Overview
- Headquarters
- El Dorado Hills, CA
- Total Firm Assets
- $238 million
- Average High-Net-Worth Client Portfolio Size
- $3.0 million
- Stated Minimum Account Size
- $1,000,000
Fee Disclosure
GOLDENSTONE WEALTH MANAGEMENT FIRM BROCHURE
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | $5,000,000 | 0.80% |
| $5,000,001 | $10,000,000 | 0.65% |
| $10,000,001 | $15,000,000 | 0.55% |
| $15,000,001 | $20,000,000 | 0.50% |
| $20,000,001 | and above | 0.40% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $48,500 | 0.97% |
| $10 million | $81,000 | 0.81% |
| $50 million | $253,500 | 0.51% |
| $100 million | $453,500 | 0.45% |
Clients
- High-Net-Worth Share of Firm Assets
- 70.12%
- Number of High-Net-Worth Clients
- 55
- Total Client Accounts
- 236
- Discretionary Accounts
- 230
- Non-Discretionary Accounts
- 6
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 310041
Primary Brochure: GOLDENSTONE WEALTH MANAGEMENT FIRM BROCHURE (2026-09-18)
View Document Text
Item 1:
Cover Page for Part 2A of Form ADV:
Firm Brochure
Version date: September 2026
Goldenstone Wealth Management, LLC
Firm CRD: (310041)
Principal Office Address:
5170 Golden Foothill Parkway
El Dorado Hills, CA 95762
Firm Contact:
Sanjay Varshney, PhD, CFA
Chief Compliance Officer
Firm Website Address:
www.goldenstonewealth.com
please
contact
us
by
telephone
at
(916)
799-6527
This brochure provides information about the qualifications and business practices of
Goldenstone Wealth Management, LLC. If you have any questions about the contents of this
brochure,
or
contact@goldenstonewealth.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any State Securities
Authority. Additional information about Goldenstone Wealth Management is available on the
SEC’s website at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of
Goldenstone Wealth Management, LLC and/or our advisors as “registered” does not imply a
certain level of skill or training. You are encouraged to review this Brochure and Brochure
Supplements for our firm’s associates who advise you for more information on the
qualifications of our firm and our employees.
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Goldenstone Wealth Management | Page 1
Item 2:
Material Changes
Goldenstone Wealth Management, LLC (“Goldenstone Wealth Management”) is required to
advise you of any material changes to our Firm Brochure (“Brochure”) from any previous
version or last update, discuss those changes on the cover page of our Brochure or on the page
immediately following the cover page, or in a separate document accompanying our Brochure.
We must state clearly that we are discussing only material changes since the last annual update
of our Brochure, and we must provide the date of the last annual update of our Brochure.
The material changes in this brochure from the last annual updating amendment of Goldenstone
Wealth Management, LLC in February 2026 are described below.
• No Material Changes to Report
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Table of Contents
Item 1: Cover Page for Part 2A of Form ADV: Firm Brochure .............................................................. 1
Item 2: Material Changes .................................................................................................................. 2
Item 4: Advisory Business .................................................................................................................. 4
Item 5: Fees & Compensation ............................................................................................................ 6
Item 6: Performance-Based Fees & Side-By-Side Management .......................................................... 7
Item 7: Types of Clients & Account Requirements ............................................................................... 7
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ..................................................... 8
Item 9: Disciplinary Information ...................................................................................................... 11
Item 10: Other Financial Industry Activities & Affiliations ................................................................. 11
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ............. 12
Item 12: Brokerage Practices .......................................................................................................... 12
Item 13: Review of Accounts ........................................................................................................... 14
Item 14: Client Referrals & Other Compensation .............................................................................. 14
Item 15: Custody ............................................................................................................................. 16
Item 16: Investment Discretion ....................................................................................................... 17
Item 17: Voting Client Securities ...................................................................................................... 17
Item 18: Financial Information ........................................................................................................ 17
Part 2B of Form ADV Brochure Supplement Item 1: Cover Page ...................................................... 18
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Goldenstone Wealth Management | Page 3
Item 4:
Advisory Business
Goldenstone Wealth Management (the “Firm”, “we”, “us”, “Goldenstone”), is an independent
investment management and advisory firm, founded in July, 2020. It is structured as a Limited
Liability Company and is owned equally (50% each) by the two founders and partners that also
serve as the only two advisers for the Firm:
• Sanjay Varshney, PhD, CFA
• Andres Villegas, CFA
Goldenstone is not owned by any parent company and does not have any subsidiaries,
intermediate or otherwise.
Our Founders strive to help their clients succeed in meeting their financial goals. They have
worked extensively in the Financial industry including on the institutional side of the business.
We help clients through bull and bear markets, through economic booms and busts, and help
them navigate difficult and uncertain financial times with discipline, skill, and confidence.
Our collective wealth management experience spans over 50 years, having managed millions
of dollars for clients in small investment boutiques as well those in one of the nation’s largest
wealth management firms. Our advisors hold the Chartered Financial Analyst (CFA®)
designation.
We always act as your fiduciary. A fiduciary has the greatest legal duty to uphold themselves
to the highest ethical standards and utmost integrity by putting client’s interests above their
own personal interests. We manage your money using loyalty, prudence, and care. Per U.S.
Department of Labor (“DOL”), Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”), all
IRA assets, whether rollover or otherwise, will receive the same fiduciary treatment as all other
assets. In no way, will clients’ interest ever be preceded by any other interest.
