View Document Text
GuideStone Advisors, LLC
5005 LBJ Freeway, Ste. 2200
Dallas, TX 75244-6152
(214) 720-6486
March 30, 2026
This Brochure provides information about the qualifications and business practices of GuideStone
Advisors, LLC (“GSA”). If you have any questions about the contents of this Brochure, please contact us
at (214) 720-6486. 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.
GSA is a registered investment adviser. Registration of an investment adviser does not imply any certain
level of skill or training.
Additional information about GSA is also available on the SEC’s website at
www.adviserinfo.sec.gov.
Item 2 – Material Changes
This Brochure contains the following material changes from the brochure dated March 28,
2025. All changes to the Brochure, including the material changes listed below, are intended
to update, clarify and enhance information in the prior Brochure.
• The GuideStone Capital Preservation Fund was replaced by the Guide Stable Value Fund in
all references including Item 4, page 1; Item 5, page 7; Item 8, page 12; Item 11, pages 16 and
17.
• GuideStone Personal Advisory Services became permitted only on ERISA accounts as of
January 1, 2026, Item 4, page 4.
• Added artificial intelligence disclosures in Item 4, page 7 and Item 8, pages 13 and 14.
ii
Item 3 – Table of Contents
Item 2 – Material Changes .............................................................................................................................. ii
Item 3 – Table of Contents .............................................................................................................................iii
Item 4
Advisory Business ............................................................................................................................ 1
Item 5
Fees and Compensation..................................................................................................................... 7
–
Item 6
Performance-Based Fees and Side-by-Side Management ............................................................... 11
–
C
............................................................................................................................. 11
–
Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 11
lients
Item 8
Item 7 – Types of
Item 9
Disciplinary Information ................................................................................................................. 14
Other Financial Industry Activities and Affiliations ..................................................................... 14
–
Item 10
–
Item 11
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 15
–
Item 12
Brokerage Practices ....................................................................................................................... 17
–
Item 13
Review of Accounts ...................................................................................................................... 20
–
Item 14
Client Referrals and Other Compensation ..................................................................................... 21
–
Item 15
Custody ......................................................................................................................................... 21
–
Item 16
Investment Discretion ................................................................................................................... 22
–
Item 17
Voting Client Securities ................................................................................................................ 22
–
Item 18
Financial Information .................................................................................................................... 22
–
–
iii
Item 4 – Advisory Business
GSA is a Texas limited liability company formed in February 2019. GuideStone Advisors, a Texas non-
profit corporation, is GSA’s manager and member that was established in June 2008 by GSFR, which is
also a Texas non-profit corporation and the sole member of GuideStone Advisors. GSA is the successor
to GuideStone Advisors. Prior to February 12, 2019, GuideStone Advisors provided investment advisory
services to clients, as described below. GSA’s other member is GuideStone Resource Management, Inc.,
a Texas corporation (“GSRM”), which is a wholly owned subsidiary of GSFR.
GSA provides advisory services to individuals, trusts, estates, charitable organizations and other
business entities. As of December 31, 2025, GSA managed $1.96 billion in client assets on a
discretionary basis.
GSA is affiliated with GSFR and its subsidiaries, GuideStone Financial Services (“GFS”) (a
registered broker-dealer), GuideStone Investment Services (“GSIS”) and GuideStone Capital
Management, LLC (“GSCM”) (a registered investment adviser to GuideStone Funds, a registered
open-end management investment company). All GSA’s investment adviser representatives
(“advisors”) (and other personnel) are employees of GSFR, and GSFR bears a material amount of
the operating and other expenses of GSA. Accordingly, GSA depends upon the revenues earned by
GSFR for its operations, including the compensation paid to its advisors (who are charged with
providing objective advice to clients) and other personnel. GSFR’s revenues consist of, among
other things, shareholder servicing fees received from GuideStone Funds, fees (administrative,
certain marketing and other services) received from the GuideStone Stable Value Fund
established by SEI Trust Company (the “GuideStone Stable Value Fund”), revenues received
from the management fees paid by GuideStone Funds to GSCM and revenues received from the
advisory fees paid to GSA. Additionally, all advisors are also registered representatives with GFS,
allowing them to provide brokerage services to individuals along with the advisory services
described in this Brochure.
When GSA is advising individuals on their assets in their employer-sponsored plan accounts with GSFR
or on their GuideStone Funds IRA or GuideStone Funds investments account (collectively “GuideStone
accounts”), model portfolios will be utilized that primarily consist of the available GuideStone Funds
and the GuideStone Stable Value Fund (collectively “Affiliated Funds”) and may include other non-
GuideStone mutual funds, if available and as chosen by the employer within an employer-sponsored-
plan (“unaffiliated funds”). GSA’s advice may be the same or materially the same for different clients
with materially similar investment objectives and circumstances. GSA, its affiliates and its
representatives have a financial interest in recommending Affiliated Funds. However, clients are under
no obligation to purchase Affiliated Funds and there may be other similar funds available with the same
or better performance, with lower expenses, from which GSA, its affiliates and its representatives receive
no compensation whatsoever. GSA has developed policies and procedures to address these conflicts.
If your GSFR account offers unaffiliated funds, GSA may ask whether you prefer: (i) a faith-based
recommendation that includes only the Affiliated Funds; or (ii) a recommendation that may include
unaffiliated funds, in addition to or instead of the Affiliated Funds. We will use your preferences,
together with other relevant information, to develop your financial plan and related projections, which
may influence the advice we provide based on your specific circumstances and choices.
GSA adheres to the faith-based investing policy of GSFR and therefore does not recommend
investments in any company or fund that invests in companies publicly recognized (as determined by
GSFR) for offering products or services that are incompatible with the Christian values of GSFR,
1
including but not limited to those involving abortion, sexual immorality, alcohol, tobacco, or gambling.
At a client’s request, GSA may implement investment selections or strategies that do not adhere to this
policy.
GSA, its personnel and affiliates will not be liable for any loss arising out of GSA’s advice or for any
other act or omission taken with respect to its services, except for any act or omission which constitutes
willful misfeasance, bad faith or gross negligence in the performance of its duties described in this
Brochure. Notwithstanding the foregoing, you should be aware that federal and state securities laws may
impose liabilities on GSA under certain circumstances. Therefore, nothing herein shall have the effect of
waiving, releasing or limiting any rights you may have under those laws or under any other laws that are
not permitted to be waived.
Investment Management Services
GSA provides investment management services according to your objectives, risk tolerance and
investment preferences to provide you a tailored Investment Strategy. You are able to impose reasonable
restrictions on us in the development of your Investment Strategy (described in more detail in the
Restrictions section below). Additionally, you may meet your investing goals by investing in other funds
or investments for which GSA does not provide advice, including some which may charge lower fees.
Our investment management services can be offered by themselves through an investment advisory
agreement or packaged together with other services, such as part of GuideStone Wealth Management®,
GuideStone Managed Accounts® or GuideStone Personal Advisory Services®. GSA does not provide tax
or legal advice.
Your Investment Strategy may include a recommendation of an allocation of your eligible assets to a
Separately Managed Account (“SMA”) consisting of equity and/or fixed income securities that will be
managed on a discretionary basis by an unaffiliated third-party investment manager (“TPIM”), for an
additional fee paid to the TPIM from your SMA and will be held in brokerage accounts with an
unaffiliated GSA designated broker-dealer for facilitation of the SMA. TPIMs are SEC-registered
investment advisors selected by the advisor due to their expertise with various types of investment
strategies such as specific market expertise, strategic approach, efficient income management and
reputation. A recommendation to allocate your assets to an SMA for management by a TPIM will
consider various factors to determine if the investment is appropriate based on your financial needs,
goals, risk tolerance, investment horizons and objectives and the investment strategy and expertise and
performance of the TPIM investment. GSA will monitor the performance of the SMA and TPIM and
will have discretion to replace any TPIM based on our evaluation of the services provided and
performance achieved by the TPIM in accordance with your agreed upon Investment Strategy. The fees
you pay to GSA for our Investment Management and Planning Services will not be increased or reduced
by the fees you pay to the TPIM.
