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Item 1
Cover Page
GuideStream Financial, Inc.
SEC File Number: 801 – 70418
ADV Part 2A, Firm Brochure
Dated: July 30, 2025
Contact: Joseph Crupper, Chief Compliance Officer
8050 Spring Arbor Road
Spring Arbor, Michigan 49283
www.guidestreamfinancial.com
This Brochure provides information about the qualifications and business practices of GuideStream
Financial, Inc. (“GuideStream Financial”). If you have any questions about the contents of this
Brochure, please contact us at (517) 750-2727. 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 GuideStream Financial, Inc. also is available on the SEC’s website at
www.Adviserinfo.sec.gov.
References herein to GuideStream Financial, Inc. as a “registered investment advisor” or any
reference to being “registered” does not imply a certain level of skill or training.
Item 2
Material Changes
Since its Annual Amendment filing on March 14, 2025, the following material change has been made to
the Guidestream Financial Form ADV Disclosure Brochure:
As of September 1, 2025, Pershing, the Firm’s primary custodian, is implementing the following
changes
o Asset-based fee increasing from 0.03% to 0.045%
o Closing account fee increasing from $75 to $125
Item 3
Table of Contents
Item 1 Cover Page .................................................................................................................................... 1
Item 2 Material Changes .......................................................................................................................... 2
Item 3
Table of Contents .......................................................................................................................... 2
Item 4 Advisory Business ........................................................................................................................ 3
Fees and Compensation .............................................................................................................. 12
Item 5
Performance-Based Fees and Side-by-Side Management .......................................................... 15
Item 6
Item 7
Types of Clients .......................................................................................................................... 15
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................... 16
Item 9 Disciplinary Information ............................................................................................................ 18
Item 10 Other Financial Industry Activities and Affiliations .................................................................. 18
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.............. 19
Item 12 Brokerage Practices .................................................................................................................... 19
Item 13 Review of Accounts .................................................................................................................... 22
Item 14 Client Referrals and Other Compensation .................................................................................. 22
Item 15 Custody ....................................................................................................................................... 22
Item 16
Investment Discretion ................................................................................................................. 23
Item 17 Voting Client Securities .............................................................................................................. 24
Item 18 Financial Information ................................................................................................................. 24
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Item 4 Advisory Business
A. GuideStream Financial is a corporation formed on June 22, 2009 in the state of Michigan.
GuideStream Financial became registered as an Investment Advisor Firm on August 24,
2009. GuideStream Financial is owned by The Free Methodist Foundation. Mark Steven
Olson is GuideStream Financial’s President.
B.
INVESTMENT ADVISORY SERVICES
GuideStream Financial provides discretionary and non-discretionary investment advisory
services on a fee basis as discussed at Item 5 below. Before engaging GuideStream
Financial to provide investment advisors services, clients are required to enter into an
Investment Advisory Agreement with GuideStream Financial setting for the terms and
conditions of the engagement, including termination, describing the scope of the services
to be provided, and the fee that is due from the client.
GuideStream Financial also provides discretionary only investment advisory services to
“Institutional Clients”, i.e., endowments, charities, churches, non-profit organizations,
pension plans and other faith-based organizations, who generally have an investment
timeline of at least five to seven years on a fee basis as discussed at Item 5 below.
To commence the investment advisory process, GuideStream Financial will ascertain each
client’s investment objective(s) and then allocate the client’s assets consistent with the
client’s designated investment objective(s). Once allocated, GuideStream Financial
provides ongoing supervision of the account(s).
GuideStream Financial's annual investment advisory fee shall include investment advisory
services, and, to the extent specifically requested by the client, financial planning and
consulting services. In the event that the client requires extraordinary planning and/or
consultation services (to be determined in the sole discretion of GuideStream Financial),
GuideStream Financial may determine to charge for such additional services, the dollar
amount of which shall be set forth in a separate written notice to the client.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
GuideStream Financial may provide financial planning and/or consulting services on a
stand-alone separate fee basis to clients who have not engaged GuideStream Financial to
provide investment management services. Prior to engaging GuideStream Financial to
provide planning or consulting services, clients are generally required to enter into a
Financial Planning and Consulting Agreement with GuideStream Financial setting forth
the terms and conditions of the engagement (including termination), describing the scope
of the services to be provided, and the portion of the fee that is due from the client prior to
GuideStream Financial commencing services.
implementation purposes,
If requested by the client, GuideStream Financial may recommend the services of other
professionals for
including certain representatives of
GuideStream Financial in their separate capacities as licensed insurance agents. (See
disclosure at Items 5 and 10 below). The commission compensation earned by an insurance
agency and its agents is separate from, and in addition to, GuideStream Financial’s
investment advisory fee. The recommendation by GuideStream Financial that a client
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consider the purchase of an insurance product from an insurance agency presents a conflict
of interest, as the potential receipt of an insurance commission compensation by the
insurance agency and its agent(s) may provide an incentive for GuideStream Financial to
recommend insurance products based on compensation to be received by representative
rather than on a particular client’s needs. To minimize the conflict, all commissions
received by the individual shall be donated to a benevolent charitable fund. The
representative’s insurance services are not material to GuideStream Financial’s advisory
operations. The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation from
GuideStream Financial.
If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such 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 GuideStream Financial, shall be
responsible for the quality and competency of the services provided.
