretion, we may accept portfolios below these stated minimums. Not all products or
services are available to all programs or platforms. Separately Managed Account, wrap fee
program, and model provider program platform clients may be subject to different minimum
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portfolio sizes and fee schedules, as determined and disclosed by the program sponsor or
platform.
Equity Strategies
Large Cap Core
This equity portfolio consists primarily of large cap U.S. equities representing multiple
sectors and/or industries and includes securities characteristics of the S&P 500 Index.
Target minimum portfolio size is $200,000.
Large Cap Core Growth
This equity portfolio consists primarily of large cap U.S. growth equities representing
multiple sectors and/or industries and includes securities characteristics of the S&P 500
Index and the Russell 1000 Growth Index. The strategy focuses on higher growth and lower
income generating investments.
Target minimum portfolio size is $200,000.
Large Cap Opportunistic Growth
This portfolio consists primarily of large cap U.S. growth equities representing multiple
sectors and/or industries and includes securities characteristic of the Russell 1000 Growth
Index. (This strategy is not open to new assets.)
Equity Income
This portfolio consists primarily of large cap U.S. equities representing multiple sectors
and/or industries and includes securities characteristics of the S&P High Yield Dividend
Aristocrats Index. The Index is “designed to measure the performance of the 60 highest
dividend yield S&P Composite constituents, which have followed a managed dividends
policy of consistently increasing dividends every year for at least 25 years.” The Strategy has
a yield target of at least 1.5x that of the S&P 500 Index. The portfolio has a minimum target
to invest 90% of holdings in dividend paying securities.
Target minimum portfolio size is $100,000.
Disciplined Growth and Innovation
This portfolio integrates ESG considerations characteristics and analysis into our investment
decision making process, at both the individual security and holistic portfolio level; while
excluding stocks of specific companies involved in certain business models such as alcohol
manufacturers, tobacco manufacturers, gambling, adult entertainment, and providing
abortions as a means of birth control. Companies are automatically excluded if any of these
activities are greater than 10% of a company’s total revenues. Portfolios are constructed to
have overall ESG characteristics. Globalt utilizes a third-party ESG information provider,
Sustainalytics, for its quantitative ESG metrics and characteristics. The process specifically
excludes stocks of all companies that are in Sustainalytics Severe Risk category (Risk Score
of 40 and above). The Risk Rating Score is evaluated in the context of its Sector Peer scores
and factors of the overall portfolio.
Target minimum portfolio size is $100,000.
Fixed Income Strategies
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Intermediate Term Fixed Income
This portfolio is managed and monitored with a weighted average maturity between 3 and
10 years, consisting of fixed income products to include: certificates of deposit, U.S.
government treasury bills and bonds, investment grade corporates, U.S. government
agencies and investment grade municipal bonds.
Target minimum portfolio size is $1 million.
State Tax-Free Fixed Income
This portfolio provides state tax-free income, invested primarily with state and local
municipal bonds, with similar investments and objectives benchmarked to Barclays Capital
10 Year Municipal Bond Index.
Target minimum portfolio size is $1 million.
Minimum portfolio sizes may be negotiable under certain circumstances.
As of December 31, 2024, Globalt’s assets under management and advisement were as follows:
Discretionary
$2,809,985,493
Non-Discretionary
$0
Total Assets Under Management
$2,809,985,493
Assets Under Advisement*
$466,248,538
Total Firm Assets*
$ 3,276,234,031
*Assets under Advisement include assets from non-affiliated firms where Globalt provides
investment advisory services and model-based business but has no trading authority, no
discretion to effect trades and no supervisory responsibility over the assets in the program, such
as for its model portfolio provider platform services. Therefore, Assets Under Advisement (AUA)
is different than Assets Under Management (AUM). Total Firm Assets represent the combined
total of both AUM and AUA.
Item 5 – Fees and Compensation
Globalt generally receives a fee from accounts based upon a percentage of assets under
management, calculated according to a schedule agreed upon between Globalt and the client.
The standard fee schedules and minimum account sizes for our strategies described in more
detail in Items 4 and 8 are negotiable on a case-by-case basis and as a result, clients with similar
assets may have differing fee schedules and pay different fees. You may request that related or
household accounts be combined in order to meet fee break points and reduce the advisory fee
charged. We reserve the right to discount or waive the advisory fee for certain accounts such as
employee accounts, family member accounts, and personal accounts of affiliated persons.
investment type, account size, specific
Therefore, fee schedules may vary by client,
circumstance, sponsor and/or platform. Fixed fees, not dependent upon a percentage of assets
under management or account size, may also be indicated via client agreement. Clients who
negotiate a flat fee schedule may or may not pay a higher fee than those who pay under a tiered
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in the client’s
schedule, depending on asset levels. The applicable terms and conditions, as they relate to a
investment management agreement or
particular client, are detailed
correspondence. Fees are typically calculated quarterly based on the market value of the
account and may be payable in advance or in arrears. For some accounts, the fees may be
calculated based upon an average daily account balance for the period.
The advisory fee covers only the investment management and advisory services provided by
Globalt. This fee generally does not include brokerage commissions, transaction fees, mark-ups
and mark-downs, odd lot differentials, exchange fees, SEC fees, dealer spreads or other costs
associated with the purchase and sale of securities, deferred sales charges, advisory fees
charged by other advisors or managers, custodian fees, transfer fees, wire and electronic fund
fees, interest, taxes, or other account expenses. All fees paid to Globalt for investment
management and advisory services are separate and distinct from the fees and expenses,
including internal management fees, charged by mutual funds or exchange traded funds (ETFs)
in conjunction with their internal expenses. An expense ratio is a measurement of what it costs
to operate a mutual fund or ETF. Operating expenses, which include the management fee, are
taken out of a fund’s assets and lower the return to a fund’s investors. These charges are in
addition to Globalt’s advisory fee, and we do not receive any portion of these charges. This is
called layering of fees. For example, layering of fees for a single ETF position of $10,000 could
include the annual Globalt fee of .45%, plus a typical ETF expense of 0.15%. The total cost for the
one ETF position annually would be $60, or .60%. The client will be solely responsible, directly or
indirectly, for these additional expenses. Refer to Item 12 for a detailed discussion of brokerage
practices. Neither Globalt nor any of its supervised persons accept compensation from
commissions or mutual fund trails for the purchase or sale of securities, including asset-based
sales charges or service fees from the sale of mutual funds or ETFs.
Supervised employees typically receive a salary from Globalt, with potential for discretionary
compensation based upon several factors that may include overall company profitability
(growth in assets, profitability/net income, and client retention), departmental performance and
individual goals. Measures and incentive opportunity are determined by Globalt management.