Once selected, a TPIM has discretion with respect to the portion of the assets placed with them, allowing
the TPIM to choose and prudently manage investments for you. In exercising their discretion, the TPIM
may develop an appropriate investment strategy, buying and selling securities in accordance with that
strategy, subject to restrictions imposed by GSA and/or you. Participation in a SMA strategy will be
subject to an investment minimum established by the TPIM or GSA establishment of a brokerage
account in your name with the designated broker-dealer. Assets in an employer benefit plan are not
eligible for placement in an SMA. No recommendation for an SMA will be given or should be expected
based solely on eligibility therefore your Investment Strategy may not include an SMA.
Upon enrollment in our investment management services, GSA will process any necessary investment
transactions to implement your Investment Strategy as efficiently as possible. Your Investment Strategy
will identify and describe how your enrolled accounts (your “Portfolio”) will be managed on a
2
discretionary basis. By enrolling, you give GSA the discretionary authority to process investment
transactions as described in your Investment Strategy. This would include executing transactions
necessary to maintain the target allocations specified in the Investment Strategy and might include
changing the specific investments used to implement the Investment Strategy (without prior notice to
you) to the extent any such changes are consistent with the Investment Strategy.
Financial Planning Services
GSA offers non-discretionary financial planning services, which may include an analysis of your
specific financial circumstances (e.g., assets, liabilities, risk tolerance, investment preferences, time
horizon, investment objectives and goals, tax considerations, insurance policies, spouse and family
information and current and future income and expenses) and make projections and recommendations
focused on improving your ability to achieve your investment objectives and goals. The projections are
based on multiple considerations including, but not limited to, historical and forward-looking projections
on the capital markets, inflation, economic factors and other matters. These projections, by their nature,
are inherently difficult to predict and might turn out to be wrong, and as a result there is no guarantee
you will meet your financial goals, even if you implement our advice. Additionally, our financial
planning services could include charitable gift planning, estate planning, tax planning, insurance
planning and other planning services. These financial planning services may be offered individually by
themselves through a financial planning agreement or packaged together with other services, such as
part of GuideStone Wealth Management®, GuideStone Managed Accounts® or GuideStone Personal
Advisory Services®. The specific services provided will be described in your respective advisory or
financial planning agreement. GSA does not provide tax or legal advice.
GuideStone Wealth Management®
GuideStone Wealth Management (“GWM”) packages our investment management services and full
array of financial planning services provided by a dedicated wealth advisor. GWM includes
discretionary investment management according to your personalized Investment Strategy,
comprehensive financial planning, tax planning, estate planning, insurance planning, charitable gift
planning and other planning services. These services represent your “Wealth Plan” and focus on helping you
achieve your investment objectives, financial goals and planning needs.
Your wealth advisor will create, implement and maintain your personalized Wealth Plan according to
your objectives, circumstances and preferences. Your wealth advisor will be available as needed and
will request you meet on at least an annual basis to review any changes to your circumstances that would
affect your Wealth Plan.
GWM provides you the option to include a Separately Managed Account (“SMA”), as described in the
Investment Management Services section above. An SMA consists of equity and/or fixed income
securities managed on a discretionary basis by a third-party investment manager (“TPIM”) for an
additional fee paid from your SMA assets. SMA assets will be held in brokerage accounts with an
unaffiliated broker-dealer designated by GSA to facilitate the SMA.
GWM services allows you the option of separately maintaining a Self-Directed Account (SDA)
consisting of investments chosen, monitored and managed by you at a GSA designated broker-dealer or
Donor Advised Fund provider and receive servicing and reporting from your wealth advisor. GWM is
not available for ERISA plan accounts.
GuideStone Managed Accounts®
GuideStone Managed Accounts (“GMA”) packages investment management services with a limited set
of financial planning services provided by a team of advisors. GMA includes discretionary investment
3
management according to your Investment Strategy and basic financial planning. These services
represent your “Managed Plan” and focus on helping you achieve your investment objectives and
financial goals.
Our advisors will create, implement, and maintain your personalized Managed Plan based on your
objectives, circumstances, and preferences. Our advisory team will be available as needed and will ask
to meet with you at least annually to review changes in your circumstances that may affect your
Managed Plan.
If you purchase GMA advisory services through an ERISA-covered plan, our investment advisory
services are limited to those investment advice, investment planning, and retirement planning services
permitted under ERISA, are provided solely to the ERISA plan account, and are limited to services paid
for by the ERISA plan and will not be provided in combination with services for any other retirement or
investment account.
GuideStone Personal Advisory Services® (ERISA client accounts only)
GuideStone Personal Advisory Services (“GPAS”) became limited to ERISA plan accounts only on
January 1, 2026. GPAS packages discretionary investment management and retirement planning
services on ERISA plan retirement accounts provided by a dedicated advisor. GPAS includes
discretionary investment management according to your Investment Strategy and financial goal
planning. These services represent your “Financial Plan” and are designed to help you pursue your
investment objectives and financial goals.
Your advisor will create, implement, and maintain your Financial Plan based on your objectives,
circumstances, and preferences. Your advisor will be available as needed and will request to meet with
you at least annually to review changes that may affect your Financial Plan.
Our investment advisory services are limited to those investment advice, investment planning, and
retirement planning services permitted under ERISA, are provided solely to the ERISA plan account,
and are limited to services paid for by the ERISA plan and will not be provided in combination with
services for any other retirement or investment account.
GPS: Guided Planning Services®
GSA provides GPS: Guided Planning Services (“GPS”) to clients on a nondiscretionary basis, for an
individual instance, at the specific point in time of the service. GPS usually involves consultation with
an advisor focused on retirement planning. Topics addressed include creating an investment allocation,
determining appropriate savings levels, estimating future retirement income, and assisting individuals in
effectively planning to achieve their preferred retirement objectives. The guidance offered is intended to
address your retirement planning objectives and does not constitute a comprehensive financial plan.
As GPS is provided at your request for a specific point in time, it does not include ongoing management
or review of your accounts or circumstances by GSA. GPS is generally intended for annual use;
however, exceptions may be made upon your request and at GSA’s discretion. You are solely
responsible for initiating each GPS request, and GSA reserves the right to approve or decline service
based on its resources and availability. The acceptance or rejection of any advice remains entirely at
your discretion. GSA will supply an updated version of this Brochure with each instance of GPS advice,
but will not issue annual updates due to the one-time nature of these services.
GSA will recommend an investment allocation for your GuideStone accounts that aligns with your
stated preferences, considering the available options within your account(s). Should you choose to
follow GSA’s recommended allocation, you remain responsible for implementing all necessary
4
transactions to achieve and maintain your target allocation, subject to any restrictions imposed by your
investment platform or the selected investments. GSA does not monitor your account for changes in
personal circumstances, market conditions, or investment products after recommendations are made, nor
does it notify you of such changes. It is your responsibility to determine if circumstances have changed
and whether additional GPS consultations or alternative resources are warranted.`
Additionally, GSA will conduct a comprehensive analysis to estimate your progress toward achieving
your retirement or financial objectives, providing recommendations tailored to factors such as your (1)
retirement age, (2) savings, (3) expenses, (4) investment purpose, and (5) investment preferences.
Projections are based on a variety of considerations, including historical data, forward-looking capital
market assumptions, inflation, and other economic factors. Given the inherent uncertainty of such
projections, there can be no guarantee that your financial goals will be met, even if all advice is
implemented.
Computer model
The investment advice provided by GPS is generated by a computer model designed and operated to:
apply generally accepted investment theories which consider historic risks and returns of different asset
classes over defined periods of time, as well as additional relevant considerations; take into account
investment management and other fees and expenses associated with the available investments;
appropriately weight the factors used in estimating future returns of investment options; utilize, to the
extent provided, information relating to age, time horizons (such as life expectancy and retirement age),
risk tolerance, current investments in other designated investment options, other assets or sources of
income, investment preferences, and any additional information that a plan, participant, or beneficiary
may provide; utilize appropriate objective criteria to offer asset allocation portfolios comprised of
available investment options; avoid investment recommendations that inappropriately favor investment
options offered by GSA’s affiliates over other investment options, if any, available under the plan, or
inappropriately favor investment options that generate greater income for GSA or it’s affiliates; and,
except as provided below, take into account all designated investment options available under the plan
without giving inappropriate weight to any investment option.