Each client is advised that it remains the client’s responsibility to promptly notify
GuideStream Financial if there is ever any change in client’s financial situation or
investment objectives for the purpose of reviewing, evaluating or revising GuideStream
Financial’s previous recommendations and/or services.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation
Services. As indicated above, to the extent requested by a client, GuideStream Financial
may provide financial planning and related consulting services. Neither GuideStream
Financial nor its investment adviser representatives assist clients with the implementation
of any financial plan unless they have agreed to do so in writing. GuideStream Financial
does not monitor a client’s financial plan, and it is the client’s responsibility to revisit the
financial plan with GuideStream Financial, if desired. GuideStream Financial believes that
it is important for the client to address financial planning issues on an ongoing basis.
GuideStream Financial’s advisory fee, as set forth at Item 5 below, will remain the same
regardless of whether or not the client determines to address financial planning issues with
GuideStream Financial.
Furthermore, GuideStream Financial does not serve as a law firm or accounting firm, and
no portion of its services should be construed as legal or accounting services. Accordingly,
GuideStream Financial does not prepare estate planning documents or tax returns. To the
extent requested by a client, GuideStream Financial may recommend the services of other
professionals for certain non-investment implementation purposes (i.e., attorneys,
accountants, insurance agents, etc.), including certain representatives of GuideStream
Financial in their separate individual capacities as licensed insurance agents.
The client is under no obligation to engage the services of any such recommended
professional. The client retains absolute discretion over all such implementation decisions
and is free to accept or reject any recommendation from GuideStream Financial and/or its
representatives.
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If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such 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 GuideStream Financial, shall be
responsible for the quality and competency of the services provided.
Retirement Plan Rollovers – No Obligation / Conflict of Interest: A client or
prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in
the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s
plan, if one is available and rollovers are permitted, (iii) roll over to an Individual
Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending
upon the client’s age, result in adverse tax consequences). If GuideStream Financial
recommends that a client roll over their retirement plan assets into an account to be
managed by GuideStream Financial, such a recommendation creates a conflict of interest
if GuideStream Financial will earn new (or increase its current) compensation as a result
of the rollover. If GuideStream Financial provides a recommendation as to whether a client
should engage in a rollover or not (whether it is from an employer’s plan or an existing
IRA), GuideStream Financial is acting as a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. No client is under any obligation
to roll over retirement plan assets to an account managed by GuideStream Financial.
GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, remains available to
address any questions that a client or prospective client may have regarding the potential
for conflict of interest presented by such rollover recommendation.
Fiduciary Status: Per the Department of Labor: “When we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are
fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act
and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our
interest ahead of yours.” Accordingly, relative to retirement accounts, “we must:
investment
interests ahead of yours when making
interest, fees, and
· Meet a professional standard of care when making
recommendations (give prudent advice);
· Never put our financial
recommendations (give loyal advice);
· Avoid misleading statements about conflicts of
investments;
· Follow policies and procedures designed to ensure that we give advice that is
in your best interest;
· Charge no more than is reasonable for our services; and
· Give you basic information about conflicts of interest.”
The Free Methodist Foundation d/b/a/ FM Financial (Conflict of Interest).
GuideStream Financial is wholly owned by The Free Methodist Foundation d/b/a/ FM
Financial (“FMF”), which is a subsidiary of the Free Methodist Church USA. GuideStream
Financial and FMF share commonality of officers, directors and employees. FMF serves
in a trustee capacity. FMF is an exempt corporate trustee under state law (religious
organization). Certain clients for whom FMF may serve as Trustee may also have a
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investment advisory relationship with GuideStream Financial. Neither
separate
GuideStream Financial nor FMF maintains physical custody of any client advisory funds
or Trust funds.
In addition, GuideStream Financial’s President, Mark S. Olson, is also the President of
FMF and oversees the Free Methodist Investment and Loan Fund (the “Fund”) and Joshua
D. Adams is the Vice President of the Fund and reporting to Mr. Olson. The Fund is a
church extension fund into which members, contributors and participants of the Free
Methodist Church may invest, including clients of GuideStream Financial.
No portion of Fund principal is guaranteed by any governmental authority, including, but
not limited to, the Federal Deposit Insurance Corporation (“FDIC”).
GuideStream Financial does not exercise any discretionary authority to place any client
assets into the Fund, nor does GuideStream Financial provide any investment advisory
services to the Fund.
GuideStream Financial does not recommend that any client invest in the Fund, and does
not receive referral fees, commissions, or any form of compensation from the Fund. Clients
who request information from GuideStream Financial about the Fund will be directed to
an FMF employee who does not provide investment advice on behalf of GuideStream
Financial.
A complete discussion of the Fund is set forth in the Fund’s subscription documents, which
are provided directly by FMF to each prospective investor for review and consideration.
Each prospective investor will generally be required to complete an Investment
Application, pursuant to which the investor shall acknowledge and accept the various risk
factors that are associated with an investment in the Fund.
Based on the relationship between GuideStream Financial and FMF, an introduction to the
Fund by GuideStream Financial presents a conflict of interest, because an investment in
the Fund provides funds that may be loaned at a margin, which benefits FMF. It remains
the client’s decision whether or not to invest in the Fund. GuideStream Financial’s Chief
Compliance Officer, Joseph Crupper, remains available to address any questions that
a client or prospective client may have regarding this arrangement.