Our Services are summarized below:
Investment Management
The portfolios, plans, and strategies we build are individualized and customized to your
objectives, risk tolerance, time horizon, goals for cash flows and income, and other
considerations affecting your wealth and portfolio needs, recognizing that you are unique and
different. We serve individuals, business owners, and institutional clients. We serve as
fiduciaries for our clients and honor their requests and any restrictions the clients may impose
on investing in certain securities or types of securities. We do not participate in wrap fee
programs.
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As of December 2025, Goldenstone Wealth Management has:
Discretionary assets:
Non-discretionary asset:
Total assets:
$177,341,000
$60,918,000
$238,259,000
230
6
236
• Ongoing Portfolio/Asset Management, Monitoring, Trading, and Rebalancing
• Customized Income and Growth Strategies
• Goals-Based Investing
• Tax Mitigation Strategies
• Portfolio Analysis and Strategies
• Economic, Market Updates, and Reviews
•
Interpretation of the Global Economic and Financial Markets
Retirement Planning
Whether you’re retired, thinking about early retirement, or need a second opinion, we can help
you properly plan, adapt, and aim for a successful retirement journey. We help you reach your
retirement goals.
Individual Retirement Accounts (IRAs)
•
• 401(k) Rollovers
• SEP IRAs
• Solo 401(k), Individual 401(k), Owner-Only 401(k)
• SIMPLE IRAs
• Profit Sharing Plans
• Retirement Income Strategies
• Understand your Balance Sheet
• Grow your Net Worth
Financial Planning
We conduct a free comprehensive evaluation of your current and future income sources,
savings, and investments to formulate an investment strategy specific to saving, investing, and
planning. This is part of our holistic discovery and evaluation process to provide the best
portfolio management services.
•
Investment Planning
• Retirement Planning
• Cash Flow Planning
• Education Planning
• Philanthropic Planning
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Item 5:
Fees & Compensation
The fee of the Adviser shall be calculated on the basis of the total market value of the assets
placed under supervision, and is billed quarterly at the end of each calendar quarter (March 31,
June 30, September 30, December 31). It shall be calculated on the basis of the total market value
of such assets as of the close of business on these quarter end dates. Fees are deducted directly
from the client account.
If assets are placed under supervision within two weeks of a quarterly end date, no advance fees
are charged, and the first billing is charged to the subsequent quarter. If the advisory
relationship with Goldenstone begins more than two weeks from a quarter end date, then
Goldenstone will charge fees for that quarter pro-rated for only the days of actual advisory
service from account inception to the quarter end date. At no time will the client ever pay any
fees in advance. Should the client terminate the relationship prior to a quarter end date,
Goldenstone will bill the client on a pro-rated basis only for those days in the quarter of advisory
services up until the date of termination.
There are no fees for financial planning or retirement planning services and we conduct a
complimentary comprehensive evaluation to our clients as part of our holistic investment
management process. We conduct a free comprehensive evaluation of your current and future
income sources, savings, and investments to formulate an investment strategy specific to saving,
investing, and planning. The Fee Schedule below is implemented for any clients onboarded after
March 1, 2025. In no way will any of our existing clients be impacted by this fee schedule so long
as they remain clients of ours. While the new fee schedule is being implemented for any new
clients, once again we may provide discounts on a case-by-case basis.
Clients are advised that lower fees for comparable services may be available from other sources.
Such fee shall be calculated at the following annual blended rates and payable quarterly:
DISCRETIONARY MANAGED ACCOUNT
1.25% of assets under management for assets under
1.00% of assets under management between
0.80% of assets under management between
0.65% of assets under management between
0.55% of assets under management between
0.50% of assets under management between
0.40% of assets under management above
$1 Million
$1-3 Million
$3-5 Million
$5-10 Million
$10-15 Million
$15-20 Million
$20 Million
PRIVATE CAPITAL AND ALTERNATIVE INVESTMENTS
Additional annual management fee ranging from 0.50%-1.50% of the specific assets under management
(Private Credit: up to 0.50%, Other Private Capital: up to 1.00%, Co-Investments: up to 1.50%)
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OPTION STRATEGIES
Additional annual fee of 1.00% of the covered assets/option strategy under management
401K CORPORATE RETIREMENT ASSETS (Business Corporate 401k Plans Only)
0.5% of plan assets under management
RECOMMENDED ACCOUNT MINIMUM
$1,000,000
We do not:
• receive any brokerage commissions or custodial fees
• sell insurance
• participate in underwritings
• participate in wrap fee programs
• receive any fees from tax shelter programs, mutual funds, or any products which might
cause a potential conflict of interest.
• receive any fees from the sale of any securities or investment products
We are a fee-only advisor and will always serve you with the utmost integrity by acting as your
fiduciary at all times. While we will adhere to the schedule of fees described above at all times,
there may be occasional cases where we may be willing to negotiate a lower fee on a need and
case by case basis.
We recommend Charles Schwab for custody of client assets. Clients will incur brokerage and
other transaction costs (such as mutual fund expenses, private capital expenses, options trading
and management expenses, block trade allocation expenses) that are specific to the custodian
where the assets are held or the manager/sub-manager for the investment strategy employed.
Please be advised of the section(s) of our brochure that discusses brokerage for more details. To
the extent possible Goldenstone will minimize the expenses to the client through use of low
expense ratio ETFs, no load funds and other investment strategies that can produce comparable
returns with similar risk.
Item 6:
Performance-Based Fees & Side-By-Side Management
We do NOT charge performance-based fees. We also do not charge any other type of fee such
as an hourly or flat fee, or any asset based or asset specific fee.