GSA has obtained a written certification from an “eligible investment expert” (as defined in Rule 408g-
1(b)(4)(iii) under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”))
certifying that the computer model used by GPS meets the requirements of Rule 408g-1(b)(4) of ERISA.
Additionally, GSA, at least annually, engages an independent auditor who has provided written
representation to GSA that the auditor has appropriate technical experience and proficiency to conduct
an audit of the investment advice arrangement for compliance with the above requirements.
Restrictions
You may impose reasonable restrictions on how GSA manages your investments, such as requesting that
allocations to certain securities be continuously held (as long as they are available within the enrolled
accounts). These requests may result in different diversification and performance characteristics than
GSA recommendations. Additionally, these restrictions will be analyzed and reviewed by your advisor
to determine how to appropriately incorporate them into your Investment Strategy.
You should consult your advisor before processing any security transactions in your accounts that are
being managed on a discretionary basis through GWM, GMA or GPAS. Processing security transactions
in managed accounts may result in your portfolio’s risk and return characteristics being inconsistent with
your Investment Strategy. Additionally, there may be tax consequences to selling securities in your
taxable investment accounts. Finally, you may be restricted from processing security transactions in
these managed accounts until you terminate the advisory agreement with GSA or if your self-initiated
trades violate the trading policies of the investment assets such as frequent trading limits and market
5
timing prohibitions.
Relating Accounts for Advisory Services and Investment Management
You may elect to apply our advisory services and investment management services across your eligible
non-ERISA accounts through a single advisory agreement or through separate agreements with similar
or different investment strategies for each account or combination of accounts. Your services may
include individual and joint accounts as one single or multiple separate portfolios. ERISA accounts
cannot be included in a portfolio with other accounts where a prohibited transaction under ERISA or the
Internal Revenue Code could result therefore, separate advisory service agreements will be established
for each ERISA account and the assets of ERISA plans will not be considered with the assets of other
accounts when determining fee breakpoints or when providing other planning services. You may elect to
have a common or different investment strategy applied to both your non-ERISA and ERISA accounts
however, the investment strategy applied to an ERISA account will be applied independent of other
accounts and for the sole benefit of the ERISA account as required by ERISA regulations.
Investment Education
In addition to the services described in this Brochure, GSA’s advisors (and other personnel), in their
capacity as registered representatives of GFS or employees of GSFR, will provide “investment
education” to you. Investment education includes, among other things, plan information, and general
financial, investment, and retirement information. For example, information that describes the terms or
operation of an employee benefit plan or individual retirement account (“IRA”), the benefits of plan or
IRA participation, the potential benefits of increasing plan or IRA contributions, the impact of
preretirement withdrawals on future retirement income, retirement income needs, varying forms of
distributions, including rollovers, annuitization and other forms of lifetime income payment options,
advantages, disadvantages and risks of different forms of distributions, or product features, investor
rights and obligations, fee and expense information, applicable trading restrictions, investment
objectives and philosophies, risk and return characteristics, historical return information, or related
prospectuses of investment alternatives available under an employee benefit plan or IRA, is “investment
education” and not “investment advice.”
Likewise, any materials you receive from GSA and its advisors (or other personnel) or from its affiliates
on financial, investment, and retirement matters informing you about general financial and investment
concepts, such as risk and return, diversification, dollar cost averaging, compounded return, and tax-
deferred investment; historic differences in rates of return between different asset classes (e.g., equities,
bonds, or cash) based on standard market indices; effects of fees and expenses on rates of return; effects
of inflation; estimating future retirement income needs; determining investment time horizons; assessing
risk tolerance; retirement-related risks (e.g., longevity risks, market/interest rates, inflation, health care
and other expenses); and general methods and strategies for managing assets in retirement (e.g.,
systematic withdrawal payments, annuitization, guaranteed minimum withdrawal benefits), including
those offered outside your employee benefit plan or IRA, are “investment education” and not
“investment advice.”
The receipt of “investment education” by you or another person does not create an advisory relationship
between you or that person, as a client, and GSA.
Limitations of Financial Planning and Non-Investment Services.
As indicated above, to the extent requested by a client, GSA may provide financial planning and related
planning services. GSA will request updates to your circumstances on an annual basis under GWM,
GMA and GPAS, but it is the client’s responsibility to inform GSA of any changes that may affect the
client’s financial planning. Neither GSA nor its representatives assist clients with the implementation of
6
any financial plan, unless they have agreed to do so in writing. Under GPS, GSA does not help assist
with implementation or monitor a client’s financial plan, and it is the client’s responsibility to revisit the
financial plan with GSA, if desired.
GSA does not serve as an attorney, tax preparer or insurance agency, and no portion of its Financial
Planning services should be construed as legal, tax, accounting or insurance brokerage services.
Accordingly, GSA does not prepare estate planning documents or tax filings, nor does GSA sell
insurance products however, certain affiliates of GSA do offer various insurance products for which
GSA may provide information, referral or a recommendation. To the extent requested by a client, GSA
may recommend the services of an affiliate or other unaffiliated professionals for certain non-investment
implementation purposes (i.e. attorneys, accountants, insurance agents, etc.).
Clients are under no obligation to engage the services of any recommended professional or GSA
affiliate. Referral by GSA of any service or to any professional should not be considered an implied
guarantee of the quality or success of the service or professional.
The client retains absolute discretion over all implementation decisions of any referred or service or
professional and is free to accept or reject any recommendation from GSA. If the client engages any
recommended professional, and a dispute arises thereafter relative to the engagement, the client agrees
to seek recourse exclusively from and against the engaged professional. At all times, the engaged
licensed professional(s) (i.e. attorney, accountant, insurance agent, etc.), and not GSA, shall be
responsible for the quality and competency of the services provided.
Artificial Intelligence
In connection with the delivery of services, GSA may utilize various technology-enabled tools,
including limited artificial intelligence ("AI") applications, to support internal administrative, research,
and compliance-related functions. GSA does not use AI to provide investment advice, make investment
decisions, or manage client portfolios. Investment advice and recommendations offered to clients are
formulated, evaluated, and authorized by GSA’s investment professionals, who apply independent
professional judgment in accordance with fiduciary duties as specified by the Investment Advisers Act
of 1940 and relevant state regulations.
Item 5 – Fees and Compensation
You will pay fees directly to GSA according to your executed advisory or financial planning agreement,
and you will pay fees to GSFR and GSCM if you invest in the Affiliated Funds that may be
recommended to you by GSA. You should consider all fees and expenses prior to investing in any
disciplines or securities.
All of GSA’s advisors (and other personnel) are employees of GSFR, and GSFR bears a material
amount of the operating and other expenses of GSA. Accordingly, GSA depends upon the revenues
earned by GSFR for its operations including the compensation paid to its advisors (who are charged with
providing fiduciary objective advice to clients) and other personnel. GSFR’s revenues consist of, among
other things, shareholder servicing fees received from GuideStone Funds, fees (administrative, certain
marketing and other services) received from the GuideStone Stable Value Fund, revenues received from
the management fees paid by GuideStone Funds to GSCM and revenues received from the advisory fees
paid to GSA. When you invest in an Affiliated Fund, you bear the fees and expenses of the fund, some
of which, as described above and in the GuideStone Funds prospectus and Disclosure Memorandum of
the Declaration of Trust for the GuideStone Stable Value Fund, are paid to GSFR and GSCM. GSA’s
advisors and other personnel therefore indirectly receive compensation (in the form of a salary and
7
incentive compensation from their employer, GSFR) that is funded, at least in part, by the fees and
expenses that you bear in the Affiliated Funds. Because GSA has a conflict of interest (since GSA and
its affiliates indirectly receive management fees from the GuideStone Funds®), purchases and sales of
the GuideStone Funds® must comply with the requirements of DOL Prohibited Transaction Class
Exemption 77-4 (“PTCE 77-4”) for all ERISA accounts.