GuideStream Charitable Gift Fund d/b/a Legacy Charitable (Conflict of Interest)
GuideStream Charitable Gift Fund d/b/a Legacy Charitable (the “Gift Fund”) is a separate
501(c)(3) public charity. When a client chooses to engage GuideStream Financial for
financial planning services, a plan may include a charitable giving component. If the client
wishes to include charitable giving in their plan, the Gift Fund may be presented as a
potential option for fulfillment of the charitable component of the plan.
Although it shares a common name, GuideStream Financial does not manage the Gift Fund
or operate the Gift Fund. The Gift Fund is a tax-exempt fund into which individuals may
choose to contribute to further their charitable endeavors, including clients of GuideStream
Financial.
The Gift Fund has not been approved by any regulatory authority, nor is any portion of the
Gift Fund principal guaranteed by any regulatory authority, including but not limited to the
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FDIC. The Gift Fund is subject to an annual certified audit. GuideStream Financial does
not exercise any discretionary authority to place any client assets into the Gift Fund, nor
does GuideStream Financial provide any investment advisory services to the Gift Fund.
GuideStream Financial does not receive referral fees, commissions or any form of
compensation from the Gift Fund.
Clients who request information from GuideStream Financial about the Gift Fund will be
directed to a Gift Fund employee. It remains the client’s decision whether or not to donate
to the Gift Fund. FMF provides administrative services to the Gift Fund, and, in the past,
has been partially reimbursed by the Gift Fund for such services. The relationship between
the Gift Fund, GuideStream Financial and FMF presents conflicts of interest as Mr. Olson
also serves as the CEO of the Gift Fund and FMF will receive additional fees for the
services it provides to the Gift Fund. Clients are therefore reminded that they are under no
obligation whatsoever to contribute to the Gift Fund, and that they may contribute to any
other unaffiliated charitable fund.
A complete discussion of the Gift Fund is set forth in the Gift Fund’s program description
and related documents, which will be provided directly by the Gift Fund to each
prospective donor for review and consideration. Each prospective donor will generally be
required to complete a Donor Application Form. GuideStream Financial’s Chief
Compliance Officer, Joseph Crupper, remains available to address any questions that
a client or prospective client may have regarding this arrangement.
Use of Mutual and Exchange Traded Funds: GuideStream utilizes mutual funds and
exchange traded funds for its client portfolios. In addition to GuideStream’s investment
advisory fee described below, and transaction and/or custodial fees discussed above, clients
will also incur, relative to all mutual fund and exchange traded fund purchases, charges
imposed at the fund level (e.g., management fees and other fund expenses). The mutual
funds and exchange traded funds utilized by GuideStream are generally available directly
to the public. Thus, a client can generally obtain the funds recommended and/or utilized by
GuideStream independent of engaging GuideStream as an investment advisor. However,
if a prospective client does so, then they will not receive GuideStream's initial and ongoing
investment advisory services.
Interval Funds/Risks and Limitations: When and where appropriate, GuideStream may
determine to utilize interval funds. An interval fund is a non-traditional type of closed-end
mutual fund that periodically offers to buy back a percentage of outstanding shares
from shareholders. Investments in an interval fund involve additional risk, including lack
of liquidity and restrictions on withdrawals. During any time periods outside of the
specified repurchase offer window(s), investors will be unable to sell their shares of the
interval fund. There is no assurance that an investor will be able to tender shares when or
in the amount desired. There can also be situations where an interval fund has a limited
amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders.
In addition, the eventual sale price for the interval fund could be less than the interval fund
value on the date that the sale was requested. While an internal fund periodically offers to
repurchase a portion of its securities, there is no guarantee that investors may sell their
shares at any given time or in the desired amount. As interval funds can expose investors
to liquidity risk, investors should consider interval fund shares to be an illiquid investment.
Typically, the interval funds are not listed on any securities exchange and are not publicly
traded. Thus, there is no secondary market for the fund’s shares. Because these types of
investments involve certain additional risk, these funds will only be utilized when
consistent with a client’s investment objectives, individual situation, suitability, tolerance
for risk and liquidity needs. Investment should be avoided where an investor has a short-
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term investing horizon and/or cannot bear the loss of some, or all, of the investment. There
can be no assurance that an interval fund investment will prove profitable or successful.
In light of these enhanced risks, a client may direct GuideStream Financial, in
writing, not to employ any or all such strategies for the client’s account.
Short-Term Trading Fees. GuideStream Financial is not a short-term trader. It manages
investment assets consistent with the client’s long-term investment objective. Some of the
mutual funds utilized by GuideStream Financial impose a short-term trading fee (generally
$50 for funds held less than 30 days). If a client requires a distribution, GuideStream
Financial, whenever possible, shall first seek to liquidate funds that either do not assess a
short-term trading fee or whose short-term trading fee has expired.
(there being no guarantee
that
Cash Positions. GuideStream Financial continues to treat cash as an asset class. As such,
unless determined to the contrary by GuideStream Financial, all cash positions (money
markets, etc.) shall continue to be included as part of assets under management for purposes
of calculating GuideStream Financial’s advisory fee unless otherwise agreed to in
writing. At any specific point in time, depending upon perceived or anticipated market
conditions/events
such anticipated market
conditions/events will occur), GuideStream Financial may maintain cash positions for
defensive purposes. In addition, while assets are maintained in cash, such amounts could
miss market advances. Depending upon current yields, at any point in time, GuideStream
Financial’s advisory fee could exceed the interest paid by the client’s money market fund.
However, GuideStream Financial, in its sole discretion, may charge a lesser investment
management fee on cash positions maintained in a client’s account.