Item 7:
Types of Clients & Account Requirements
We expect to have the following types of clients:
•
•
Individuals and High Net Worth Individuals;
Institutional Clients;
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• Trusts, Estates or Charitable Organizations;
• Profit Sharing and Retirement Plans;
• Corporations, Limited Liability Companies and/or Other Business Types
Our requirements for opening accounts or otherwise engaging us:
• We generally require a minimum household balance of $1,000,000.
Item 8:
Methods of Analysis, Investment Strategies & Risk of Loss
As a Wealth Management Firm, we help support your financial goals as you strive to grow and/or
preserve capital. There are several dimensions that are important in the portfolio management
process such as understanding the fundamental and technical factors influencing markets,
historical trends, business and economic cycles, monetary and fiscal policies, risk (political,
economic, company specific, regulatory, market) and their impact on security prices and
consequently your portfolio.
Clients are advised that fundamental and technical trends from the past may not be true for the
future. While reasonable assumptions can be made about past business cycles, and the impact of
monetary and fiscal policy on markets and securities, the past may not be a predictor of the
future.
We assume a long-term horizon for investment decision-making and consider your ability and
willingness to take risk. We employ a series of disciplines – qualitative and quantitative, utilizing
comprehensive fundamental, technical, and economic analyses. We do not pursue any
extraordinary strategies that may involve significant or unusual risks outside of market risks,
such as frequent trading of securities that usually can affect investment performance,
particularly through increased brokerage and other transaction costs and taxes.
We pursue strategies to analyze markets from top-down and bottom-up perspectives. Our
investment programs are designed to meet your objectives within realistic limits of capital
markets using traditional asset classes of stocks, bonds, and real assets that are mostly liquid and
traded in the public securities markets. On occasion, for accredited investors or qualified
purchasers, we may consider based on risk tolerance, time horizon, and return goals some
alternative assets such as private capital and hedge funds. However, these alternative assets are
not for everyone since they come with substantially more risk, and are not that liquid, compared
to marketable securities such as stocks and bonds.
As fiduciaries, we may on occasion determine, based on client suitability and under full
advisement with the client, option strategies limited to collars, covered calls and protective puts
to generate income and/or minimize risk in the client’s portfolio. Such strategies would be
pursued only if appropriate based on our macro analysis of the economy and the markets, client’s
personal situation as well as risk profile, and only if appropriate and beneficial for the client’s
portfolio. Covered call writing is the sale of in-, at-, or out-of- the money call option against a long
security position held in a client portfolio. This type of transaction is used to generate income. It
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also serves to create downside protection in the event the security position declines in value.
Income is received from the proceeds of the option sale. Such income may be reduced to the
extent it is necessary to buy back the option position prior to its expiration. This strategy may
involve a degree of trading velocity, transaction costs and significant losses and/or tax
implications if the underlying security has volatile price movement. Covered call strategies are
generally suited for companies with little price volatility. Protective puts provide protection
against market downturns or in the event of specific decline in the stock or the market price.
Buying puts require a premium against the stock or the market in the form an insurance policy,
which may or may not get utilized. In the event the put is not exercised the premium is lost,
however, the premium serves its purpose as insurance against downside movement in the
underlying security. An Options Collar is an options strategy used primarily to protect an existing
stock position from a significant decline while giving up some upside potential. A typical collar
involves three positions: Own the underlying stock (or ETF). Buy a protective put — gives you the
right to sell the stock at a predetermined strike price, limiting downside below that level. Sell a
covered call — gives someone else the right to buy your stock at a predetermined strike price,
limiting your upside above that level. The premium received from selling the call can partially or
fully offset the cost of buying the put. The benefits include downside protection by establishing a
floor on potential losses; reduced hedging cost: The call premium can help pay for the put; defined
risk/reward: You know approximately where your downside protection and upside cap are; useful
for concentrated holdings: Can help protect an appreciated stock position without immediately
selling it. Key risks / disadvantages of a collar are: Upside is capped: A strong rise in the stock may
result in the shares being called away. Protection isn't free: If the call premium doesn't fully cover
the put premium, you pay a net cost. Limited flexibility: The strategy can restrict your ability to
benefit from large price increases. Assignment risk: The short call can be exercised, particularly
around expiration or when it is deep in-the-money. Expiration/roll risk: You may need to roll the
options to maintain protection, potentially at an unfavorable cost. In short: A collar is essentially a
trade-off: you sacrifice some upside potential in exchange for meaningful downside protection,
often at a relatively low net cost.
As we use fundamental and technical analysis to understand market trends and pricing in the
stock market, we shall utilize either the covered call to generate additional income or the
protective put to avoid losses as appropriate only if previously agreed upon with the client.
We pursue an active global multi-asset total return policy to maximize portfolio returns through
a combination of asset allocation, asset mix, equity style selection, and security selection. These
are carefully and effectively custom tailored to your individual needs and constraints along with
strategic investment tactics.
We start by listening and engaging in meaningful conversations with you. Then, we provide
personalized advice to help you reach and manage your goals.
Our personalized advice includes many dimensions, but primarily revolves around building a
proper investment program designed to meet your cash flow needs, follow your risk appetite,
grow over your time horizon, and be tax and cost efficient.
In addition to managing money, we manage relationships. We recognize the need for our clients
to consult with us any time they wish at their convenience, or to discuss with us life changes that
could change the portfolio strategy. We are passionate and driven to exceed client expectations.