GSA’s advisors (and other personnel) receive compensation (in the form of a salary and incentive
compensation from their employer, GSFR) that is based, in part, on the number of advisory clients, the
services provided to advisory clients and the overall performance of GSA and GSFR, including, in part,
the amount of assets that clients contribute or rollover from investment accounts, Individual Retirement
Accounts or other employer retirement plans into accounts held at GSFR or its affiliates. This practice
presents a conflict of interest and gives GSA’s advisors (and other personnel) an incentive to
recommend investment products, investment contributions and rollovers to GSA affiliates and products
based on the compensation the advisor or other personnel received, rather than on your needs. GSA and
GFS have policies and procedures to address conflicts that arise from these activities including a strict
prohibition against providing advice or a recommendation on the appropriateness of any rollover
decision, and the conflicts disclosed in this Brochure may also be disclosed separately at account
opening.
GSA and its affiliates will not be paid, any brokerage commissions or other transaction-related fees or
charges in connection with any fund share transactions undertaken to implement GSA’s advice. You
also have the option to purchase investment products that GSA recommends through other brokers or
agents that are not affiliated with GSA.
Investment Management Services
GSA offers investment management services for an annual fee (“IMS Fee”) based upon a percentage of
the average daily balance of your Portfolio. This annual fee will be based on the fees described in your
advisory agreement and range up to a maximum of 1.0% of your Portfolio. The IMS Fee is in addition to
the fees in the Affiliated Funds, fees in the unaffiliated funds, third-party investment manager (TPIM)
fees, account service fees, brokerage fees, transaction fees, electronic funds fees, taxes and other related
costs and expenses on brokerage accounts and security transactions. GSA may also waive and/or offer a
negotiated IMS Fee in certain instances at its discretion.
Financial Planning Services
The GSA financial planning agreement provides for non-discretionary financial planning services. The
agreement will outline the services being provided and indicate the fee for the services. The fees will
then be collected at the time of execution of the financial planning agreement.
GuideStone Wealth Management®
After enrolling in GuideStone Wealth Management, you will pay an annual fee (“GWM Fee”) described
here and illustrated below, based upon a percentage of the average daily balance of your Portfolio. Your
gross GWM Fee will be based on the fee schedule described in your advisory agreement ranging
generally from a minimum of $5,000 and up to a maximum of 1.0% of your Portfolio depending on the
size and composition of your Portfolio. Since GWM includes investment management services and our
full array of financial planning services, you will not be charged a separate IMS Fee or financial
planning service fee. Your GWM Fee is in addition to the fees in the Affiliated Funds, fees in the
unaffiliated funds, TPIM fees, account service fees, brokerage fees, transaction fees, electronic funds
fees, taxes and other related costs and expenses on brokerage accounts and security transactions. Your
gross GWM Fee will be calculated and then reduced by your Fee Credit. Your Fee Credit will be
determined by calculating the pro-rata management and administrative fees paid to GSA affiliates for
8
each Affiliated Fund in your Portfolio for the applicable period. Your GWM Fee is further reduced by
any available Service Credit. Your Service Credit will be equal to the total of shareholder servicing,
marketing and other services fees paid to GSA affiliates through each Affiliated Fund in your Portfolio
and any employer plan service fees paid from your portfolio assets to GSA affiliates up to a maximum
of 0.25% of the average daily balance of your Portfolio or your gross GWM Fee minus your Fee Credit,
whichever is lower. GSA may also waive and/or offer a negotiated GWM Fee in certain instances at its
discretion. Illustrated GWM Fee calculation:
GWM Fee = Gross GWM Fee – Fee Credit – Service Credit
GuideStone Managed Accounts®
After enrolling in a GuideStone Managed Account, you will pay an annual fee (“GMA Fee”) described
here and illustrated below, based upon a percentage of the average daily balance of your Portfolio. Your
GMA Fee will be based on the fees described in your advisory agreement and range up to a maximum of
0.50% of your Portfolio. Since GMA includes investment management services, you will not be charged
a separate IMS Fee. Your GMA Fee is in addition to the fees in the Affiliated Funds, fees in the
unaffiliated funds, account service fees, brokerage fees, transaction fees, electronic funds fees, taxes and
other related costs and expenses on brokerage accounts and security transactions. Your GMA Fee will
be calculated by reducing your gross GMA Fee by your Fee Credit (calculated on a calendar quarter
basis by determining the pro-rata management and administrative fees paid to affiliates of GSA for each
Affiliated Fund in your Portfolio for the applicable quarter). GSA may also waive and/or offer a
negotiated GMA Fee in certain instances at its discretion. Illustrated GMA Fee calculation:
GMA Fee = Gross GMA Fee – Fee Credit
GuideStone Personal Advisory Services® (available to ERISA client accounts only)
After enrolling in GuideStone Personal Advisory Services, you will pay an annual fee (“GPAS Fee”)
described here and illustrated below, based upon a percentage of the average daily balance of your
Portfolio. Your GPAS Fee will be based on the fees described in your advisory agreement and range up
to a maximum of 1.00% of your Portfolio. Since GPAS includes investment management services, you
will not be charged a separate IMS Fee. Your GPAS Fee is in addition to the fees in the Affiliated
Funds, fees in the unaffiliated funds, account service fees, brokerage fees, transaction fees, electronic
funds fees, taxes and other related costs and expenses on brokerage accounts and security transactions.
Your GPAS Fee will be calculated by reducing your gross GPAS Fee by your Fee Credit (calculated on
a calendar quarter basis by determining the pro-rata management and administrative fees paid to
affiliates of GSA for each Affiliated Fund in your Portfolio for the applicable quarter). GSA may also
waive and/or offer a negotiated GPAS Fee in certain instances at its discretion. Illustrated GPAS Fee
calculation:
GPAS Fee = Gross GPAS Fee – Fee Credit
SDA Service Fees
If you open a Self-Directed Account (“SDA”) with GSA, you will pay GSA a 0.10% fee for its servicing
and reporting based upon the average daily balance of assets in each SDA, if attainable, or the end of
quarter balance if the average daily balance for an SDA asset is not available to GSA. Your SDA
Service Fee may be adjusted from time to time by GSA with your written consent. GSA may also waive
and/or offer a negotiated SDA Service Fee in certain instances at its discretion. Your SDA Service Fee is
in addition to the fees of any holdings or investments (including the Affiliated Funds), in the SDA
account service fees, brokerage fees, transaction fees, electronic funds fees, taxes and other related costs
and expenses on brokerage accounts and security transactions. Your SDA Service Fee is separate from
9
the other asset-based fees charged by GSA and the assets in an SDA will not be used in calculating your
other asset-based fees. You will not pay GSA any other asset-based fees on assets in any SDA.
Third-party Investment Manager Fees
If you open an SMA with GSA, you will also pay a fee for the investment management services of any
assets managed by a third-party investment manager (“TPIM”) in an SMA with GSA. The fees you pay
the TPIM will be in addition to the advisory fees paid to GSA. TPIM Fees are determined by the TPIM
and as negotiated by GSA on behalf of its clients. Your TPIM Fees will be paid commencing on the
funding date of the SMA or on the date active management of the SMA by the TPIM begins, whichever
is later. Your TPIM Fee will be paid each calendar quarter in arrears until such time as TPIM’s
management of such SMA is terminated or the SMA is closed or transferred away from GSA. The
market value used in the quarterly fee calculation will be the market value as of the close of business on
the last day of the quarter and will be based on the SMA’s total fair market value as determined by the
TPIM. For periods less than a full calendar quarter your TPIM Fee will be pro-rated by dividing the days
under management by the total calendar days in the quarter. No portion of your TPIM fee will be paid to
or benefit GSA.
Billing
The annual net asset-based fees (IMS Fee, GWM Fee, GMA Fee, GPAS Fee, SDA Service Fee) will be
assessed quarterly, based on the Portfolio average daily balance and prorated for the number of days in
the quarter. The fees will be deducted pro-rata from the accounts in the Portfolio (or another GuideStone
account selected by the client), generally within thirty calendar days after each quarter’s end, by
redeeming fund shares, liquidating client assets or from cash or cash equivalents within the enrolled
accounts.
Terminations
In the event the advisory agreement with GSA is terminated, or services rendered for any reason before
the current quarter has ended, GSA will calculate and deduct the applicable asset-based fee based on the
average daily balance of your accounts that pay these fees for the incomplete quarter. The calculation
will use the most recent completed quarter’s net advisory fees paid to affiliates of GSA in the underlying
Affiliated Funds in calculating any applicable Fee Credit. The TPIM will calculate and deduct a pro-
rated TPIM Fee by dividing the actual calendar days under management by the total actual calendar days
in the quarter.