Cybersecurity Risk. The information technology systems and networks that Guidestream
Financial and its third-party service providers use to provide services to Guidestream
Financial’s clients employ various controls that are designed to prevent cybersecurity
incidents stemming from intentional or unintentional actions that could cause significant
interruptions in Guidestream Financial’s operations and/or result in the unauthorized
acquisition or use of clients’ confidential or non-public personal information. In
accordance with Regulation S-P, Guidestream Financial is committed to protecting the
privacy and security of its clients' non-public personal information by implementing
appropriate administrative, technical, and physical safeguards. Guidestream Financial has
established processes to mitigate the risks of cybersecurity incidents, including the
requirement to restrict access to such sensitive data and to monitor its systems for potential
breaches. Clients and Guidestream Financial are nonetheless subject to the risk of
cybersecurity incidents that could ultimately cause them to incur financial losses and/or
other adverse consequences. Although Guidestream Financial has established processes to
reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will
always be successful, especially considering that Guidestream Financial does not control
the cybersecurity measures and policies employed by third-party service providers, issuers
of securities, broker-dealers, qualified custodians, governmental and other regulatory
authorities, exchanges, and other financial market operators and providers. In compliance
with Regulation S-P, Guidestream Financial will notify clients in the event of a data breach
involving their non-public personal information as required by applicable state and federal
laws.
emoney. In the event that GuideStream provides the client with access to an unaffiliated
vendor’s website such as emoney, and the site provides access to information and/or
concepts, including financial planning, the client, should not, in any manner whatsoever,
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infer that such access is a substitute for services provided by GuideStream. Rather, if the
client utilizes any such content, the client does so separate and independent of
GuideStream.
Portfolio Activity. GuideStream has a fiduciary duty to provide services consistent with
the client’s best interest. GuideStream will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not
limited to, investment performance, market conditions, fund manager tenure, style drift,
account additions/withdrawals, and/or a change in the client’s investment objective. Based
upon these factors, there may be extended periods of time when GuideStream determines
that changes to a client’s portfolio are unnecessary. Clients remain subject to the fees
described in Item 5 below during periods of portfolio inactivity. Of course, as indicated
below, there can be no assurance that investment decisions made by GuideStream will be
profitable or equal any specific performance level(s).
Cash Sweep Accounts. Certain account custodians can require that cash proceeds from
account transactions or new deposits, be swept to and/or initially maintained in a
specific custodian designated sweep account. The yield on the sweep account will
generally be lower than those available for other money market accounts. When this
occurs, to help mitigate the corresponding yield dispersion, GuideStream shall (usually
within 30 days thereafter) generally (with exceptions) purchase a higher yielding money
market fund available on the custodian’s platform, unless GuideStream reasonably
anticipates that it will utilize the cash proceeds during the subsequent 30-day period to
purchase additional investments for the client’s account. Exceptions and/or modifications
can and will occur with respect to all or a portion of the cash balances for various reasons,
including, but not limited to the amount of dispersion between the sweep account and a
money market fund, an indication from the client of an imminent need for such cash, or the
client has a demonstrated history of writing checks from the account. Please Note: The
above does not apply to the cash component maintained within a GuideStream actively
managed investment strategy (the cash balances for which shall generally remain in the
custodian designated cash sweep account), an indication from the client of a need for access
to such cash, assets allocated to an unaffiliated investment manager, and cash balances
maintained for fee billing purposes. Please Also Note: The client shall remain exclusively
responsible for yield dispersion/cash balance decisions and corresponding transactions for
cash balances maintained in any GuideStream unmanaged accounts. ANY QUESTIONS:
GuideStream’s Chief Compliance Officer, Joseph Crupper, remains available to address
any questions that a client or prospective client may have regarding the above.
Other Assets. A client may:
hold securities that were purchased at the request of the client or acquired prior
to
the client’s engagement of GuideStream. Generally, with potential
exceptions, GuideStream does not/would not recommend nor follow such
securities, and absent mitigating tax consequences or client direction to the
contrary, would prefer to liquidate such securities. Please Note: If/when
liquidated, it should not be assumed that the replacement securities purchased by
GuideStream will outperform the liquidated positions. To the contrary, different
types of investments involve varying degrees of risk, and there can be no
assurance that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by GuideStream) will be profitable or equal any specific performance
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level(s). In addition, there may be other securities and/or accounts owned by the
client for which GuideStream does not maintain custodian access and/or trading
authority; and,
hold other securities and/or own accounts for which GuideStream does not
maintain custodian access and/or trading authority.
Corresponding Services/Fees: When agreed to by GuideStream, GuideStream
shall: (1) remain available to discuss these securities/accounts on an ongoing basis
at the request of the client; (2) monitor these securities/accounts on a regular
basis, including, where applicable, rebalancing with client consent; (3) shall generally
consider these securities as part of the client’s overall asset allocation; (4) report on
such securities/accounts as part of regular reports that may be provided by
GuideStream; and, (5) include the market value of all such securities for purposes of
calculating advisory fee. ANY QUESTIONS: GuideStream’s Chief Compliance
Officer, Joseph Crupper, remains available to address any questions regarding the
above.
Non-Discretionary Service Limitations. Clients that determine to engage GuideStream
Financial on a non-discretionary investment advisory basis must be willing to accept that
GuideStream Financial cannot effect any account transactions without obtaining prior
consent to such transaction(s) from the client. Therefore, in the event that GuideStream
Financial would like to make a transaction for a client’s account (including in the event of
an individual holding or general market correction), and the client is unavailable,
GuideStream Financial will be unable to effect the account transaction(s) (as it would for
its discretionary clients) without first obtaining the client’s consent.