Globalt recognized the potential conflict of interest inherent in compensation associated with
assets under management and performance criteria and manages this risk through a
management review process. Globalt also employs a sales team consisting of external and
internal sales directors or wholesalers to support and enhance distribution of Globalt’s
investment strategies through external channels, including SMA, wrap fee programs and model
portfolio provider platforms with which we work. These team members receive various forms of
compensation, including a percentage of revenue received from new or existing accounts or
relationships. Program fees vary by product type creating an incentive for the sales team and/or
wholesalers to recommend programs to sponsoring firms based on the compensation received.
As a mitigating factor, the sponsoring firm and their other financial advisors perform a suitability
review and work with the client to determine whether the client should invest with Globalt, and
the investment strategy in which to invest.
Investment Advisers that directly debit advisory fees from a client’s custodial account are
deemed to have custody. Globalt may debit the advisory fees from the client’s custodial account
at the client’s direction and would therefore be deemed to have custody. Clients receive
statements directly from their custodian, usually monthly, but no less than quarterly. Globalt
urges clients to review their statements for accuracy and compare them to any reports received
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directly from Globalt. Please refer to Item 15 of this document for additional disclosures relating
to Custody.
An Investment Advisory Agreement may be terminated at any time, by either party, without
penalty, for any reason upon receipt of 30 days written notice, unless stated otherwise in the
Agreement, and in accordance with the terms and conditions stated therein. Any such
termination will not affect the party’s status, obligations or liabilities. If an account is terminated,
the client will receive a refund of any prepaid fees on a prorated basis, determined by the
number of calendar days left in the quarter. Any unpaid investment management fees owed
by the client will be due upon termination.
Globalt’s standard fee schedule for separately managed accounts and discretionary investment
advisory services, not associated with Wrap Fee Programs or Model Portfolio Provider Platforms
are as follows:
Equity Strategies
Between $0 - $1 million
Between $1,000,001 - $5 million
Between $5,000,001 - $10 million
Between $10,000,001 - $50 million
Between $50,000,001 - $100 million
Above $100 million
1.00%
0.70%
0.60%
0.40%
0.30%
0.25%
Fixed Income Strategies
Between $1 million - $2.5 million 0.50%
0.40%
Between $2,500,001 - $5 million
0.35%
Between $5,000,001 - $10 million
0.30%
Between $10,000,001 - $20 million
0.25%
Between $20,000,001 - $30 million
0.20%
Between $30,000,001 - $40 million
Negotiable
Above $40 million
innovatETF Strategies® *
Between $0 - $1 million
Between $1,000,001 - $2 million
Between $2,000,001 - $5 million
Between $5,000,001 - $10 million
Above $10 million
1.10%
1.00%
0.75%
0.50%
Negotiable
*This represents a flat fee versus the tiered approach, which is generally utilized for other products. For
example, a client with an initial portfolio size of $1,500,000 will be billed 1.0% on the entire portfolio.
Wrap Fee Programs:
Wrap fee program sponsors (“wrap fee sponsors”) have contracts with the program client to
provide investment manager and/or custodian services. For these services, the client generally
pays a single all-inclusive fee, based upon the terms of the agreement, to the wrap fee sponsor.
In these programs, the wrap fee sponsor and Globalt enter into a sub-advisory or other licensing
agreement under which Globalt agrees to manage the client’s assets according to the client’s
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risk profile. The wrap fee sponsor is responsible for paying applicable investment management
fee to the appropriate advisory firms, such as Globalt. Each wrap fee sponsor provides a brochure
detailing all applicable aspects, including program features and fees, to the program clients.
Fees and features of each program offered by various sponsors may vary whereby the specific
fees and features may be greater than or less than those described above or from different
sponsors. The wrap fee sponsor determines and calculates the client fee and expenses, generally
based upon a fee based on assets under management (in advance or arrears) or similar formula
in accordance with the agreement between the wrap fee sponsor and the client. The wrap fees
typically include portfolio management, trade execution, custodial and other services provided
by the sponsor or custodian. Globalt is generally paid a portion of the fee by the wrap fee sponsor
for advisory services, while the wrap fee sponsor retains the remainder of the fee. Fees,
depending upon the program offered by the wrap fee sponsor, may be negotiable. For its
advisory and licensing services, Globalt typically receives fees from the wrap fee sponsor ranging
from 0.10% to 0.45% per year of the value of participating accounts. For more information,
including program details, disclosures, fees, and minimum portfolio size, about each wrap fee
sponsor and program, clients should review the wrap fee sponsor’s Form ADV Part 2A -
Appendix 1, Wrap Fee Program Brochure.
Model Portfolio Provider Platform:
Similar to the wrap fee program, model portfolio program platforms (“model platform”) have
contracts with the client to provide investment manager and/or custodian services. For these
services, the client generally pays a single all-inclusive fee, based upon the terms of the
agreement with the model platform. The model platform will then pay the applicable
investment management fee to Globalt. Fees, depending upon the model platform’s program,
may be negotiable. For its advisory services, Globalt typically receives fees from the model
platform ranging from 0.10% to 0.45% per year of the value of participating accounts. For more
information, including program details, disclosures, fees, and minimum portfolio size, about
each model platform and program, clients should review the model platform’s Program
Brochure.
Item 6 – Performance Based Fees and Side-By-Side Management
Globalt does not charge any clients a performance-based fee (fees based on a share of capital
gains or capital appreciation of the assets of a client).
Globalt simultaneously offers advisory services, including wrap fee programs and model
portfolio provider platform programs, according to the same or similar investment strategy.
Such accounts will not necessarily be managed the same at all times due to a variety of factors,
including differences in cash flows, timing of trading, or variations in platform requirements. As
a result, Globalt manages multiple portfolios with similar or identical investment objectives or
trade in same securities across different strategies, the portfolio decisions relating to these
accounts and the resultant performance may differ from portfolio to portfolio.
Item 7 – Types of Clients
Globalt offers investment advisory services to individuals, high net worth individuals,
corporations and institutions, and trust companies, pension and profit-sharing plans, estates
and trusts, charitable organizations, and other investment advisers, such as wrap program
sponsors.
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For ongoing management of each strategy found in Item 4, the minimum portfolio size for
ongoing management is listed. In our sole discretion, we may accept portfolios below these
stated minimums.
With respect to separately managed accounts, wrap fee programs, or model portfolio provider
platform programs, clients should consult the program sponsor or platform for detailed
information on the minimums, fees, and restrictions of each program. Globalt does not impose
investment minimums on model portfolio provider platform programs or UMAs.