Insurance Products
As noted above GSA offers financial planning services which may include evaluation of your insurance
policies and providing insurance planning. GSA may refer you to an unaffiliated insurance broker or to a
GSFR affiliate that provides insurance products. GSA and its advisors do not receive commissions or
payment if you purchase an insurance product from a recommended unaffiliated insurance broker. GSA
and its advisors do not receive commissions or any direct compensation when you purchase a GSFR
affiliate’s insurance product however the relationship between GSA and its affiliates creates a conflict
when GSA recommends a GSFR affiliate’s product. GSFR bears a material amount of the operating and
other expenses of GSA. Accordingly, GSA depends upon the revenues earned by GSFR and its affiliates
for its operations, including compensation paid to its advisors and other personnel. Additionally, GSA
employees receive incentive compensation that is, in part, based on the performance of GSFR and its
affiliates. Therefore, GSA and its representatives have a financial interest in recommending GSFR
affiliated products. However, clients are under no obligation to purchase affiliated insurance products to
receive GSA services and there may be other similar products available with the same or better
provisions at lower costs, from which GSA, its GSFR affiliates and its representatives receive no
compensation whatsoever.
10
GPS: Guided Planning Services®
As noted above, GSA does not charge a separate fee for the use of GPS by any client.
Aggregating Accounts For Fee Purposes
IMS, GWM and GPAS advisory services provide fee breakpoints based on the average daily balance of
the managed assets in a portfolio. When determining breakpoints, the average daily balance of all
managed accounts in a portfolio are combined to calculate an aggregate balance in order to apply the
breakpoints across the portfolio accounts. ERISA regulations prohibit the aggregation of ERISA
accounts with other accounts. Therefore, separate advisory service agreements are established for each
non-related ERISA account and the assets of non-related ERISA accounts cannot be aggregated with
other accounts when calculating average daily balances to determine fee breakpoints.
Item 6 – Performance-Based Fees and Side-by-Side Management
GSA does not charge any performance-based fees.
Item 7 – Types of Clients
GSA offers advisory and financial planning services to individuals including those with high net worth
and individuals considered as a “qualified client” under Rule 205-3 of the Investment Advisers Act of
1940, or individuals and other entities that are a “qualified purchaser” under 15 USC § 80a-2(a)(51),
trusts, estates, charitable organizations and other business entities. GSA generally requires a minimum
of $500,000 in assets under management and generally $5,000 in minimum annual gross fees for GWM
but has discretion to accept lower amounts. GSA does not require a minimum asset amount for other
services. Investment in an SMA requires various minimum asset levels as determined by the TPIM
managing the selected investment strategy.
GWM is not available for any ERISA plan accounts. GPAS is limited to ERISA plan client accounts.
GMA and GPS are available on any non-ERISA GuideStone account. Each employer sponsor of an
ERISA plan eligible for GPS, GPAS and GMA services has entered into a written agreement
acknowledging the employer’s fiduciary relationship to the plan and the selection of GSA to provide
GPAS and GMA services to individuals who have account balances in the plan. The employer has
received and reviewed disclosures of the investment advisory and other fees charged to or paid by GPAS
and GMA accounts and the Affiliated Funds, the reasons why GSA may consider such purchases to be
appropriate for GPAS and GMA accounts and whether there are any limitations on GSA with respect to
the assets of GPAS or GMA accounts that may be invested in the Affiliated Funds and, if so, the nature
of such limitations. Based on the prospectus and disclosures provided by GSA, the employer has
approved purchases and sales of the Affiliated Funds consistent with the responsibilities, obligations,
and duties imposed on fiduciaries by Part 4 of Title I of ERISA. As permitted by PTCE 77-4, the
employer’s approval is limited solely to the investment advisory and other fees paid by the Affiliated
Funds in relation to the fees paid by a GPAS or GMA participant’s account and does not relate to any
other aspects of the investments. Any changes to the fees require notice to and approval by the
sponsoring employer for the continuance of services.
Item 8 – Methods of Analysis, Investment Strategies and Risk of
Loss
11
The advisory services and investment strategies developed and provided by GSA are based on the
information provided by you and consistent with long-term investing and diversification principles. As
part of the investment analysis GSA conducts when developing the investment strategies it recommends,
GSA utilizes research and analysis provided by GSCM, an affiliated registered investment adviser.
Specifically, GSCM provides the following services and information to GSA:
• Develop, propose and maintain asset allocation models.
• Develop and maintain benchmark-relative performance measurement for the asset allocation
models.
• Employ an objective, quantitative methodology to rate available mutual funds on the GSFR
retirement plan recordkeeping platform by asset class.
• Recommend available private funds.
• Provide evaluations of separately managed account strategies.
Investment risks
By investing in the Affiliated Funds, unaffiliated funds, equity securities or fixed income securities, or
following any investment strategy or plan you will be exposed to risks including the loss of a substantial
portion or all your investment. Investing in any type of security involves risk of loss that you should be
prepared to bear. In addition, each of the funds and SMA strategies has its own unique risks based on its
investment objective and principal investment strategies.
These risks are described in the prospectus for each respective fund or in the Declaration of Trust for the
GuideStone Stable Value Fund or in the disclosures of the TPIMs of the SMA strategies. However, there
are some risks that can generally be applied to all funds such as: market risk, which is the possibility that
fund prices overall will decline over short or even extended periods; principal risk, which is the
possibility that an investment will decline below the original or invested amount; interest rate risk,
which is the possibility that fund prices will be adversely affected by changes in interest rates; and
manager risk, which is the possibility that an investment manager will fail to execute an investment
strategy effectively.
Additionally, the Affiliated Funds and SMA strategies adhere to the faith-based investing policy of
GSFR and therefore do not invest in any company that is publicly recognized, as determined by GSFR,
as being in the alcohol, tobacco, gambling, pornography or abortion industries, or any company whose
products, services or activities are publicly recognized as being incompatible with the moral and ethical
posture of GSFR. Due to these restrictions, the Affiliated Funds and SMA strategies will not be able to
take advantage of certain investment opportunities, and this may adversely affect the investment
performance you realize other than would be the case without these restrictions. Some of the Affiliated
funds utilize impact investing criteria that could cause them to perform differently compared to funds
that do not apply such criteria.
Index strategies used by the Affiliated Funds and TPIM generally involve investing in securities
included in a benchmark index, or a representative sample of such securities, regardless of market
trends. Strategies employing an index strategy may not perform as well as investments in an actively
managed strategy that select securities based on economic, financial and market analysis, because the
index strategy may not sell a security if its issuer is in financial trouble, unless that security is removed
or is anticipated to be removed from the index. An index strategy must pay various expenses, and
therefore, its return may differ from the benchmark index’s total return, which does not reflect any
expenses. Cash flow into and out of an index strategy portfolio, portfolio transaction costs, changes in
the securities that comprise the index strategy and the strategy’s valuation procedures also may affect an
index strategy performance. For any index-based strategy, the faith-based investment policies and
12
restrictions will prevent investing in certain securities which comprise the index, which may result in
lower performance than the index and contribute to a lower correlation between the performance of the
strategy and the index. Index strategies will not contain the complete component composite of the
benchmark index which will contribute to a lower correlation between the performance of the strategy
and the benchmark. Therefore, there can be no assurance that the performance of the index strategy will
match that of its benchmark index.
SMAs will invest in and trade individual equity and fixed income securities according to strategies
designed by the TPIM and selected for your account based on your risk tolerances and objectives.