Borrowing Against Assets/Risks. A client who has a need to borrow money could
determine to do so by using:
Margin-The account custodian or broker-dealer lends money to the client. The
custodian charges the client interest for the right to borrow money, and uses the
assets in the client’s brokerage account as collateral or
Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to make a
loan to the client, the client pledges its investment assets held at the account
custodian as collateral;
These above-described collateralized loans are generally utilized because they
typically provide more favorable interest rates than standard commercial loans. These
types of collateralized loans can assist with a pending home purchase, permit the
retirement of more expensive debt, or enable borrowing in lieu of liquidating existing
account positions and incurring capital gains taxes. However, such loans are not
without potential material risk to the client’s investment assets. The lender (i.e.,
custodian, bank, etc.) will have recourse against the client’s investment assets in the
event of loan default or if the assets fall below a certain level. For this reason,
GuideStream Financial does not recommend such borrowing unless it is for specific
short-term purposes (i.e., a bridge loan to purchase a new residence). GuideStream
Financial does not recommend such borrowing for investment purposes (i.e., to invest
borrowed funds in the market). Regardless, if the client was to determine to utilize
margin or a pledged assets loan, the following economic benefits would inure to
GuideStream Financial:
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by taking the loan rather than liquidating assets in the client’s account,
GuideStream Financial continues to earn a fee on such Account assets; and,
if the client invests any portion of the loan proceeds in an account to be managed
by GuideStream Financial, GuideStream Financial will receive an advisory fee
on the invested amount; and,
if GuideStream Financial’s advisory fee is based upon the higher margined
account value (see margin disclosure at Item 5 below), GuideStream Financial
will earn a correspondingly higher advisory fee. This could provide GuideStream
Financial with a disincentive to encourage the client to discontinue the use of
margin.
Please Note: The Client must accept the above risks and potential corresponding
consequences associated with the use of margin or a pledged assets loans.
Client Obligations. In performing its services, GuideStream Financial shall not be
required to verify any information received from the client or from the client’s other
professionals and is expressly authorized to rely thereon. Moreover, each client is advised
that it remains their responsibility to promptly notify GuideStream Financial if there is ever
any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating or revising GuideStream Financial’s previous recommendations
and/or services.
Disclosure Brochure. A copy of GuideStream Financial’s written Privacy Notice, written
Brochure as set forth on Part 2 of Form ADV and Form CRS (Client Relationship
Summary) shall be provided to each client prior to, or contemporaneously with, the
execution of an advisory agreement.
Please Note: Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific investment or
investment strategy (including the investments and/or investment strategies recommended
or undertaken by GuideStream Financial) will be profitable or equal any specific
performance level(s).
C. GuideStream Financial shall provide investment advisory services specific to the needs of
each client. Prior to providing investment advisory services, an investment advisor
representative will ascertain each client’s
investment objective(s). Thereafter,
GuideStream Financial shall allocate and/or recommend that the client allocate investment
assets consistent with the designated investment objective(s). The client may, at any time,
impose reasonable restrictions, in writing, on GuideStream Financial’s services.
D. GuideStream Financial does not participate in a wrap fee program.
E. As of December 31, 2024, GuideStream Financial had $202,560,874 in assets under
management on a discretionary basis and $14,688,878 in assets under management on a
non-discretionary basis for a total of $217,249,752.
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Item 5
Fees and Compensation
A.
INVESTMENT ADVISORY SERVICES
Effective July 1, 2023, GuideStream Financial’s annual investment advisory fee for
individuals and families shall be based upon a percentage (%) of the average daily market
value, based upon the custodial valuation, and type of assets placed under GuideStream
Financial’s management.
GuideStream Financial’s fee will be prorated and charged on a monthly basis, in arrears,
as follows:
Market Value of Portfolio
Annual Fee %
First $250,000
Next $250,000
Next $250,000
Next $250,000
Amount over $1,000,000
1.15%
1.00%
0.85%
0.70%
0.55%
Effective July 1, 2023, Institutional Clients (i.e., ERISA plans, charities, endowments, and
for-profit business entities) are subject to the following fee schedule which, is also prorated
and charged on a monthly basis, in arrears:
Market Value of Portfolio
Annual Fee %
First $2,000,000
Next $8,000,000
Amount over $10,000,000
0.70%
0.40%
0.10%
Institutional clients are generally required to have a minimum asset level of $2,000,000.
Those institutional clients that do not meet the minimum will generally (with potential
exceptions-see Fee Dispersion below) be subject to the individual and family fee schedule
reflected above unless and until the $2,000,000 level is achieved.
Please Note: Several clients that engaged GuideStream Financial prior to June 30, 2023,
have been grandfathered under a prior fee schedule.
Please Note: Institutional Clients do not receive Financial Planning services as described
in Item 4 above.