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Our goal is to help you succeed financially through:
• Long-term investing and disciplined strategy
• Minimizing broad market risk from portfolios
• Pursuing active strategies
• Understanding market trends from countries and industries
• Portfolio management
• Keeping perspectives of business cycles
• Removing emotion from decision-making process
•
Interpreting impact of monetary and fiscal policy
Important Risk Considerations:
Investing in securities involves possible risk of principal that clients should be prepared to bear.
It is possible for your investments to increase or decrease in value with fluctuations of the stock
market, therefore you should be prepared to bear the risk associated with investing in the stock
market.
It is important that you understand the risks associated with investing in the stock market, are
appropriately diversified in your investments, and consult with us to answer your questions.
Investment strategies and market investments involve risk arising from a variety of factors such
as: interest rate risk, market risk, inflation risk, currency risk, reinvestment risk, business risk,
liquidity risk, economic risk and general financial risk. These risks can impact security prices,
portfolio valuations, and may result in loss.
Not all investments are suitable for all clients. Certain investments may only be appropriate for
those who have higher risk tolerance, higher net worth disposition, or higher income.
Option strategies are among investments that may not be suitable for all clients. As fiduciaries,
we may on occasion determine, based on client suitability and under full advisement with the
client, option strategies limited to collars, covered calls and protective puts to generate income
and/or minimize risk in the client’s portfolio. While covered calls and protective puts reduce risk
somewhat, they cannot eliminate it entirely. Covered calls usually prevent significant profit
potential if a stock moves substantially in your favor. Anytime you sell a covered call, you have
established a maximum selling price (covered call) for your stock. Any stock movement beyond
that established price creates no additional profit for you and you could give up any gains or
appreciation beyond that. Losses are reduced only by the amount of premium received on the
initial sale of the covered call. While it is possible to hold the options until expiration, you can
usually close out a covered option at any time by buying it to close at the current market price. A
significant change in the price of the underlying stock prior to expiration could result in an early
assignment, and if your short option is in-the-money, you could be assigned at any time,
consequently triggering a sale of your position and/or potentially generating capital gains.
Covered calls written against dividend paying stocks are especially vulnerable to early
assignment. Protective puts carry risk in the event markets or the stock does not go down and
the premium paid on the protected put is lost. Premiums received from the sale of covered calls
or premiums paid from the purchase of protective puts are determined on factors including but
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not limited to: current market volatility, volatility of the underlying security, interest rates in the
market, time of the contract, dividends of the underlying security, macroeconomic and market
factors, or reasons specific to the underlying security.
Investments in private capital such as private equity, private real estate, private debt, or hedge
funds, could have substantial illiquidity risk, concentration risk, and should be used only for
accredited investors as defined by the Securities Exchange Commission (SEC). Additional
considerations and paperwork will be required of clients wanting to invest in any private capital
opportunities. Clients are advised to consult their legal and tax advisors, in addition, to consulting
us prior to making any investment in private capital.
Item 9:
Disciplinary Information
There are no legal or disciplinary events that are material or non-material involving
Goldenstone or any of its founders/advisers that may impact or affect a client’s or prospective
client’s evaluation of our advisory business or the integrity of our management.
Item 10:
Other Financial Industry Activities & Affiliations
Our firm has NO other Financial Industry activity, affiliation with any other firm, ownership in,
or owned by any other firm. We have no conflict of interest arising as a result.
Goldenstone has only two employees/advisers – both are partners and founders, and both hold
the CFA designation.
We are not registered or propose to register as a broker-dealer, a futures commission
merchant, commodity pool operator, a commodity trading advisor, or an associated person of
the foregoing entities. We have no relationship that would cause conflict of interest for our
clients or any arrangement with entities such as broker-dealer, municipal securities dealer, or
government securities dealer or broker, investment company or other pooled investment
vehicle (including a mutual fund, closed-end investment company, unit investment trust,
private investment company or “hedge fund,” and offshore fund), other investment adviser or
financial planner, futures commission merchant, commodity pool operator, or commodity
trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm,
insurance company or agency, pension consultant, real estate broker or dealer, sponsor or
syndicator of limited partnerships.
We do NOT recommend or select other investment advisers for our clients or receive
compensation directly or indirectly from those advisers that creates a material conflict of
interest, or have other business relationships with those advisers that create a material conflict
of interest.
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Item 11:
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
Goldenstone is committed to applying a high Code of Ethics and require that all such transactions be
carried out in a way that does not endanger the interest of any client. At the same time, we
believe that if investment goals are similar for clients and for the advisers, it is reasonable and
even desirable that there may be common ownership of some securities.
We are a fee-only advisory firm. We are independent and have no conflicts of interest or
affiliations with marketing groups. Goldenstone is operated and managed by the Owners and
Founders.
As a fiduciary, it is our responsibility to provide fair and full disclosure of all material facts and to
act solely in the best interest of each of our clients at all times. Our fiduciary duty is considered
the core principle for our Code of Ethics which also includes Insider Trading and Personal
Securities Transactions Policies and Procedures. We require ourselves (both founders/advisers)
to conduct business with the highest level of ethical standards and to comply with all federal and
state securities laws at all times. We both will sign an acknowledgement that we have read,
understand, and agree to comply with our Code of Ethics. This acknowledgement will be shared
at the request of the client.
Our firm and supervised persons must conduct business in an honest, ethical, and fair manner at all
times and avoid all circumstances that might negatively affect or appear to affect our duty of
complete loyalty to all clients. This disclosure is provided to give all clients a summary of our
Code of Ethics.