Globalt provides offerings to investors seeking to roll over balances held in employer‐sponsored
retirement plans (often referred to as a “rollover”). Individuals with investments in a former
employer’s retirement plan generally have five options for those assets: (1) Leave the
investments in that plan, (2) roll the assets into his/her new employer’s plan, (3) rollover the
money to an Individual Retirement Account, (4) liquidate the investments and cash out the
money, or (5) some combination of the previous four options. Each option presents different
considerations - including tax implications, and no one solution is right for every investor. When
we meet with you about your options we will provide you with a Disclosure of Fiduciary Capacity
document that further discloses the requirement for us to act in your best interest, and we also
encourage you to talk with your adviser about these options and to consult with a tax
professional regarding the potential impacts each of the options may have to your specific
situation. Globalt has an economic incentive to recommend a rollover because assets rolled into
one of our strategies will generate investment management fees. In discussing and evaluating
your options, it is important you know you are under no obligation to rollover assets to us.
Information about minimum account size requirements for each Program can be found in Item
4 of this Brochure.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Globalt primarily offers three investment advisory strategies, Equity, Fixed Income and the
innovatETF Strategies® that span multiple investment styles and are designed to serve multiple
investor objectives, with active management. Within each of these three major investment
strategies, Globalt offers various strategy subcategories to focus on different investment
objectives, benchmarks and risk attributes. Strategies are managed by the Investment Policy
Committee using a team approach. The goal of the investment process is to deliver competitive
returns versus the appropriate benchmarks for each investment strategy over market cycles.
Globalt’s investment evaluation places emphasis on the “weight of the evidence” approach and
reliance upon quantitative, technical and fundamental analysis of issuers of equity, debt and
managed securities.
• Quantitative Analysis: involves market behavior analysis, through the use of complex
mathematical and statistical modeling, measurement and research.
• Technical Analysis: involves past market data analysis, specifically price and volume, and
use of performance charts and patterns that may predict favorable conditions for buying
or selling a security.
• Fundamental Analysis: involves reviewing financial statements and management teams
to gain a better understanding of a company’s general financial health and to identify
potential competitive advantages, relative to competition, that company may have.
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The Equity strategies utilize quantitative, fundamental, and technical analysis to identify the
most appropriate securities for each investment strategy. For the quantitative analysis, Globalt
begins with a proprietary database of companies, and scores the companies for historical and
prospective growth and value in order to identify attractive companies with scores in the top
40% of the relative universe. Utilizing fundamental analysis, these portfolio candidates are then
evaluated for global competitiveness, industry leadership, sector risks (including economic,
political, regional risks) and company specific risks (including pricing valuations, product cycles,
margins, legal, etc.) to determine potential additions to or deletions from the portfolios. Globalt
continues with technical analysis to identify those companies with an attractive technical
outlook, based upon relative strength by sector, by company and overall price trend analysis.
The Fixed Income strategies utilize a four-step approach to identify the securities most
appropriate for each portfolio: identifying secular trends; evaluating cyclical patterns; security
selection and sector allocation; and ongoing monitoring. To identify secular trends, the Globalt
team evaluates monetary and fiscal policy, unemployment trends, inflation, risk premiums and
GDP. Cyclical patterns are identified by evaluating market sentiment, sector rotation and
structural preferences. Securities are identified for inclusion in the portfolio by incorporating
sector allocation (including the appropriate benchmark weightings, relative value and specific
sector trends) and security selection (using credit research and supply/demand for specific
securities). Positions are continually monitored to determine whether any changes to the
investments are warranted.
The innovatETF Strategies® utilize a proprietary asset allocation approach, developed by
Globalt with the resources of Ned Davis Research. Our goal is to focus on and develop the
appropriate asset allocation strategies and to rebalance as market and economic conditions
warrant using a strategic and tactical approach. Each model strategy is built around a flexible
strategic asset allocation with asset ranges or bands for the major asset classes. The strategies
invest primarily in exchange-traded funds (ETFs) representing various asset classes, sectors,
industries, regions or countries required for each portfolio to meet its investment objective.
Globalt begins with an assessment of major asset classes and approximately 150 indicators (such
as economic conditions, political, market sentiment, government policies and market factors).
The strategic approach allocates investments across multiple asset classes, and the tactical
evaluation considers country, market, sector, and asset class momentum. The analysis process
along with a risk/volatility assessment determines the most attractive relative asset class
weightings. When trends and assessment indicate a relatively stable environment, the
strategies tend towards higher allocations, within the asset bands, to risk assets (e.g., equities)
which generally have a favorable forecast for price appreciation. When the indicators and model
indicate more volatility, risk and/or decelerating growth trends, then we will seek to increase
defensive allocations to fixed income, cash and inverse equity. Inverse ETFs generally rise when
the associated market index is falling (and vice versa) and may be utilized to hedge the portfolios
against market declines or to more efficiently position portfolios for opportunities to maintain
value during extended periods. There is no certainty that inverse ETFs will work always as
expected. It should be understood that hedging techniques such as inverse ETFs may not
always be available when desired and may not be effective in minimizing losses.
Globalt offers diversified strategies with capital appreciation as a primary investment objective
as well as strategies with objectives for income and for international exposure. In the income
growth strategy, the portfolio manager may utilize bonds, fixed income, common & preferred
stock, REITS, and other income-generating securities with ETFs.
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Clients should be aware that there is a material risk of loss (see Appendix A). In each of the
strategies listed above, we may utilize inverse ETFs, which potentially carry increased risk.
Because inverse ETFs are sophisticated investments and may not be suitable for all clients, and
due to restrictions against their use by some custodians, wrap fee programs or model portfolio
provider platforms, Globalt will construct and manage portfolios that exclude inverse ETFs
accordingly. The strategies and models do not incorporate leveraged securities.
All allocations or holdings within Globalt’s investment strategies are subject to change at any
time without notice. Asset allocation does not ensure a profit or protect against a loss.
We have included in Appendix A of this brochure a list of common risks and their definitions.
The list is not meant to be exhaustive of all risks, but rather to help our clients better understand
each investment management program involves certain risks.
Summary of Material Risks:
Investing in securities involves risk of loss that clients should be prepared to assume. Globalt
uses its best judgment and good faith efforts in providing advisory services to clients. Globalt
cannot warrant or guarantee any particular level of account performance, or that an account
will be profitable over time. Since the identification of attractive investment opportunities is
difficult and involves a high degree of uncertainty, not every investment decision or
recommendation made by Globalt will be profitable. Globalt primarily manages risk through
the quantitative, technical and fundamental analysis on equity, fixed income, and asset
allocation strategies. Our Investment Policy Committee is largely responsible for monitoring risk
in the strategies, in the portfolios and in the selection of individual securities. Strategies and
portfolios are monitored against their applicable benchmarks. Globalt is not able to mitigate,
project or anticipate all risks that may impact strategies, portfolios, and securities. While it
generally recommends diversified portfolios constructed to meet the client’s goals and
objectives, Globalt cannot guarantee any level of performance, nor promise or make
assumptions that any strategy or service will provide a better return than other investment
strategies or that account assets will not be lost.