GuideStream Financial’s policy is to treat intra-month account additions and withdrawals
equally unless indicated to the contrary on GuideStream Financial’s Investment Advisory
Agreement executed by its retail and institutional clients. Since its fees are calculated on
the average daily value of the client’s account, additions and withdrawals will impact the
fee charged. Additionally, GuideStream Financial bills on cash in the client’s account as
well as the outstanding margin value. GuideStream Financial’s investment advisory fee
may be negotiable at its discretion, depending upon objective and subjective factors
including but not limited to: the amount of assets to be managed; portfolio composition;
the scope and complexity of the engagement; the anticipated number of meetings and
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servicing needs; related accounts; future earning capacity; anticipated future additional
assets; the professional(s) rendering the service(s); prior relationships with GuideStream
Financial and/or its representatives, and negotiations with the client. As a result of these
factors, similarly situated clients could pay different fees, the services to be provided by
GuideStream Financial to any particular client could be available from other advisers at
lower fees, and certain clients may have fees different than those specifically set forth
above.
Fee Dispersion. GuideStream, in its discretion, may charge a lesser or higher investment
advisory fee, charge a flat fee, waive its fee entirely, or charge fee on a different interval,
based upon certain criteria (i.e., anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account
composition, complexity of the engagement, anticipated services to be rendered,
grandfathered fee schedules, employees and family members, competition, negotiations
with client, etc.). Please Note: As result of the above, similarly situated clients could pay
different fees. In addition, similar advisory services may be available from other
investment advisers for similar or lower fees. ANY QUESTIONS: GuideStream’s Chief
Compliance Officer, Joseph Crupper, remains available to address any questions that a
client or prospective client may have regarding advisory fees. See additional disclosure
regarding fees, including fee schedule deviations and fee minimums, and at Item 7 below.
Margin Accounts: Risks/Conflict of Interest. GuideStream Financial does not
recommend the use of margin for investment purposes. A margin account is a
brokerage account that allows investors to borrow money to buy securities and/or for other
non-investment borrowing purposes. The broker/custodian charges the investor interest for
the right to borrow money and uses the securities as collateral. By using borrowed funds,
the customer is employing leverage that will magnify both account gains and losses. Should
a client determine to use margin, GuideStream Financial will include the entire market
value of the margined assets when computing its advisory fee. Accordingly, GuideStream
Financial’s fee shall be based upon a higher margined account value, resulting in
GuideStream Financial earning a correspondingly higher advisory fee. As a result, the
potential of conflict of interest arises since GuideStream Financial may have an economic
disincentive to recommend that the client terminate the use of margin. Please Note: The
use of margin can cause significant adverse financial consequences in the event of a market
correction. ANY QUESTIONS: Our Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client may have
regarding the use of margin.
FINANCIAL PLANNING AND CONSULTING SERVICES (STAND-ALONE)
GuideStream Financial may provide financial planning and/or consulting services,
including investment and non-investment related matters, on a stand-alone separate fee
basis to clients who have not engaged GuideStream Financial to provide investment
management services. GuideStream Financial’s planning and consulting fees are
negotiable but will be normally based on a rate of $175 per hour and will generally range
from $500 to $4,500, depending upon the level and scope of the services required and the
professionals rendering the service.
B. Clients may elect to have GuideStream Financial’s advisory fees deducted from their
custodial account. Both GuideStream Financial's Investment Advisory Agreement and the
custodial/clearing agreement may authorize the custodian to debit the account for the
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amount of GuideStream Financial's investment advisory fee and to directly remit that
management fee to GuideStream Financial in compliance with regulatory procedures.
Please Note: The fee deduction from the custodial account is not an option for clients who
have only engaged GuideStream Financial for stand-alone financial planning services.
Those clients shall be billed directly per the terms of the Financial Planning and Consulting
Agreement.
In the limited event that GuideStream Financial bills the client directly for investment
advisory services, payment is due upon receipt of GuideStream Financial’s invoice.
GuideStream Financial shall deduct fees and/or bill clients monthly in arrears, based upon
the average daily market value of the assets during the previous month.
C. As discussed below, unless the client directs otherwise or an individual client’s
circumstances require, GuideStream Financial shall generally recommend that Pershing,
LLC (“Pershing”) serve as the broker-dealer/custodian for client investment management
assets.
Broker-dealers such as Pershing generally charge brokerage commissions and/or
transaction fees for effecting certain types of securities transactions (i.e., including
transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed
income transactions, etc.). The types of securities for which transaction fees, commissions,
and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. While certain custodians, including Pershing, generally (with the
potential exception for large orders) do not currently charge fees on individual equity
transactions (including ETFs), others do. There can be no assurance that Pershing will not
change their transaction fee pricing in the future. Pershing may also assess fees to clients
who elect to receive trade confirmations and account statements by regular mail rather than
electronically (see below). However, GuideStream Financial has negotiated an asset-based
fee with Pershing. Effective September 1, 2025, Pershing’s asset-based fee will be 0.045%
(0.045% = four and one half one hundredths of 1%) for client accounts (which clients
acknowledge, in writing). The asset-based fee is calculated based on each client’s assets
placed under Pershing’s custody and is payable by the client to cover brokerage and
transaction fees in client accounts maintained with Pershing. Pershing debits the fee
directly from each client’s account. The 0.045% deducted by Pershing is in addition to
GuideStream Financial's advisory fee. GuideStream Financial does not receive any portion
of the fee paid to Pershing.
Please Note: Effective September 1, 2025, Pershing also charges clients $125.00 for
closing certain types of accounts. In addition, Pershing may charge other fees as warranted
by particular circumstances. Please Also Note: Effective 1/1/2024, Pershing shall assess
fees to clients (charged to the client’s Pershing account) who elect to receive trade
confirmations and account statements by regular mail rather than electronically. Pershing
requires that each client (not GuideStream behalf of the client) notify Pershing directly, in
writing, if the client would like to transition from paper (regular mail) to electronic
delivery.