Related persons of our firm (both founders/advisers) will buy or sell some securities and other
investments that are also recommended to clients. This presents a conflict of interest regarding
the prices paid or received for client transactions vis-à-vis those of the Firm’s advisors or
related persons. Our Code of Ethics outlines the process for quarterly reviews of all Firm
personnel/advisor/related person transactions to ensure that clients are not adversely
impacted by personal trades.
A copy of our Code of Ethics will be provided to any client or prospective client upon request.
Item 12:
Brokerage Practices
We seek to recommend a custodian/broker who will hold your assets and execute transactions
on terms that are overall most advantageous when compared to other available providers and
their services. We consider a wide range of factors, including, among others, these:
• Confidentiality of trading activity and adviser/client relationship
• Timeliness of execution and best price execution
• Frequent and timely trade confirmations
• Liquidity of the securities traded and access across markets
• Ability to place trades in difficult market environments
• Ability to execute and custody private capital
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• Research services and trading tools provided
• Client interface tools and ease of use by clients
• Custody services provided and quality of services
• Financial condition and safety of assets
• Business reputation and reliability of services
Goldenstone had at inception entered into an agreement to use TD Ameritrade Inc. (TD
Ameritrade) as the primary custodian and trading platform for our clients (“custodian”). TD
Ameritrade, Inc. was acquired by Charles Schwab & Co.
Charles Schwab is an independent and unaffiliated SEC-registered broker-dealer. Charles Schwab
offers to independent investment Advisors services which include custody of securities, trade
execution, clearance and settlement of transactions.
Charles Schwab offers zero commission trades. They charge brokerage commissions and
transaction fees for certain securities transactions (i.e., transaction fees are charged for certain
no-load mutual funds, expenses and costs related to options transactions, commissions are
charged for debt securities transactions, there may be charges associated with custody of
private capital assets). They provide access to many no-load mutual funds without transaction
charges and other no-load funds at nominal transaction charges. However, the commission and
transaction fees charged by our custodian may be higher or lower than those charged by other
custodians and broker-dealers.
Charles Schwab provides comprehensive custodian services to include at no charge to us or the
client:
• Company/Industry research products/reports
• Economic reports, data and analyses
• Financial publications and news
• Pricing data and portfolio evaluation services
Goldenstone does not receive any part of, or use client brokerage commissions to obtain
research or other products or services. Research and brokerage services at Charles Schwab are
used by our firm to manage those accounts of our clients custodied there. Since we do not have
to pay to produce or pay for such research, this has the potential to pose a conflict of interest
while recommending Charles Schwab as the custodian, including not receiving the best
execution had we selected another firm for custody that could provide better execution on a
specific trade or transaction. We look to Charles Schwab to provide us the most favorable
execution, and the most efficient custody of clients’ assets. Goldenstone also utilizes research
from other sources and does not depend solely on such products/services from Charles
Schwab.
Neither Goldenstone Wealth Management nor its Founders/Advisors receive research (other
than research available to clients for using Charles Schwab platform) or other products or
services other than execution from a broker-dealer or a third party (“soft dollar benefits”) in
connection with client securities transactions.
Goldenstone investigated any potential conflict of interest and concluded that using them as our
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primary custodian serves the best interests of our clients and satisfies our fiduciary obligations,
including our duty to seek best execution.
Goldenstone does not receive brokerage commissions or client referrals from the
recommendation of Charles Schwab as custodian. We do not have discretionary authority in
making the determination of the brokers with whom orders for the purchase or sale of
securities are placed for execution, and the commission rates at which such securities
transactions are effected. Goldenstone does not require client- directed brokerage to any
specific broker-dealer, but recommends Charles Schwab as discussed earlier. Client-Directed
Brokerage Arrangement refers to an arrangement whereby a Client directs that trades for its
account be executed through a specific Broker in exchange for which the Client receives a
benefit in addition to execution services. If a client insists on or requires using a specific
custodian of their choice, or direct brokerage, the client is advised that we may be unable to
achieve most favorable execution of client transactions. Directing brokerage may cost clients
more money.
Goldenstone proposes to use aggregation only if it does not result in any additional costs to
clients, and serves to be both expedient and efficient from a best execution standpoint.
Item 13:
Review of Accounts
We review accounts on at least a quarterly basis for all of our clients. We continuously monitor
all client portfolios and assets, and review them to ensure that our clients’ accounts are aligned
with their investment objectives, risk tolerance, investment horizon, and investment policies
as applicable. We will rebalance portfolios as needed to reflect current market conditions, and
ensure that the portfolios and assets are managed with prudence and care, since we are
fiduciaries. All reviews will be conducted only by the firm’s founders/advisers.
We will meet with our clients upon their request, on at least an annual basis, or per agreed
schedule, to discuss updates to their plans, changes in their circumstances or other questions or
concerns they may have.
We may review client accounts and/or meet with clients more frequently, if such reviews or
meetings are triggered due to major or unusual changes in markets, the economy, the client’s
personal circumstances or life events, or requests by the client, etc.
We provide written reports to clients on at least an annual basis, and quarterly for those clients
who want those. Clients will also receive reports from their custodian, monthly, or quarterly
at the least, and have full access to their accounts and records online.
All reviews will be conducted by: Sanjay Varshney, Principal/Adviser, and/or Andres Villegas,
Principal/Adviser.
Item 14:
Client Referrals & Other Compensation
As part of our fiduciary duties to our clients, we endeavor at all times to put the interests of our
clients first. We do not receive any economic benefit or fee from anybody other than the client
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 14
for providing advice and managing portfolios for the client. From time to time we may receive
referrals from clients for new business. We do NOT compensate clients for such referrals.