Investments in securities are subject to various risks. Appendix A: Risk Definitions provides term
definitions associated with these risks, including but not limited to:
• General Investing Risks: Over time, investments may be volatile, experience sharp
declines in value, and may result in losses. Stock markets and bond markets,
domestically and internationally, fluctuate substantially over time. Globalt does not
represent, warrant or imply that the services, strategies, products or methods of analysis
used can or will predict future results, successfully identify market tops or bottoms, or
insulate against losses from market corrections. General investing risks include but are
not limited to economic, market and sociopolitical risks, country risks, business cycle
risks, inflation and interest rate risks, liquidity risks, diversification risks, tax risks, legal or
regulatory risk, commodity price risk, currency and foreign exchange risks. The specific
risks associated with particular strategies depend upon the approaches used and the
extent to which the strategy employs certain portfolio management techniques,
including diversification.
• Active Management Risks: Globalt’s subjective investment decisions, supported by the
quantitative, technical, and fundamental analysis, may result in a client portfolio
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incurring
losses or missing profit opportunities. Risks associated with active
management include model risk, timing risk of purchases or sells, industry and security
selection risk, correlation risk and tracking error risk, on a daily or aggregate basis. Other
factors which may impact the strategies include fees, trading expenses, regulatory
policies, correlation and index composition changes, and turnover rate,
• Equity Investing Risk: In addition to the General Investing Risks and Active Management
Risks, strategies that are equity focused may be sensitive to security selection, specific
events with the issuers or sectors and industries. market capitalization, earnings, liquidity
and valuation,
• Fixed Income Investing Risk: In addition to the General Investing Risks and Active
Management Risks, strategies that are fixed income focused involve a number of
material risks including but not limited to yield curve, inflation, credit rating and issuer
quality risk, call risk, counterparty risk, availability, diversification risk, reinvestment risk,
and valuation risk,
• Exchange Traded Fund Risk: In addition to the General Investing Risks and Active
Management Risks, ETFs are a type of Investment Company (usually, an open-end fund
or unit investment trust) containing a basket of stocks. Typically, the objective of an ETF
is to achieve returns similar to a particular market index, including sector or sub-asset
class indexes. Although ETFs themselves are generally classified as equities, the
underlying holdings of ETFs can include a variety of asset classes, including but not
limited to equities, bonds, foreign currencies, physical commodities and derivatives. A
full disclosure of the specific risks of ETFs is located in the respective prospectus of each
fund. An ETF is similar to an index fund in that it will primarily invest in securities of
companies that are included in a selected market. Unlike traditional mutual funds, which
can only be redeemed at the end of the trading day, ETFs trade throughout the day on
an exchange. ETF prices fluctuate throughout the day and during times of extreme
market volatility, ETF pricing may lag versus the actual underlying asset values. ETFs are
subject to tracking error risks, concentration, currency, dispersion risk, hedging, trading
volume risk, expenses and fee risk, and time horizon risk. Because of these factors, ETFs
may not be able to exactly replicate the performance of their associated index. These
risks may be magnified in funds with concentrated or non-diversified holdings. Non-
leveraged inverse ETFs seek returns that are -1x the return of the benchmark index for a
single day, as measured from one NAV calculation to the next. Over time periods greater
than a day, their performance can significantly differ in amount and possible direction
from that index benchmark. While inverse ETFs can be useful in some situations, as
described in Item 8 above, they can be more expensive and can result in losses to
investors. In all cases, investment returns will fluctuate and are subject to market
volatility.
Item 9 – Disciplinary Information
Registered Investment Advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of Globalt or the integrity of
Globalt’s management. Globalt has no legal or disciplinary events to report.
Item 10 – Other Financial Industry Activities and Affiliations
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Globalt does not have any other financial industry activities or affiliations.
Item 11 – Code of Ethics
Code of Ethics:
Globalt believes that we owe clients the highest level of trust and fair dealing. Globalt’s Code of
Ethics (the “Code”) sets forth a professional business standard to guide Globalt and its
employees to place the clients’ interests before its own. No person shall prefer his or her own
interest to that of the advisory client. Globalt requires all individuals to act in accordance with
all applicable federal, state and regulatory agency regulations governing investment advisory
practices. The standards of conduct outline our fiduciary responsibilities, and the Code includes
our policies related to insider trading, personal securities transactions, privacy of client
information and reporting requirements.
Certain Globalt members and employees
(“Related Persons”) are also clients or
investors. Globalt may invest client accounts in, among other things, securities in which Globalt
or its Related Persons have a financial interest. Globalt or its Related Persons may purchase for
themselves securities or other investments which one or more clients own, previously owned,
or will own in the future. As these situations may represent a potential conflict of interest,
Globalt has adopted procedures relating to personal securities transactions and insider trading,
both of which are described below, that are reasonably designed to prevent actual conflicts of
interest. There may be times when the sale or purchase of a security for a Related Person may
precede, occur at the same time, or follow the sale or purchase of a security for a client, subject
to the overriding principle that the interests of clients must come before the interests of Globalt
or its Related Persons.
Globalt’s Code of Ethics is reasonably designed to ensure that the personal securities
transactions and interests of the employees will not interfere with making decisions in the best
interest of clients. Nonetheless, because the Code permits employees to invest in the same
securities as clients, there is a possibility that employees might benefit from market activity by
a client. Employees are required to provide a quarterly report to the Chief Compliance Officer,
showing investment transactions in their personal accounts, as well as disclosing annually all
securities held on their behalf. Certain securities are exempt from reporting based upon the
determination that these would not pose any material conflicts. These reports are monitored
regularly to reasonably prevent conflicts of interest between Globalt and its clients.
Globalt may manage simultaneously parallel accounts in some cases with the same portfolio
managers, with similar objectives, but with differing fees to Globalt. Globalt’s policy is to manage
each account independently and fairly, and to recognize and strive to control the conflicts of
interests inherent in such practices.
Clients or prospective clients may request a copy of the firm’s Code of Ethics by contacting
Globalt’s Chief Compliance Officer, Annette M. Marshall at 678-802-4433 or 877-438-6956.
Item 12 – Brokerage Practices
Globalt has discretion over those accounts under its management as specified in the
contractual advisory agreement it enters into with the client. Under that agreement, Globalt
determines which securities are bought or sold for an account, the amount of such securities
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and the timing of the purchases and sales. Except as specifically directed by the client, Globalt
determines the broker through which transactions are affected and the commission rates or
spreads paid. Globalt buys or sells specific securities in amounts consistent with the client’s
defined strategy, any reasonable restrictions accepted by Globalt, objectives and tolerance for
risk.