ANY QUESTIONS: GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client may have
regarding the above.
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to GuideStream Financial’s investment management fee, brokerage
In addition
commissions and/or transaction fees, clients will also incur, relative to all mutual fund and
exchange traded fund purchases, charges imposed at the fund level (e.g., management fees,
transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed
income transactions, etc.). The types of securities for which transaction fees, commissions,
and/or other type fees (as well as the amount of those fees) shall differ depending upon the
broker-dealer/custodian. These fees/charges are in addition to GuideStream Financial’s
investment advisory fee described above. GuideStream Financial does not receive any
portion of these fees/charges.
D. GuideStream Financial's annual investment advisory fee shall be prorated and paid
monthly, in arrears, based upon the average daily market value of the assets during the
previous month.
The Investment Advisory Agreement between GuideStream Financial and the client will
continue in effect until terminated by either party by written notice in accordance with the
terms of the Investment Advisory Agreement. Upon termination, GuideStream Financial
shall debit the account for the pro-rated portion of the unpaid advisory fee based upon the
number of days that services were provided during the billing month.
E. Neither GuideStream Financial, nor its representatives, accepts compensation from the sale
of securities. However, if requested by the client, GuideStream Financial may recommend
the services of certain of its representatives in their separate capacities as licensed insurance
agents as an accommodation to specific client need. (Reference disclosure in Item 10.) The
commission compensation earned by its agents is separate from, and in addition to,
GuideStream Financial’s investment advisory fee. The recommendation by GuideStream
Financial that a client consider the purchase of an insurance product from an insurance
agency presents a conflict of interest, as the potential receipt of an insurance commission
compensation by the insurance agency and its agent(s) may provide an incentive for
GuideStream Financial to recommend insurance products based on compensation to be
received by representative rather than on a particular client’s needs.
ANY QUESTIONS: GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client may have
regarding advisory fees.
Item 6
Performance-Based Fees and Side-by-Side Management
GuideStream Financial, is not a party to any performance or incentive-related
compensation arrangements with its clients.
Item 7
Types of Clients
GuideStream Financial’s clients shall generally include individuals, business entities,
trusts, estates, charitable organizations and pension and profit-sharing plans.
GuideStream Financial may require an annual minimum fee of $250 or a minimum asset
level of $25,000 for investment advisory services for retail clients. GuideStream Financial
generally requires a minimum asset level of $2,000,000 for Institutional Clients as
described above. 403(b) accounts will generally not be subject to the annual minimum fee.
However, GuideStream Financial, in its sole discretion, may charge a higher or lower fee
15
or waive or reduce its minimum fee or asset requirement based upon certain criteria (i.e.,
anticipated future earning capacity, anticipated future additional assets, dollar amount of
assets to be managed, related accounts, account composition, complexity of the
engagement, anticipated services to be rendered, grandfathered fee schedules, employees
and family members, , competition, negotiations with client, etc.). As a result of the above,
similarly situated clients could pay different fees. In addition, similar advisory services
may be available from other investment advisers for similar or lower fees. ANY
QUESTIONS: GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client may have
regarding advisory fees.
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
A. GuideStream Financial may utilize the following methods of security analysis and
strategies when implementing investment advice given to clients:
Apply provisions of an Investment Policy that contains the details to define,
implement and manage a specific strategy.
Identify time horizons.
Identify risk levels.
Identify a target investment return intended to meet the investment objectives
based on historical data and present data forecasts for each particular strategy
Select asset classes appropriate for the identified time horizon, risk level and
return objective.
Select investments in ETFs, index funds or mutual funds within each asset
class appropriate for the identified time horizon, risk level and return
objective.
Investment Risk. Investing in securities involves risk of loss that clients should be
prepared to bear. Different types of investments involve varying degrees of risk, and it
should not be assumed that future performance of any specific investment or investment
strategy (including the investments and/or investment strategies recommended or
undertaken by GuideStream Financial) will be profitable or equal any specific performance
level(s).
B. GuideStream Financial’s methods of analysis and investment strategies do not present any
significant or unusual risks.
GuideStream Financial’s primary investment strategy - Long Term Purchases – is a
fundamental investment strategy. However, every investment strategy has its own inherent
risks and limitations. For example, longer term investment strategies require a longer
investment time period to allow for the strategy to potentially develop.
Every method of analysis has its own inherent risks. To perform an accurate market
analysis GuideStream Financial must have access to current/new market information.
GuideStream Financial has no control over the dissemination rate of market information.
Furthermore, an accurate market analysis can only produce a forecast of the direction of
market values. There can be no assurances that a forecasted change in market value will
materialize into actionable and/or profitable investment opportunities.
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Margin Accounts-GuideStream Financial does not recommend the use of margin.
However, should a client determine to use margin, GuideStream Financial will include the
entire market value of the margined assets when computing its advisory fee. Accordingly,
GuideStream Financial’s fee shall be based upon a higher margined account value,
resulting in GuideStream Financial earning a correspondingly higher advisory fee. As a
result, this presents a conflict of interest since GuideStream Financial has an economic
disincentive to recommend that the client terminate the use of margin.