Goldenstone Wealth Management pays cash compensation to certain promoters for referring
prospective clients to the firm. Promoters receiving referral compensation are required to
comply with applicable federal and state regulatory requirements. If you were referred to
Goldenstone by a promoter, you should have received this brochure and a separate written
disclosure describing the referral arrangement at the time of the referral.
If you engage Goldenstone for advisory services, the promoter will receive a portion of the
advisory fees you pay. This compensation will continue for as long as you remain a client or
until the referral agreement with the promoter is terminated. You do not pay additional fees or
incur higher advisory costs as a result of this arrangement.
Because promoters are compensated for referrals, they have a financial incentive to
recommend Goldenstone, which creates a conflict of interest. You are under no obligation to
engage Goldenstone. Similar advisory services may be available from other investment
advisors at different fee levels. Promoters who maintain referral relationships with multiple
advisory firms may have an additional incentive to recommend firms that provide higher
compensation. Goldenstone requires promoters to disclose such relationships and conflicts of
interest to prospective clients.
Zoe Financial Referral Arrangement
Goldenstone Wealth Management receives client referrals through its participation in the Zoe
Advisor Network (“ZAN”), operated by Zoe Financial, Inc. Zoe Financial is an independent,
unaffiliated entity, and there is no employment, ownership, or common control relationship
between Zoe Financial and Goldenstone.
Zoe Financial established ZAN to refer individuals seeking fee-only investment management or
financial planning services to independent investment advisors. Zoe Financial does not
supervise, direct, or control Goldenstone’s advisory services, investment recommendations, or
client account management.
Goldenstone pays Zoe Financial an ongoing referral fee for clients referred through ZAN. This
fee is generally calculated as a percentage of the advisory fees paid by the client to Goldenstone
and is commonly referred to as a promoter fee. Clients referred through ZAN do not pay
advisory fees higher than Goldenstone’s standard fee schedule offered to similarly situated
clients.
Additional information regarding compensation paid, directly or indirectly, to Zoe Financial is
provided in the Zoe Financial Disclosure and Acknowledgement Form.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 15
Item 15:
Custody
As a matter of policy and practice, Goldenstone Wealth Management does not permit
employees or the firm to accept or maintain custody of client assets. It is our policy that we will
not accept, hold, directly or indirectly, client funds or securities, or have any authority to obtain
possession of them, with the sole exception of direct debiting of advisory fees. Goldenstone
Wealth Management will not intentionally take custody of client cash or securities. However,
Goldenstone Wealth Management may be deemed to have custody of assets due to Standing
Letters of Authorization and consequently having third-party money movement authority over
client accounts.
All of our clients receive monthly and at least quarterly account statements directly from their
custodians.
The Client’s assets are held in custody with a third-party firm in their name. Goldenstone does
not take ownership of any of your assets or accounts, and we simply serve as discretionary
advisors and fiduciaries. We ask our clients to choose a third-party discount brokerage house
for the purpose of holding the assets and providing detailed record- keeping. Clients are
advised to review the statements received from the custodian upon receipt, and also compare
them to the statements they receive from us.
Goldenstone will be directly deducting advisory fees from the account held at the respective
custodian. Any fees deducted will appear on statements received from Charles Schwab.
Per the SEC’s Division of Investment Management granted no-action relief to advisers with
custody due to authority granted under third-party SLOAs, (Rule 206(4)-2 (“Custody Rule”)
under the Investment Advisers Act of 1940 (“Advisers Act”), Goldenstone provides the
following protections regarding the qualified custodian when deemed to have custody due to
third party SLOAs by ensuring the following steps are completed:
• Client Authorization: The client must provide written authorization to the qualified
custodian to allow the adviser to transfer funds to a third party.
• Designated Third Party: The client must designate the third party in the written
authorization.
• Custodian Oversight: The qualified custodian must receive a copy of the written
authorization from the client.
• Transfers to Designated Accounts Only: Goldenstone can only send funds to the
designated third party at a specified account.
• Client Can Modify or Revoke: The client must be able to change or revoke the Standing
Letter Of Authorization (SLOA).
• Custodian Confirmation: The custodian sends confirmations of transfers to the client as
requested.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 16
• No Adviser Modification Authority: Goldenstone cannot modify any details of the
designated third party (name, address, account number, etc.).
• Third Party is not related to any advisor at Goldenstone, or located at the same
address as Goldenstone.
Item 16:
Investment Discretion
To work with Goldenstone, client will engage in a discretionary plan where all investment
decisions are made by Goldenstone as your fiduciary. These decisions follow a previously
agreed upon plan, which is your unique investment policy statement. Clients may choose to give
us full discretionary authority, or place restrictions on us on the types of securities, companies,
or investments we may pursue. All such restrictions will be clearly documented in the
investment policy statement, as well as the client agreement. These restrictions will be reviewed
during client meetings, at least annually. Goldenstone has discretionary authority to determine
the securities to be bought or sold for a client's account and the securities to be bought or sold
for a client's account.
Item 17:
Voting Client Securities
We do not accept the proxy authority to vote client securities. Clients will receive proxies or
other solicitations directly from their custodian or a transfer agent. Clients may call, write or
email us to discuss questions they may have about particular proxy votes or other solicitations.