Obtaining best execution is an important aspect of every trade that we place in client
accounts. Best execution can be described as seeking the most favorable terms for completing
client transactions considering all relevant circumstances at the time. Globalt has a Trade
Oversight Committee that administers our Trade Oversight (Best Execution) program and
provides oversight of its trading practices, including execution quality, trade review, trade errors,
soft dollars, directed brokerage, broker review, trade aggregation and training/education. The
goal of the Trade Oversight Committee is to reasonably design, implement and monitor a best
practices approach to trading practices to ensure transactions are executed to seek the most
favorable terms reasonably available under the circumstances and in a manner that is
consistent with Globalt’s fiduciary responsibility to place interests of clients above corporate and
personal interests and to develop and implement trading practices that best meet each client’s
investment objectives and directions.
Globalt’s Investment Policy Committee (IPC) evaluates and selects brokers for client
transactions. When applicable, a tier list is developed based upon investment services, order
processing and execution capability expectations to be received from those brokers. Trading
and Operations track updates to the tier list, should one be developed, and the list(s) are
provided to the Trade Oversight Committee for reporting purposes. In evaluation of the tier list,
commissions and related transaction costs are an important factor, but other judgment factors
may also be considered. These factors include, without limitation:
• Nature of the security being traded
• Size of the transaction
• Client-specific needs and circumstances
• Broker's stability, financial standing and business circumstances
• Broker's execution, clearance and settlement capabilities
• Past experience with a particular broker
• Research services available from the broker
The brokers selected by the IPC are then placed on an approved brokers list and is then used by
Trading to place orders. Brokers may be added or deleted, or commission targets revised as
approved by the IPC. Trading may provide alternative trading solutions, from time to time, to
the broker tier list when it is in the client’s best interest. The IPC and Trading sets targets when
appropriate for the approximate amount of commissions to direct to each broker. The Trade
Oversight Committee reviews the broker selection process,
including the review of
commissions subject to any soft dollar arrangements. In limited circumstances, traders are
permitted to use brokers that are not on the approved list; however, trading activity is reviewed
and monitored by the Trade Oversight Committee.
Soft dollar practices or commission sharing arrangements (CSAs) refer to the practice of an
investment adviser paying brokers for investment research and other brokerage services, either
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provided directly by the brokers or by others (known as third party providers), using commission
dollars generated by client transactions. CSAs are a type of soft dollar arrangement that allows
the investment manager to separately pay the executing broker for execution and ask that
broker to allocate a portion of the commission directly to an independent research provider.
Section 28(e) of the Securities Exchange Act permits advisers to use soft dollars, whereas a
portion of client commissions is used to purchase research and brokerage services that assist
the adviser in managing client accounts. Under the soft dollar arrangements, Globalt receives
both proprietary research created and developed by the brokers as well as third party research.
The types of eligible research include but are not limited to: research reports on companies,
industries and sectors; economic and financial data; financial publications; market data and
quotation services; asset allocation; and portfolio analytics.
The following list describes some of the research products Globalt receives, from time-to-time,
with soft dollar benefits. The list is subject to change without notice.
• FACTSET: a comprehensive integrated solution for qualitative and quantitative
portfolio research and analysis, including but not limited to managed data feeds
(market, news, and research), analytics (equity, portfolio, quant and risk, fixed income,
market), and portfolio/strategy simulations and testing.
• Ned Davis Research: Equity and fixed income market data, sectors and industries,
individual security analysis, asset allocation charts and asset class rankings.
Globalt recognizes that using client commissions for research products may create a conflict of
interest because Globalt does not have to pay for the products. This may give Globalt an
incentive to use a particular broker based on Globalt’s interest in receiving the products rather
than the client’s interest in receiving the most favorable execution. Clients may pay more than
the lowest available commission for executing a transaction in order for Globalt to receive these
benefits. Nonetheless, Globalt believes the commissions paid by the client are reasonable in
relation to the value of the research and brokerage services received from the brokers and/or
third-party providers.
While Globalt intends to use all research products and brokerage services obtained through soft
dollar arrangements to benefit all client accounts, the brokerage commissions paid by a client may
be used to pay for research that is not used in managing that particular client’s account.
Directed Brokerage:
Clients may direct Globalt to use a particular broker to execute client transactions. Clients that
choose to designate a particular broker should consider that such designation may result in
certain costs or disadvantages to the client, either because the client may pay higher
commissions on transactions than might otherwise be attainable by Globalt or the client may
receive less favorable execution. Directing brokerage impedes Globalt's ability to include the
client's account in block trades on the same terms as non-directed clients.
By directing Globalt to use a specific broker, clients who are subject to ERISA confirm that they
have the authority to make the direction; that there are no provisions in any client or plan
document which are inconsistent with the direction; that the brokerage and other goods and
services provided by the broker through the brokerage transactions are provided solely to and
for the benefit of the client's plan, plan participants and their beneficiaries; that the amount paid
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for the brokerage and other services has been determined by the client and the plan to be
reasonable; that any expenses paid by the broker on behalf of the plan are expenses that the
plan would otherwise be obligated to pay; and that the designated broker is not a party-in-
interest of the client or the plan as defined under applicable ERISA regulations.
When placing trades for directed accounts and providing notification of model changes to
model provider platform programs, Globalt seeks to ensure that, over time, no client, group of
clients or platform is disadvantaged by Globalt’s trading practices. Globalt utilizes a
trade/notification rotation cycle that assigns each broker and platform a position in a queue. On
a daily basis that position rotates such that the broker whose trades are executed first/or
platform which received notification first will subsequently be executed/or receive notification
last in the subsequent cycle. This ensures that no client, group of clients or platform is given
preferential treatment. Likewise, no client, group of clients or platform is consistently
disadvantaged. Regarding model changes to model provider platform programs, Globalt does
not generally exercise trading discretion over the associated Unified Managed Accounts (UMA)
client accounts.
In evaluating the wrap fee arrangement, a client should recognize that the sponsor firm is solely
responsible for establishing brokerage commissions for transaction execution. When so
indicated, Globalt will, subject to its duty to seek best execution, execute trades through the
sponsoring broker. Since no additional commissions are charged to execute transactions
through the sponsor, best execution is typically achieved through the sponsor.
As is true for almost all of our client accounts, there are generally two instances in which we
make trades in the accounts:
• The first is when we alter our overall investment model upon which our accounts are
based. Under such circumstances we ordinarily adjust all accounts in the related
strategy, and the change in the investment model will result in an “across the board”
trade;
• The second is when trades are associated with a specific account level activity (e.g.,
account open, funding, withdrawals, liquidations, etc.) in the account.