Investment in individual securities carry various risks which may be realized based on the strategy,
selection and trading activity of the TPIM. Long-term risk is the risk of experiencing gains in the value
of a security followed by experiencing losses without the TPIM capturing the opportunity to realize the
gains prior to disposal. Short-term risk is the risk the TPIM will sell/buy too early/late and miss out on
gains or receive too many losses and incur increased trading costs and greater tax liabilities on behalf of
you. An SMA strategy is also subject to failure by the TPIM to successfully perform fundamental,
technical or quantitative analysis in selecting investments to fulfill their strategy. The risk of
fundamental analysis is looking at the historical and present financial statements of a company and
reviewing the information to gain insight on a company’s future performance in light of the overall
economy and industry specific conditions and determining a different outcome from others. Technical
analysis is reviewing patterns and trends of a specific security/sector and using data of past prices and
volume to predict what a security will do in the future. Execution of the data is at the discretion of the
person reviewing the data and past performance is not a guarantee of future performance resulting in
technical analysis risk. Quantitative analysis is the technique that tries to understand the behavior of a
security/sector by using complex mathematical and statistical modeling used for performance
evaluation, valuation of an instrument or in an attempt to predict market events. Quantitative analysis
involves risk because it does not factor in all possible variables and the formulas and processes used to
predict outcomes are insufficient to guarantee infallible analysis.
Software and modeling risks
GSA’s advice relies heavily on the use of financial planning software. The validity of the output and
projections produced by the software is dependent on several factors, among others the analytical and
mathematical models underpinning the software, the incorporation of those models in complex
computations and software coding and the quality and accuracy of the data provided by you and put into
the software. GSA attempts to ensure that the software and the underlying models are sound in their
development and appropriately adapted, calibrated, configured and protected. However, software
development and implementation errors and other types of inadvertent systems or human errors are an
inherent risk in this process, as are risks of loss, corruption or error due to computer viruses, computer
worms, computer hacking, unauthorized intrusions, outages or other outside factors. These risks could
adversely affect output received from such financial planning software.
The projections presented within GSA’s advice are hypothetical in nature, do not deduct any investment
fees or expenses and are no guarantee that you will meet your retirement and/or financial goals if you
implement GSA’s advice. The services are based on assumptions about capital markets, inflation,
economic factors and other matters. In some cases, these assumptions are forward-looking projections
and estimates that, by their nature, are inherently difficult to predict and might turn out to be wrong.
Historical data used to make projections – such as historical returns, correlations and growth rates – may
not be borne out in the future.
Technology and Artificial Intelligence
As part of its investment advisory operations, GSA may use technology-enabled analytical tools to assist
in research, operational efficiency, and compliance support. These tools may include software
13
applications that incorporate artificial intelligence; however, such tools are used solely as decision-
support resources and do not replace human analysis, oversight, or accountability.
GSA does not rely on artificial intelligence to formulate investment strategies, select securities,
determine asset allocations, or execute trades on behalf of clients. AI tools are not permitted to generate
or communicate investment advice to clients or to make autonomous investment or trading decisions.
The use of technology, including artificial intelligence and third-party software, involves inherent
operational and data-related risks, including risks associated with model limitations, data integrity, and
over-reliance. GSA maintains controls designed to identify and manage these risks; however, no system
of controls can eliminate all such risks.
GSA maintains policies and procedures reasonably designed to address risks associated with the use of
technology, including artificial intelligence, in its advisory operations in alignment with the policies of
GSFR. These policies and procedures include limitations on permitted uses of AI tools, requirements for
human review of AI-assisted outputs prior to reliance, role-based access controls, and employee training
regarding responsible technology use and the exercise of independent professional judgment.
GSA conducts due diligence and ongoing oversight of third-party software providers, including
evaluation of whether such providers utilize artificial intelligence in connection with services provided
to GSA. As part of this process, GSA reviews vendor policies and practices relating to data protection,
privacy, and information security to assess consistency with GSA’s obligations under Regulation S-P
and related internal policies.
GSA is subject to Regulation S-P and maintains policies and procedures designed to safeguard client
nonpublic personal information. The Firm’s use of technology, including artificial intelligence and third-
party service providers, is governed by its privacy, cybersecurity, and data governance policies. GSA
does not permit the use of AI tools in a manner that would be inconsistent with its privacy obligations
under applicable law.
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 GSA or the integrity of its management.
GSA has no information to disclose applicable to this section.
Item 10 – Other Financial Industry Activities and Affiliations
GSA has several financial industry affiliates, described below. For purposes of efficiency, consistency
and overall corporate governance, persons typically serve in officer or other roles of GSA and one or
more affiliates. Personnel allocate their time among various roles as needed.
GuideStone Financial Resources of the Southern Baptist Convention (GSFR), as described in Item 4
– Advisory Business above, is the sole member of GuideStone Advisors, and GuideStone Advisors is the
manager and a member of GSA. GSFR is a church benefits board that provides or makes available
retirement, health and welfare and other employee benefit programs for organizations controlled by or
associated with the Southern Baptist Convention, and other organizations determined by GSFR to share
common convictions with the Southern Baptist Convention, as well as the ministers and employees
serving them. GSFR manages or holds assets contributed to church plans or other assets which are
14
permitted to be commingled with the assets of church plans under the Internal Revenue Code of 1986.
Affiliates of GSFR also make available certain risk management programs, such as property and
casualty coverages, for organizations it is eligible to serve. The principal business of GSA’s executive
officers is GSFR and the customers of GSFR and its affiliates. GSA indirectly receives material support
including compensation for its advisors and other personnel and for its operations from GSFR.
GuideStone Financial Services is an affiliated broker-dealer under common control of GSFR with
GSA. All advisory personnel of GSA are licensed as registered representatives of GFS. GFS offers and
sells GuideStone Funds mutual fund shares through retail and institutional accounts. GFS charges no
brokerage fees on its sale of the GuideStone Funds.
GuideStone Funds is an affiliated investment company under common control of GSFR with GSA.
GSA’s investment advice will include the GuideStone Funds within the recommended model portfolios
and as individual investments if GSA determines a GuideStone Fund best fulfills/completes a portfolio
strategy.
GuideStone Capital Management, LLC is an affiliated investment adviser under common control of
GSFR with GSA. GSCM provides asset allocation models, mutual fund ratings, private fund
recommendations, and other non-discretionary investment advice that GSA utilizes, in its discretion, in
formulating investment advice to its clients. GSCM also serves as investment adviser for each of the
GuideStone Funds.
GSA’s relationships and arrangements with these affiliates pose conflicts of interest, as more fully
described in the section immediately below.
Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
GSA has a Code of Ethics that governs the activities of its personnel. Additionally, GuideStone Funds
and GSCM, each an affiliate of GSA, have a Code of Ethics that governs the activities of its personnel.
In providing investment advice, GSA recommends the GuideStone Funds. Affiliates and personnel of
GSA may buy and sell, for themselves, these same securities, but only in accordance with GSA’s Code
of Ethics.
GSA’s affiliate(s) receive a shareholder servicing fee of 0.25% of average daily net assets from the
Investor Class of GuideStone Funds. Because the Institutional Class of GuideStone Funds does not bear
this fee, GSA’s affiliate(s) will benefit to a greater degree from a client’s investments in the Investor
Class of GuideStone Funds. This represents a conflict of interest for GSA when the option to invest in
the Investor and Institutional class of the same or another GuideStone Fund is available within your
portfolio accounts or through other available investment accounts. If a discretionary client who holds
Investor Class shares becomes eligible for Institutional Class shares, GSA will coordinate and request
consent from the client to transfer/convert their shares; however, such transfer/conversion requires the
client’s consent and will not be made automatically. Share class eligibility is established by GuideStone
Funds and determined by account type and amount and is not subject to the discretion of GSA.
GSA has adopted a Code of Ethics in which GSA recognizes and establishes that GSA and its personnel
owe a fiduciary duty to clients. As a fiduciary, GSA has an obligation to only make recommendations
and exercise its discretionary authority in the best interest of each client. All GSA personnel must adhere
15
to this fiduciary duty in all their business activities. Even when a particular activity is not specifically
addressed in the Code of Ethics or other parts of GSA’s policies and procedures, supervised persons are
required to “do what is best” for the client.