Clients maintain responsibility for: (1) directing the manner in which proxies solicited by
issuers of securities beneficially owned by the client shall be voted, and (2) making all elections
relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type
events pertaining to the client’s investment assets. Therefore, our firm and/or you shall instruct
your qualified custodian to forward to you copies of all proxies and shareholder
communications relating to your investment assets.
Item 18:
Financial Information
It is our policy that we will not accept, hold, directly or indirectly, client funds or securities, or
have any authority to obtain possession of them, with the sole exception of direct debiting of
advisory fees. Goldenstone Wealth Management will not intentionally take custody of client
cash or securities. However, Goldenstone Wealth Management may be deemed to have custody
of assets due to Standing Letters of Authorization and consequently having third-party money
movement authority over client accounts.
We do NOT require or solicit prepayment of more than $1,200 in fees per client (per state
securities authorities registration requirements), six months or more in advance under any
circumstances. We do NOT have any financial condition that is reasonably likely to impair our
ability to meet contractual commitments to clients.
We have NOT been the subject of a bankruptcy petition at any time during the past ten years.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 17
Part 2B of Form ADV
Brochure Supplement
Item 1: Cover Page
Sanjay Varshney, PhD, CFA
Advisor CRD # 4721550
Business Address:
5170 Golden Foothill Parkway,
El Dorado Hills CA 95762
(916) 799-6527
Goldenstone Wealth Management
Firm CRD: 310041
5170 Golden Foothill Parkway El
Dorado Hills CA 95762
Firm Website Address:
www.goldenstonewealth.com
This brochure supplement provides information about Sanjay Varshney, PhD, CFA that
supplements Goldenstone Wealth Management firm brochure. You should have received a
copy of that brochure. Please contact Sanjay Varshney, PhD, CFA (Chief Compliance Officer) by
telephone at (916) 799-6527 or contact@goldenstonewealth.com if you did not receive the
Goldenstone Wealth Management’s Brochure or if you have any questions about the contents
of this supplement.
Additional information about the firm and its representatives is available on the SEC’s
website at www.adviserinfo.sec.gov.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 18
Item 2
Education Background and Business Experience
Sanjay Varshney, PhD, CFA – Founder and Principal
Year of Birth: 1967
Dr. Sanjay Varshney, CFA has over experience in the investments industry for over three
decades. Prior to founding Goldenstone, he was a senior wealth management executive for six
years at Wells Fargo Private Bank, serving as a Senior Vice President and a Senior Investment
Strategist for California and Nevada, providing leadership and investment strategy for over
$200 billion in assets. Dr. Varshney is also a Professor of Finance at Sacramento State,
contributes to the local economic forecasts in the Greater Sacramento region, and has conducted
numerous business and economic impact studies. Dr. Varshney earned an undergraduate
degree in Accounting and Financial Management from Bombay University, a Master’s degree in
Economics from the University of Cincinnati, and a PhD in Finance from Louisiana State
University in Baton Rouge. He also holds the Chartered Financial Analyst (CFA®) designation.
Employment History for Sanjay Varshney, PhD, CFA
From
To
Address
Position Held
Investment
related
07/2020
Present
Yes
Principal
Name of
Firm of
Company
Goldenstone Wealth
Management
El Dorado Hills,
CA
Sacramento, CA
01/2015
Present
No
Professor
California State
University
03/2015
06/2020 Wells Fargo Private
Roseville, CA
Yes
Bank
Senior Vice
President
10/2014
03/2015
Yes
El Dorado Hills,
CA
Senior Vice
President
Wells Fargo
Advisors, LLC
Sacramento, CA
07/2004
12/2014
No
Dean
California State
University
Chartered Financial Analyst (CFA):
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment
credential established in 1962 and awarded by CFA Institute — the largest global association of
investment professionals.
There are currently more than 200,000 CFA charterholders around the world. To earn the CFA
charter, candidates must:
1. Complete a bachelor's program or equivalent program and have received a degree
from the college/university
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 19
2. Pass three sequential, six-hour examinations covering investment analysis,
management, and ethics
3. Have at least four years of qualified professional investment experience
4. Obtain 2-3 professional letters of recommendation
5. Join the CFA Institute as members of the organization
6. Commit to abide by, and annually reaffirm, adherence to the CFA Institute Code of
Ethics and Standards of Professional Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an
active professional conduct program, require CFA charterholders to:
1. Place their clients’ interests ahead of their own
2. Maintain independence and objectivity
3. Act with integrity
4. Maintain and improve their professional competence
5. Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams requires extensive study - on average a candidate spends over 900
hours of self-study.
Additionally, regulatory bodies in 28 countries recognize the CFA charter as a proxy for meeting
certain licensing requirements.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for
investment decision making and is firmly grounded in the knowledge and skills used every day
in the investment profession. The three levels of the CFA Program test a proficiency with a wide
range of fundamental and advanced investment topics, including ethical and professional
standards, fixed-income and equity analysis, alternative and derivative investments, economics,
financial reporting standards, portfolio management, and wealth planning.
For more information, please go to: https://www.cfainstitute.org/en/programs/cfa/charter
Item 3
Disciplinary Information
There are no legal or disciplinary events material to a client’s or prospective client’s evaluation
of Dr. Sanjay Varshney, CFA.
Item 4
Other Business Activities
Dr. Sanjay Varshney, CFA is engaged in outside business activity as a Professor of Finance at
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 20
Sacramento State University, Sacramento, CA. He teaches courses in Managerial/Corporate
Finance. His activities as Professor are not investment related. He has served as Professor since
01/2015 and spend approximately 36 hours per month teaching.