Trade Allocation/Block:
In accordance with Globalt’s goal to achieve best execution for client transactions and when
appropriate to do so, Globalt generally aggregates or blocks individual client orders into a larger
single order with the intention of achieving more favorable execution and preferential
commission rates. When a block trade is completed, the price may be averaged so that each
account participating in the trade may receive the same price. If a specific equity or ETF block
is not filled in its entirety, Globalt will allocate shares to each account participating in the trade
on a pro rata basis, in accordance with the size of their individual client order. Allocations of any
partial fills of equities will be prorated across all client accounts participating in the specific
strategy for which the indication was given. For fixed income securities, if the pro-rata allocation
would result in amounts of less than $500,000, the portfolio manager may buy a comparable
security in any account that did not participate in the original purchase. For initial public
offerings in the case of equities or new issues in the case of fixed income, indications will be
given by specific strategy (i.e., Large Cap Core, Intermediate Fixed Income, etc.). To the extent
that the limited availability of a security would result in a de minimis allocation, Globalt may
exclude those accounts from the order.
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In some situations, in an effort to achieve best execution as well as to aggregate prices among
many accounts, step-outs are used. In a step-out, one broker, the executing broker, executes a
block trade and then gives up (“steps-out”) the shares to one or more brokers. These brokers
will directly bill these shares to the client accounts as if they were the executing or directed
broker. At times, there may be multiple stepped-out brokers receiving portions of a trade. Each
broker may receive a commission or brokerage fee with respect to that portion of the
transaction that it settles and completes.
Globalt may step-out trades if it determines that the step-out is in the clients’ best interest. For
example, there are certain across-the-board trades, where the security trade is best aggregated,
that a step-out is deemed in the clients’ best interest. Clients in a wrap-fee program will
therefore incur additional commissions and fees (generally, up to $0.01 per share) beyond the
wrap fee program fee due to participating in the stepped-out trade. The commissions paid on
trades executed away from the sponsors are reflected in the transaction price at which the
securities are bought or sold (rather than being separately stated or charged, resulting in a
higher or lower potential price). Step-outs and associated fees/charges are evaluated on a case-
by-case basis. Globalt believes that stepping out these trades helps us to achieve best execution.
By stepping out the trade, we believe we are best able to: minimize the risk of market movement
in pricing, achieve competitive pricing, access additional sources of liquidity and assure that all
participating clients receive the same execution price. Please note that some sponsor firms and
directed brokers may not permit the use of step-out trades. Generally, the executing broker will
charge a mark-up or mark-down to execute the step-out order.
Item 13 – Review of Accounts
Globalt assigns each managed account to a portfolio manager. Each account is invested in a
specific investment strategy, as described in Item 4 above. Portfolio managers regularly review
each strategy with support from the Investment Policy Committee (IPC). The IPC generally
meets one or more times each week to discuss market related issues, changes to companies in
the Globalt universe, and to review the status of the managed strategies. Within the IPC, the
asset allocation strategies are reviewed on a monthly basis or more frequently, as warranted.
Portfolio Managers are responsible for ensuring that the accounts and securities selected
comply with the investment objectives of the particular strategy. The Trading and Operations
department regularly reviews cash flows and cash balances to identify accounts in need of
rebalancing.
Clients receive account statements directly from their custodian usually monthly, but no less
frequently than quarterly. For SMA accounts, Globalt also sends quarterly reports to clients that
may include holdings, valuations and/or performance. Clients may request reports more
frequently or as needed. Clients in separately managed accounts or in a wrap fee programs
typically receive reports directly from the sponsor. Depending on the sponsor and the program,
Globalt may provide quarterly reports as well. In addition to these reports, correspondence,
including quarterly review and economic outlook reviews may be provided to clients. Globalt
urges clients to compare information contained in its reports with information contained in the
report received directly from the account custodian. Globalt does not generally provide
statements or reports for model portfolio provider platform clients. Wrap fee program clients
and/or model portfolio platform program clients should consult their program’s disclosure
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statement for types of reports that they will receive from the associated program sponsor or
platform.
Item 14 – Client Referrals and Other Compensation
Globalt has no agreement(s) with third-party promoters that provide endorsements of Globalt.
Globalt does continue to compensate a former affiliate pursuant to a promoter agreement that
was in place several years ago in accordance with the surviving terms of that agreement for an
account that was gained as a result of the agreement.
Globalt, from time to time, will enter into agreements and licensing arrangements with wrap
fee and model portfolio provider program parties for which it will receive a portion of the fees
collected under the terms of those agreements. Item 4 above provides more details regarding
these arrangements.
Item 15 – Custody
Globalt is deemed to have “custody” because investment advisory fees may be directly debited
from client accounts. Globalt does not have direct physical custody of any client funds and/or
securities. Debiting of fees is done pursuant to authorization provided by each client.
Clients should receive at least quarterly statements from their broker dealer, bank or other
qualified custodian that holds and maintains client’s investment assets. Globalt must be
reasonably certain that the client’s qualified custodian provides at least quarterly statements
directly to them. Custodial statements include account holdings, market values and any activity
that occurred during the period, including the deduction of applicable investment advisory fees.
Clients are encouraged to carefully review such statements for accuracy and compare such
official custodial records to the reports Globalt may provide; noting that Globalt’s reports may
vary from the custodial statements based upon accounting procedures, reporting dates, or
valuation methodologies of certain securities. Clients with questions regarding their account
reports should contact Globalt at 404-364-2188.
Item 16 – Investment Discretion
Globalt manages client portfolios on a discretionary basis and receives discretionary authority
from the client at the outset of an advisory relationship, as established with the investment
advisory agreement. This discretionary authority authorizes Globalt to determine the specific
securities to be bought or sold, the number of securities to be bought or sold, the broker or
dealer used to execute trades and the commission rate paid by clients, consistent with the
stated objectives, policies, limitations and restrictions for the particular client account. A client
may, with Globalt’s consent, impose reasonable restrictions, guidelines or limitations on
investments in certain securities, types of securities, or industries in its account. These
limitations or restrictions are negotiated individually with each client at the outset of the
relationship and may be modified by notifying Globalt in writing.
Globalt also offers non-discretionary investment advice through Unified Managed Accounts
(UMAs), model strategists or similar platforms where Globalt provides Model Portfolio
recommendations but has no responsibility for effecting trades on behalf of any client.
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Item 17 – Voting Client Securities
Globalt does not, generally, vote proxies on a client’s behalf. However, Globalt has agreed to
vote or chosen to vote on behalf of clients in certain strategies through a third-party
administrator. Globalt is not required to vote proxies on a client’s behalf. Clients that retain proxy
voting responsibilities will receive all issuer communications from their custodian.
Proxy Policy:
Globalt has engaged Glass Lewis & Co. (“Glass Lewis”) as our third-party proxy administrator for
clients that Globalt has agreed to vote their proxies (including a “named fiduciary” under ERISA)
or as required in plan documents. Globalt has adopted the proxy voting guidelines of Glass Lewis
& Co. Glass Lewis. When the responsibility to vote proxies has been assigned to Globalt, our
utmost concern is that all decisions be made solely in the best interest of the client (and for
ERISA accounts, plan beneficiaries and participants, in accordance with the letter and spirit of
ERISA). Globalt through Glass Lewis will vote in a prudent and diligent manner intended to
enhance shareholder value. For proxy issues that fall outside of the adopted proxy guidelines,
Glass Lewis provides Globalt with in-depth research on proxies issued by the companies in our
clients’ portfolios and voting recommendations for proposals contained in those proxies.