GSA’s Code of Ethics states that GSA and its personnel must always place the interests of clients first
and that GSA and its personnel must always comply with applicable federal securities laws, including
the Investment Company Act of 1940 and the Investment Advisers Act of 1940. The Code of Ethics
requires GSA’s personnel to report their personal securities holdings and transactions to GSA for review
on at least a quarterly basis. On occasion, GSA may recommend that a client buy or sell equity or fixed
income securities in which GSA employees may also invest. This could create a potential conflict of
interest. To avoid conflicts of interest, we do not allow GSA personnel to trade in their personal or
beneficial accounts in conflict with the investment interests of our clients. Employees may not trade
securities in their own accounts ahead of clients or take advantage of their knowledge of pending or
active transactions in client accounts. The giving and receiving of gifts by or to personnel of GSA are
restricted and monitored for potential conflicts of interest.
The Code of Ethics also requires that personnel report any violations of its policies and the Code of
Ethics to GSA’s Chief Compliance Officer (CCO).
Upon becoming a supervised person of GSA and at least annually, GSA provides copies of the Code of
Ethics to its personnel. Personnel are required to attest to having received, to having read, to having
understood and that they will abide by the Code of Ethics.
GSA will provide a copy of the Code of Ethics to any clients or prospective clients upon request by
calling 1-888-98-GUIDE (1-888-984-8433).
Other interests
GSA and its advisors recommend investments in which GSA or its affiliates have a material financial
interest. GSCM is the investment adviser to GuideStone Funds, which GSA and its advisors recommend
to clients. GSFR receives payments for recordkeeping, certain marketing and other services from the
GuideStone Stable Value Fund. GSFR also receives fees as a shareholder servicing agent of GuideStone
Funds. This presents conflicts of interest, because these investments pay fees to GSCM and/or GSFR, as
described herein.
GSA’s advisors, acting in their capacity as employees of GSFR and/or registered representatives of
GFS, make recommendations, in some instances, to increase the client’s contribution rate to his or her
account(s). The compensation that the advisors receive as employees of GSFR depends, at least in part,
on the amount of new assets that clients contribute, rollover, or otherwise invest in Affiliated Funds.
This practice creates an inherent conflict of interest for an advisor to the extent he or she personally
benefits financially (e.g., from increased incentive compensation) due to client contributions, rollovers
and/or other investments into GuideStone investment products and employee benefit plans. GSA has
adopted policies and procedures that are reasonably designed to ensure that all investment advice
rendered to clients by GSA or an advisor is, at the time of the recommendation, in the client’s “best
interest,” which means that the advice reflects the care, skill, prudence, and diligence under the
circumstances then prevailing that a prudent person acting in a like capacity and familiar with such
matters would use in the conduct of an enterprise of a like character and with like aims, based on the
client’s investment objectives, risk tolerance, financial circumstances, and needs, without regard to the
financial or other interests of the advisor, GSA or any affiliate or other party.
The amount of fees paid to GSA’s affiliates by the Affiliated Funds varies by Fund. Fees paid to GSA’s
affiliates, as well as overall Fund expenses, may be higher in the GuideStone Funds series of target date
funds (known as the MyDestination Funds®) and target risk funds (known as the Asset Allocation
16
Funds) since those funds invest their assets in various GuideStone Select Funds. They therefore bear
their proportionate share of the expenses of the GuideStone Select Funds in which they invest in
addition to their own expenses. For more detailed information regarding the fees and expenses of the
GuideStone Funds, you should refer to the GuideStone Funds prospectus. For more detailed information
regarding the fees and expenses of the GuideStone Stable Value Fund, you should refer to the
GuideStone Stable Value Trust Declaration of Trust and the Disclosure Memorandum Appendix A
GuideStone Stable Value Trust Schedule of Fees.
In addition to fees paid to GSA’s affiliates by the Affiliated Funds, GSA personnel may also be invested
personally in these Funds that are recommended. As a result, they may benefit like all shareholders from
the added stability and positive effects afforded by new fund inflows when GSA’s clients invest in the
Affiliated Funds.
Due to the foregoing, GSA’s advisors have a conflict of interest because they have a financial incentive
to recommend that you invest in the Affiliated Funds that will benefit, or will most benefit, GSA’s
affiliates. However, an advisor’s compensation does not vary based upon specific investment
recommendations (i.e., as to which Affiliated Fund or unaffiliated fund a client should invest in).
Item 12 – Brokerage Practices
Accounts not requiring brokerage services
Certain client accounts are not maintained, custodied or serviced by a broker-dealer. Transactions in an
employee benefit plan serviced by GSFR are processed through omnibus accounts by GSFR as the
qualified custodian of the plan. Retail accounts consisting of only GuideStone Funds are processed
directly with GuideStone Funds through the transfer agent of the Funds. Clients will not be charged, and
GSA and its affiliates will not be paid, any brokerage commissions or other transaction-related fees or
charges in connection with any such transactions. GSA’s best execution responsibility on these accounts
is satisfied if securities that it purchases for client accounts are mutual funds in the lowest priced eligible
share class to the account that trade at net asset value as determined at the daily market close.
Accounts requiring brokerage services
Accounts containing assets that are not part of an employee benefit plan or invested solely in
GuideStone Funds must be held in an account at an unaffiliated “qualified custodian”, generally a
broker-dealer or a bank. GSA requires our clients use Charles Schwab and Co., Inc (Schwab) a
registered broker-dealer, member SIPC, as the qualified custodian for client accounts that contain assets
that are not part of an employee benefit plan or invested solely in GuideStone Funds as described in the
above section.
GSA and its affiliates have no ownership affiliation with Schwab or any Schwab affiliate. Schwab will
hold your invested assets in a brokerage account and buy and sell securities when instructed by you, us
or a third-party investment advisor according to the GSA services you select. While we require you to
use Schwab as your custodian/broker for our services on these certain accounts, you will decide whether
to do so and you will open your account directly with Schwab by entering into a separate account
agreement directly with them. GSA and its affiliates will not be paid, any brokerage commissions or
other transaction-related fees or charges in connection with any brokerage transaction conducted by
Schwab.
We do not open the brokerage account for you although we may assist you in doing so. If you do not
wish to place your assets that are not in an employee benefit plan or invested solely in GuideStone
Funds with Schwab, then we cannot manage those assets for you. Even though these account types are
17
maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still
use other brokers to execute trades for your account as described below (see “Your brokerage and
custody costs”).
You should be aware not all advisors require their clients to use a particular broker-dealer or other
custodian selected by the advisor. Conflicts of interest with this arrangement are described below as well
as in Item 14 Client Referrals and Other Compensation. You should consider these conflicts of interest
when selecting your broker/custodian and advisor services.
How we select broker/custodians
We do not select the broker or custodian for client assets that are part of an employee benefit plan or
assets invested solely in GuideStone Funds through a retail account. The custodians for those assets are
determined by the employee benefit plan and GuideStone Funds, respectively. We use Schwab, a
custodian/broker, to hold assets and execute security transactions for all other asset accounts GSA
provides advisory and/or other services for on your behalf. When considering whether the terms that
Schwab provides are, overall, most advantageous to you when compared with other available providers
and their services, we consider a wide range of factors. Including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payment to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), etc.)
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.)
• Reputation, financial strength, security and stability
• Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below (see “Products
and services available to us from Schwab”)
Your brokerage and custody costs
The brokerage commissions or transaction fees charged by Schwab are exclusive of, and in addition to,
GSA’s advisory fees, TPIM fees or any underlying fees in any mutual funds or ETFs. Neither GSA nor
any of its representatives will receive any of these brokerage commissions or transaction fees charged by
Schwab.
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. Certain trades (for example, mutual funds and ETFs)
do not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest
on the uninvested cash in your account in Schwab’s Cash Features Program.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not required
to execute all trades through Schwab, we have determined that having Schwab execute most trades is
consistent with our duty to seek “best execution” of your trades. Best execution means the most
favorable terms for a transaction based on all relevant factors, including those listed above (see “How
we select brokers/custodians”). By using another broker or dealer you may pay lower transaction costs.
18
Products and services available to us from Schwab
Schwab Advisor ServicesTM is Schwab’s business serving independent investment advisory firms like
us. They provide our clients and us with access to their institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to Schwab retail customers.
However, certain retail investors may be able to obtain institutional brokerage services without going
through us. Although not a material consideration when determining to require that a client use the
services of Schwab, Schwab will make available, and GSA will receive various support services from
Schwab. Some of those services help us manage or administer our client’s accounts, while others help us
manage and grow our business. Schwab’s support services are generally available on an unsolicited
basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of
Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets. The
investment products available through Schwab include some to which we might not otherwise have
access or that would require a significantly higher minimum initial investment by our clients.