Item 5
Additional Compensation
Dr. Sanjay Varshney, CFA does NOT receive any performance-based compensation or any
economic benefits to include sales awards and other prizes, or any bonus that is based, at least
in part, on the number or amount of sales, client referrals, or new accounts.
Item 6
Supervision
Dr. Sanjay Varshney, CFA as Principal and Advisor is supervised by Andres Villegas, CFA Principal and
Advisor (Telephone: 915-726-8262) at Goldenstone Wealth Management. This supervision extends
to reviewing business practices, trading and ensuring the firm is adhering to applicable laws,
regulations and firm policies. He can be reached at (915)-726-8262.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 21
Part 2B of Form ADV
Brochure Supplement
Item 1: Cover Page
Andres Villegas, CFA
Advisor CRD # 7274223
Business Address:
5170 Golden Foothill Parkway,
El Dorado Hills CA 95762
(915) 726-8262
Goldenstone Wealth Management
Firm CRD: 310041
5170 Golden Foothill Parkway
El Dorado Hills CA 95762
Firm Website Address:
www.goldenstonewealth.com
This brochure supplement provides information about Andres Villegas, CFA that supplements
Goldenstone Wealth Management firm brochure. You should have received a copy of that
brochure. Please contact Sanjay Varshney, PhD, CFA (Chief Compliance Officer) by telephone
at (916) 799-6527 or contact@goldenstonewealth.com if you did not receive the Goldenstone
Wealth Management’s Brochure or if you have any questions about the contents of this
supplement.
Additional information about the firm and its representatives is available on the SEC’s website
at www.adviserinfo.sec.gov.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 22
Item 2
Education Background and Business Experience
Andres Villegas, CFA – Founder and Principal
Year of Birth: 1990
Andres Villegas is a portfolio investment manager having served the wealth and investment
management needs of families, businesses, and nonprofit organizations in Texas, New Mexico,
and California. Prior to founding Goldenstone, Andres was a Vice President and Investment
Strategist at Wells Fargo Private Bank for nearly 10 years, managing over $400 million in assets.
His previous background includes portfolio and investment management for clients from Latin
America. Andres earned an undergraduate degree in Finance from the McCombs School of
Business at The University of Texas at Austin. He also attended a business program at The
University of Chicago Booth School of Business. He holds the Chartered Financial Analyst (CFA®)
designation. Andres contributes regularly to the local economic forecasts in the Greater
Sacramento region.
Employment History for Andres Villegas, CFA
From
To
Address
Name of
Firm of Company
Investment
related
Position
Held
07/2020
Present
Yes
Principal
04/2012
06/2020
Yes
El Dorado Hills,
CA
Roseville, CA
01/2010
04/2012
Austin, TX
No
Goldenstone Wealth
Management
Wells Fargo
Private Bank
The University of
Texas at Austin
Investment
Strategist
Student/
Assistant
Chartered Financial Analyst (CFA):
The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment
credential established in 1962 and awarded by CFA Institute — the largest global association of
investment professionals.
There are currently more than 200,000 CFA charterholders around the world. To earn the CFA
charter, candidates must:
1. Complete a bachelor's program or equivalent program and have received a degree
from the college/university
2. Pass three sequential, six-hour examinations covering investment analysis,
management, and ethics
3. Have at least four years of qualified professional investment experience
4. Obtain 2-3 professional letters of recommendation
5. Join the CFA Institute as members of the organization
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 23
6. Commit to abide by, and annually reaffirm, adherence to the CFA Institute Code of
Ethics and Standards of Professional Conduct.
High Ethical Standards
The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an
active professional conduct program, require CFA charterholders to:
1. Place their clients’ interests ahead of their own
2. Maintain independence and objectivity
3. Act with integrity
4. Maintain and improve their professional competence
5. Disclose conflicts of interest and legal matters
Global Recognition
Passing the three CFA exams requires extensive study - on average a candidate spends over 900
hours of self-study.
Additionally, regulatory bodies in 28 countries recognize the CFA charter as a proxy for meeting
certain licensing requirements.
Comprehensive and Current Knowledge
The CFA Program curriculum provides a comprehensive framework of knowledge for
investment decision making and is firmly grounded in the knowledge and skills used every day
in the investment profession. The three levels of the CFA Program test a proficiency with a wide
range of fundamental and advanced investment topics, including ethical and professional
standards, fixed-income and equity analysis, alternative and derivative investments, economics,
financial reporting standards, portfolio management, and wealth planning.
For more information, please go to: https://www.cfainstitute.org/en/programs/cfa/charter
Item 3
Disciplinary Information
There are no legal or disciplinary events material to a client’s or prospective client’s evaluation
of Andres Villegas, CFA.
Item 4
Other Business Activities
Andres Villegas, CFA is NOT engaged in other outside business activity.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 24
Item 5
Additional Compensation
Andres Villegas, CFA does NOT receive any performance-based compensation or any economic
benefits to include sales awards and other prizes, or any bonus that is based, at least in part, on
the number or amount of sales, client referrals, or new accounts.
Item 6
Supervision
Andres Villegas, CFA as Principal and Advisor is supervised by Dr. Sanjay Varshney, CFA, Principal
and Advisor (Telephone: 916) 799-6527) at Goldenstone Wealth Management. This supervision
extends to reviewing business practices, trading and ensuring the firm is adhering to applicable laws,
regulations and firm policies. He can be reached at (916) 799-6527.
ADV Part 2A & Part 2B – Firm Brochure & Brochure Supplement
Goldenstone Wealth Management | Page 25