Globalt has complete decision-making authority and instructs Glass Lewis whether to vote in
accordance with or contrary to their recommendations. Proxies are voted and other corporate
actions are acted on in a timely manner. Corporate actions may include, for example, and
without limitation, tender offers or exchanges, bankruptcy proceedings, and class actions.
In situations where a material conflict of interest arises between Globalt and an issue on the
ballot (e.g., where Globalt has a financial interest in the outcome of the vote), Glass Lewis, in
accordance with the proxy policy adopted by Globalt, would vote proxies based on their
recommendation.
Environmental, Social and Governance Proxy Policy:
Globalt by way of Glass Lewis, our third-party proxy administrator, will vote proxies for clients
invested in the Environmental, Social and Governance strategy. Clients invested in the ESG
Equity strategy may choose to retain proxy voting authority.
Clients can receive a copy of Globalt’s Proxy Voting Guidelines or obtain information on how
votes were cast on their behalf by making a written request to Annette M. Marshall, Chief
Compliance Officer.
Item 18 – Financial Information
Registered investment advisers are required to provide you with certain financial information
or disclosures about their financial condition. Globalt 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 proceeding.
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Appendix A: Risk Definitions
All investments offer varying degrees of balance between risk and potential return. As an
example, an investor’s exposure to investment risk typically increases in exchange for
opportunities to achieve higher returns. Item 4 above details Globalt’s Advisory Business,
including the investment services offered to clients. The risk definitions below are intended to
assist clients in understanding certain risks associated in investing in our strategies and to
provide information to help make informed investment decisions, though it is not an exhaustive
list of all potential investment risks and may not be applicable for all investment strategies.
Business Cycle Risk
The risk that cyclical business cycles, with periods of peak
performance followed by a downturn, then a trough of low activity,
affect the returns of an investment, an asset class or an individual
company’s profits.
Call Risk
See reinvestment risk. Some corporate, municipal and agency
bonds have a “call provision” entitling their issuers to redeem them
at a specified price on a date prior to maturity. Declining interest
rates may accelerate the redemption of a callable bond, causing an
investor’s principal to be returned sooner than expected. In that
scenario, investors have to reinvest the principal at the lower
interest rates than they may have had prior.
Collateral Account Risk
A client may enter into a separate securities agreement with a
creditor, bank, broker dealer or other financial institution (together,
“creditor”) to pledge securities or assets against a loan or collateral
amount. This agreement grants the creditor a security interest to
transfer, sell, redeem, close open trade or otherwise liquidate any
assets in the account (including instructions to transfer assets
directly) in the pledged assets or collateral account. Adverse
market conditions can impact the value of the value of the pledged
securities causing the portfolio value to decline. This may result in
the client to pledge additional assets, pay down the line of credit or
the creditor may instruct the adviser and/or custodian to sell
pledged assets, which depending on market conditions may result
in receiving less for the securities than the original purchase price.
Declining market conditions may also limit the client’s ability to
draw upon their account. Long-term investment strategies and
goals may be adversely impacted by the creditor’s actions, as they
may instruct the adviser to sell some or all of the pledged assets as
payment against the loan. In this instance, since the creditor
agreement may provide certain rights, the client may not be able
to choose which securities are liquidated and the client would also
be responsible for any loan shortfall after such sale. There is no
guarantee that investment account returns will meet or exceed
loan costs.
Commodity Price Risk
The possibility that fluctuations
in the price, shortage or
overabundance of material inputs, such as fuel, energy, raw
materials, metals, manpower, etc. will materially impact operating
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reduce
the
a company, production of goods/services or
attractiveness or price of an investment.
Composition Risk
result
The possibility that changes in an index, resulting from security
membership, market capitalization and weighting, and investment
guide changes may increase the relative dispersion for a strategy
and
in unexpected performance variance. Security
membership, being added, reduced or weight changed, in an index
may result in security prices changes.
Consumers Risk
The risk when clients are exposed to unsuitable investments that
they do not fully understand.
Correlation Risk
See Diversification Risk - When portfolio holdings are too highly
correlated with each other, meaning that the move up and down
in value together, there may be insufficient diversification to
counter market or security risks.
Counterparty Risk
Also called default risk. Counterparty risk occurs when one or more
parties to an agreement, such as a bond, defaults and does not
fulfill their contractual obligation, such as payments or principal.
For example, a bond issuer with a lower quality rating may have a
higher default risk and its bonds will need to pay a higher yield than
an issuer with a higher rating.
Credit Rating / Issuer
Quality Risk
Credit rating agencies provide analysis and comparative opinions
on the bond issuer's ability and willingness to meet its financial
obligations. For bond holders, risk occurs when the opinion
changes, resulting in a lower rating, which may decrease the
current holding value and may make it more expensive, in the form
of higher interest rates, for the issuer to raise new debt to meet
future obligations. Credit ratings are not indications of investment
merit but are a significant factor in the investment decision.
Generally, the higher the credit rating, the higher the bond price
relative to the yield rate.
Currency / Foreign
Exchange Risk
Also called foreign exchange risk and implies international
investing: the possibility that the relative change in currency value
from one country to another will reduce the investment value
when converted back from one currency to the other.
Dispersion Risk
The uncertainty risk associated when an investment strategy is not
in accordance with its model, resulting in performance or risk that
is less or greater than expected.
Diversification Risk
Diversification means to reduce risk by investing in a variety of
assets, and generally in assets that do not move up or down in value
together (correlate). There are two forms of diversification risk: A
portfolio that is relatively undiversified, such as having a single
security or positively correlated holdings may be more volatile and
value sensitive to the security’s market actions. A portfolio that is
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too diversified may result in a proxy for an index and not provide
acceptable returns relative to the fees or expenses incurred with a
managed account.
Economic Risk
The risk that economic conditions, such as government
regulations, tax policies, political or social instability, workforce, or
exchange rates will negatively affect investments, usually one in a
foreign country. Economic risk
is one of the reasons why
international investing, especially in emerging countries, carries
more risk than domestic investing.
Expenses and Fees Risk
like mutual funds, generally
Exchange traded funds,
incur
operating expenses for management, record-keeping, custodial
services, taxes, legal, accounting and audit fees, which are taken
from the fund's assets and lower investor return. Different funds
may have different expenses and fees ratios, relative to the fund
assets. Therefore, selection of a fund with higher expenses and fees
may have lower performance than a comparable fund with a lower
expense ratio.