Schwab’s services described in this paragraph generally benefit you and your account.
Services that do not directly benefit you but may provide a benefit to the services we provide.
Schwab also makes available to us other products and services that benefit us but do not directly
benefit you or your account. These products and services assist us in managing and administering our
clients’ accounts and operating our firm. They include investment research, both Schwab’s own and
that of third parties. We can use this research to service all or a substantial number of our clients’
accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab
also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
statements),
facilitate trade execution and allocate aggregated trade orders for multiple accounts,
•
• provide pricing and other market data,
facilitate payment of our fees from our clients’ account, and
•
assist with back-office functions, recordkeeping, and client reporting.
•
Services that generally benefit only us. Schwab also offers other services intended to help us
manage and further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and compliance related needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing, consulting, and support
19
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide these services to us. Schwab also discounts or waives its fees for some of these services or
pays all or part of a third party’s fees. Schwab also provides us with other benefits, such as occasional
business entertainment or meals for our personnel. If you did not maintain your account with Schwab,
we would be required to pay for those services from our own resources. GSA’s clients do not pay
more for investment transactions effected and/or assets maintained at Schwab as a result of this
arrangement. There is no corresponding commitment made by GSA to Schwab (or any other any
entity) to invest any specific amount or percentage of client assets in any specific securities or other
investment products as a result of the above arrangement.
GSA only seeks to accept the above services from Schwab to the extent the services benefit you
directly or indirectly and enable us to better serve you and all GSA clients. We realize, and you
should also realize, that you may not benefit from each or any of the services described above if we or
you do not use the services. For example, if we or you do not execute trades in your accounts or use a
significantly broad range of securities you will not benefit from Schwab’s securities execution
services or access to their broad range of investment products. You also will not be aware of when or
to what measurable extent the indirect services benefit you such as when we receive data from your
Schwab accounts or the amount of efficiency gained in servicing your account from services such as
the aggregation of trade orders for your account with other client accounts, assistance with our back-
office functions, recordkeeping and reporting on your account and facilitation of payment of our fees
from your account. However, to the extent we and you use the services we believe you will benefit in
product availability and client experience.
Our interest in Schwab’s services
The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don’t have to pay for Schwab’s services. The services we receive from Schwab are
not contingent upon us committing any specific amount of business to Schwab in trading commissions
or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to require
the use of Schwab rather than making such a decision based exclusively on your interest in receiving the
best value in custody services and the most favorable execution of your transactions. This is a conflict of
interest. We also realize the services that generally benefit only us present an additional conflict of
interest in our requirement on you to use Schwab in order to access our services on these accounts. GSA
has implemented procedures to monitor and reasonably mitigate this conflict of interest as part of our
Code of Ethics described in Item 11. Procedures include review of the receipt of these services or any
benefits or gifts from Schwab by the Firm or an associated person of GSA by the Chief Compliance
Officer of GSA for determination of reasonableness. We believe, that taken in the aggregate our
selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is
primarily supported by the scope, quality, and price of Schwab’s services (see “How we select
brokers/custodians”) and not Schwab’s services that benefit only us.
Electronic Confirmations/Account Statements
Unless you advise GSA or the custodian to the contrary, GSA will advise each custodian you elect to
provide electronic trade confirmations and account statements directly to. You should carefully review
and compare all trade confirmations and account statements received from GSFR, the transfer agent of
the GuideStone Funds and Schwab with account information provided by GSA.
Item 13 – Review of Accounts
GSA will monitor and rebalance your Portfolio as described in your Investment Strategy. We will
request a meeting with you to review your respective Investment Strategy, Wealth Plan, Managed Plan
20
and/or Financial Plan on at least an annual basis to determine if there have been any changes to your
circumstances that would necessitate adjustments. If you do not respond to our requests to conduct an
annual review, we will assume that there have not been any changes to your circumstances (e.g.,
financial situation, risk tolerance, time horizon, investment objectives and goals). If there are any
material changes to your circumstances in between your annual review, it is critical that you inform us
of this information so that we can incorporate it and determine if any recommendations need to be
adjusted.
GSA offers GPS on an individual instance at a specific point in time and therefore does not conduct any
ongoing monitoring of the individual client or the advice delivered. Clients are solely responsible for
implementing and maintaining any desired GPS advice received from GSA.
Item 14 – Client Referrals and Other Compensation
GSA receives an economic benefit from Schwab in the form of the support products and services it
makes available to us and other independent investment advisors whose clients maintain their accounts
at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we
would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a
certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the arrangement because the cost of these services would otherwise be borne
directly by us. You should consider these conflicts of interest when selecting a custodian. The products
and services provided by Schwab, how they benefit us, and the related conflicts of interest are described
above (see Item 12 – Brokerage Practices).
GSA does not have any arrangements, oral or in writing, whereby it directly or indirectly compensates
any unrelated person for client referrals. However, GSA receives material support for its operations from
GSFR and GSFR and its affiliates and the employees of GSFR provide client referrals to GSA. GSFR,
its affiliates and the employees of GSFR benefit from the success, service, and revenues of GSA.
Because of the relationship between GSA and GSFR and its affiliates, there is a conflict of interest when
these referrals are made. You will not pay additional fees because of these referrals, and you are not
required to retain the advisory services of GSA to receive the services or products of GSFR or its
affiliates and comparable services may be available from other advisers for lower fees. These
arrangements and GSA’s affiliate relationships are described more fully in section Item 5 – Fees and
Compensation, section Item 10 –Other Financial Industry Activities and Affiliations and section Item 11
– Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.
Item 15 – Custody
GSA is not a broker-dealer and does not take direct possession of your assets. Your assets will be held
by a qualified custodian or a broker-dealer. GSFR acts in the capacity of a qualified custodian for the
employee benefit plans GSA serves. The GuideStone Funds transfer agent serves as the qualified
custodian of investment accounts held directly with GuideStone Funds. GSA has selected Schwab to
serve as the broker-dealer and custodian for assets in an SMA or SDA.
Due to our affiliate relationship with GSFR we are deemed to have custody of your assets if managed
under any of our Investment Management Services. These practices are subject to an annual surprise
custody examination in accordance with the requirements of Rule 206(4)-2 under the Investment
Advisers Act of 1940. Further, GSA has the ability to deduct its net asset-based advisory fees and SDA
Fees from your Portfolio and is deemed to have custody of your assets in accordance with Rule 206(4)-
21
2. You receive transaction confirmation notices and account statements from the custodians (i.e., GSFR,
GuideStone Funds’ transfer agent, Schwab) at least quarterly. Please Note: Please compare any
statements provided by GSA with the account statements you receive from the respective account
custodian.
Item 16 – Investment Discretion
For clients with an Investment Strategy, GSA will have discretionary authority to conduct the necessary
investment transactions as efficiently as possible to implement and maintain your Portfolio in
accordance with your Investment Strategy without additional approval. This would include changing the
specific investments used to implement the Investment Strategy (without additional notice to you) as
long as any changes are consistent with your Investment Strategy.
GSA will not exercise discretionary authority on any assets in an SDA. Additionally, when GSA
provides GPS advice it is provided at a specific point in time and does not involve the ongoing
management of client assets on either a discretionary or non-discretionary basis. GSA will not have, nor
will it exercise investment or brokerage discretion over any GPS client’s assets or accounts. GPS clients
can choose to implement any advice received from GSA in their sole discretion, and GSA or its
personnel are available to assist clients in this implementation. Clients will not be charged, and GSA and
its affiliates will not be paid, any brokerage commissions or other transaction-related fees or charges in
connection with any such transactions.
Item 17 – Voting Client Securities
GSA does not have or accept authority to vote proxies on client owned securities. Proxies for client
securities will be delivered by the custodians of the client account. Additionally, if you delegate voting
authority to GSA in your SMA or SDA through your brokerage accounts, GSA will abstain from voting any
client securities.
Item 18 – Financial Information
Registered investment advisers are required in this section to provide certain financial information or
disclosures about their financial condition. GSA has no information to disclose applicable to this section.
22