Industry Risk
The possibility of investment losses related to a specific industry or
market sector stemming from economic or regulatory change,
instability, volatility or market shift from a particular industry. These
losses may increase in relation to the overall portfolio weighting
towards that industry.
Inflation Risk
Inflation causes tomorrow’s dollar to be worth less than today’s.
Inflation reduces the purchasing power of a bond investor’s future
interest payments and principal, collectively known as “cash flows.”
Inflation also leads to higher interest rates, which in turn leads to
lower bond prices.
Interest Rate Risk
The possibility that the value of a security, especially a bond, will
reduce as a resulting from a rise in interest rates.
Inverse ETFs
Inverse ETFs are designed to replicate the opposite direction of the
matching or indicated index. These ETFs often use a combination
of futures, swaps, short sales, and other derivatives to achieve these
inverse objectives. As complex products, inverse ETFs may not
track the underlying or contra benchmark as expected and are
designed to achieve those results on a daily basis only. That means
that over periods longer than a trading day, the value of these ETFS
can and usually do deviate from the performance of the contra
index that they are designed to track. Over longer periods of time
or
in situations of high volatility, these deviations can be
substantial.
Legal Risk
The risk that a legal contract or financial transaction will not be
fulfilled because it breaks a law or there is a regulatory conflict. In
addition, companies involved in legal actions may have to increase
cash reserves for settlement, which may restrict their growth
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ability, lower their relative profit or income potential, and be more
volatile.
Liquidity Risk
The risk that investors may have difficulty finding a buyer when
they want to sell a security and may be forced to sell at a significant
discount to its expected market value. Liquidity risk is greater for
thinly traded securities.
Market Capitalization
Risk
regardless of
the
A company's market capitalization, one measure of potential
growth, is the value calculated from the company's shares
outstanding multiplied by the price per share. The basic market cap
categories are large-cap, mid-cap and small-cap. Large-cap stocks,
representing companies over $10 billion in size, are generally
researched and followed more by analysts or investors. Many large-
cap companies are called “Blue Chips”. Large-caps historically
experience comparatively slower growth, with less risk, than
smaller-sized companies. Smaller-sized companies typically are not
as financially strong but are expected to grow at a faster rate with
greater investment return potential. Smaller-sized companies and
funds may experience greater up/down price and value volatility.
Within investment guidelines, many strategies, ETFs or mutual
funds focus their funds on investing in specific market cap sized
companies. Market capitalization risk exists when comparative-
sized companies, such as large, mid- or small-caps as a whole and
the ETFs and funds targeted to the cap, would decline, bringing the
associated values down
fundamental
characteristics or investment potential. Strategy allocations that
over- or under-weight asset classes, including market caps, may
have greater volatility, missed return potential, or relative loss.
Market Risk
Also called systematic or undiversifiable risk: The risk that the stock
or bond market as a whole would decline, bringing the value of
individual securities down with it regardless of their fundamental
characteristics or investment potential.
Model Risk
The possibility that the analysis, investment or allocation decisions
for a strategy model may be unreliable or provide incorrect signals
in volatile market conditions.
Pandemic Risk
The possibility of a large-scale outbreak of infectious disease that
can greatly
increase morbidity and mortality over a wide
geographic area, crossing international boundaries, and causing
significant economic, social, and political disruption.
Regulatory Risk
The risk that a change in laws and regulations will materially
impact, increase the costs of operating a business, reduce the
attractiveness of investment and/or change the competitive
sector or market.
security, business,
landscape
for a
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Reinvestment Risk
Also see inflation risk. Risk occurs, especially in a declining interest
rate environment, when an income producing bond or security is
sold or called and the reinvested funds may yield a lower rate than
the original security. The reinvested assets may provide a lower
cash flow than expected or required to meet the investor’s
investment objectives.
Security Selection Risk
The risk that an investor chooses a security that underperforms the
market for reasons that cannot be anticipated. The possibility of
investment losses related to a specific company or security
stemming from economic or regulatory change, business climate,
earnings surprise or legal action relative to a specific company.
These losses may increase in relation to the security's overall
portfolio weighting.
Sociopolitical Risk
The danger that political or cultural changes or instability in a
location or a country could turn against an investment.
Tax Risk
For taxable accounts, the possibility that the security holdings,
interest, dividends and timing of the buys/sell transactions will
increase one's tax liability. Tax risk may also occur when investing
just prior to dividend or capital gain activities for ETFs or mutual
funds.
Time Horizon Risk
Investment time horizon generally reflects the total length of time
the investor expects to invest before the assets are utilized for their
financial goal, such as retirement income. Because different
security types, such as equities, bonds and cash have different
reward and risk characteristics, a client's time horizon is important
in influencing the investment and strategy decisions. Generally, the
shorter the client's time horizon, the less time available to the client
to recover from any incurred losses.
Timing Risk
The risk that an investment performs poorly after its purchase or
better after its sale. This risk may reflect security selection made
either too soon or too late, relative to historical review, and thereby
missing profit opportunities or increasing loss potential.
Tracking Error Risk
Also called active risk. The possibility that a security, such as ETF or
mutual fund, deviates from and does not accurately track its
defined index or benchmark. The fund does not work as effectively
as intended, resulting in unexpected asset allocation and price
behavior for the holding.
Trading Volume Risk
Trading volume occurs as a direct result of supply and demand.
Generally, the greater the trading volume, the more liquid it is and
the spread between buy/sell transactions is smaller. A lightly traded
security may have more volatile pricing, be less liquid and have
higher transaction costs due to the buy/sell spreads.
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Turnover rate Risk
Turnover rate or ratio reflects the frequency that managers buy or
sell securities within a portfolio. There is no turnover rate that is
correct for all accounts – the rate will vary upon the strategy type,
securities held, or investment conditions. In effect, a high turnover
rate may reflect excessive trading, resulting in potentially higher
costs or transaction expenses, increased capital gains tax liability of
the portfolio, and reduced relative performance. A low turnover
rate, again not conclusive, may reflect low account management
activity or decreased available investment opportunities.
Valuation Risk
It may be difficult to price or fairly value securities that are thinly or
infrequently traded, not readily accessible, illiquid, or of varying
quality. In the absence of accurate security valuation, buy or sell
transactions may be higher or lower than anticipated. Securities
that increase or decrease in price may result in overweight or
underweight conditions relative to the model or benchmark,
increasing diversification risk.
Yield Curve Risk
The yield curve represents the relationship between rate of return
or interest rates and time to maturity. For bond holders, risk occurs
when bond values decrease, impacting portfolio value, when
interest rates go up or when needed fixed income or cash flow
decrease when bond prices go up the yield curve will slope,
up/down and widen or narrow, in relationship between short term
bond yields and long-term bond yields and varying maturities. To
compensate for the liquidity risk of tying up one's money for long
periods of time, a typical investor expects a higher rate of return for
a longer time to maturity.
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