To supplement the specific risk disclosures provided throughout this Brochure, the
following provides a short description of some of the risks associated with the types of
investments to which GuideStream Financial allocates client investment assets:
Market Risk. The price of a security may drop in reaction to tangible and intangible events
and conditions. This type of risk may be caused by external factors (such as economic or
political factors) but may also be incurred because of a security’s specific underlying
investments. Additionally, each security’s price can fluctuate based on market movement,
which may or may not be due to the security’s operations or changes in its true value. For
example, political, economic and social conditions may trigger market events which are
temporarily negative, or temporarily positive.
Mutual Fund Risk. Mutual funds are operated by investment companies that raise money
from shareholders and invests it in stocks, bonds, and/or other types of securities. Each
fund will have a manager that trades the fund’s investments in accordance with the fund’s
investment objective. Mutual funds charge a separate management fee for their services,
so the returns on mutual funds are reduced by the costs to manage the funds. While mutual
funds generally provide diversification, risks can be significantly increased if the fund is
concentrated in a particular sector of the market. Mutual funds that are sold through brokers
are called load funds, and those sold to investors directly from the fund companies are
called no-load funds. Mutual funds come in many varieties. Some invest aggressively for
capital appreciation, while others are conservative and are designed to generate income for
shareholders. In addition, the client’s overall portfolio may be affected by losses of an
underlying fund and the level of risk arising from the investment practices of an underlying
fund (such as the use of derivatives).
Exchange Traded Fund Risk. ETFs are marketable securities that are designed to track,
before fees and expenses, the performance or returns of a relevant index, commodity, bonds
or basket of assets, like an index fund. Unlike mutual funds, ETFs trade like common stock
on a stock exchange. ETFs experience price changes throughout the day as they are bought
and sold. In addition to the general risks of investing, there are specific risks to consider
with respect to an investment in ETFs, including, but not limited to: (i) the price of an ETF
may or may not fluctuate with the price of the underlying securities that make up the fund;
(ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii)
trading of an ETF’s shares may be halted if the listing exchange’s officials deem such
action appropriate, the shares are de-listed from the exchange, or the activation of market-
wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading
generally.
C. Currently, GuideStream Financial primarily allocates client investment assets among
various individual equity (stocks), debt (bonds), and fixed income securities, mutual funds
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and/or exchange traded funds and separately managed accounts on a discretionary basis in
accordance with the client’s designated investment objective(s).
Item 9
Disciplinary Information
GuideStream Financial has not been the subject of any disciplinary actions.
Item 10
Other Financial Industry Activities and Affiliations
A. Neither GuideStream Financial, nor its representatives, are registered or have an
application pending to register, as a broker-dealer or a registered representative of a broker-
dealer.
B. Neither GuideStream Financial, nor its representatives, are registered or have an
application pending to register, as a futures commission merchant, commodity pool
operator, a commodity trading advisor, or a representative of the foregoing.
C. As indicated at Item 4 above, GuideStream Financial does not serve as an attorney,
accountant, or insurance agent, and no portion of our services should be construed as same.
Accordingly, GuideStream Financial does not prepare legal documents, prepare tax
returns, or sell insurance products. To the extent requested by a client, we may recommend
the services of other professionals for non-investment implementation purpose (i.e.,
attorneys, accountants, insurance, etc.), including:
Licensed Insurance Agents. Certain representatives of GuideStream Financial, in their
separate individual capacities as licensed insurance agents, may be engaged to provide
insurance products on an accommodation basis for GuideStream Financial’s clients. If the
client engages certain representatives of GuideStream Financial’s in their separate
individual capacities as licensed insurance agents, and a dispute arises thereafter relative
to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional. At all times, the engaged professional[s], and not GuideStream
Financial shall be responsible for the quality and competency of the services provided.
Neither GuideStream Financial nor its representative hold themselves out as providing
insurance services to the general public. To minimize the conflict, all commissions
received by the individual shall be donated to a benevolent charitable fund. The
representative’s insurance services are not material to GuideStream Financial’s advisory
operations.
The recommendation by GuideStream Financial that a client purchase an insurance
commission product through a related person presents a conflict of interest, as the receipt
of commissions, though mitigated in this circumstance, may provide an incentive to
recommend investment products based on commissions, rather than on a particular client’s
need. No client is under any obligation to purchase any commission products from
GuideStream Financial’s representatives. Clients may purchase insurance commission
products recommended by GuideStream Financial through other, non-affiliated insurance
agents/agencies. GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client may have
regarding the above conflicts of interest.
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D. GuideStream Financial does not receive, directly or indirectly, compensation from
investment advisors that it recommends or selects for its clients.
Item 11
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
A. GuideStream Financial maintains an investment policy relative to personal securities
transactions. This investment policy is part of GuideStream Financial’s overall Code of
Ethics, which serves to establish a standard of business conduct for all of GuideStream
Financial’s Representatives that is based upon fundamental principles of openness,
integrity, honesty and trust, a copy of which is available upon request.
In accordance with Section 204A of the Investment Advisors Act of 1940, GuideStream
Financial also maintains and enforces written policies reasonably designed to prevent the
misuse of material non-public information by GuideStream Financial or any person
associated with GuideStream Financial.
B. Neither GuideStream Financial nor any related person of GuideStream Financial
recommends, buys, or sells for client accounts, securities in which GuideStream Financial
or any related person of GuideStream Financial has a material financial interest.
C. GuideStream Financial and/or representatives of GuideStream Financial may buy or sell
securities that are also recommended to clients. This practice may create a situation where
GuideStream Financial and/or representatives of GuideStream Financial are in a position
to materially benefit from the sale or purchase of those securities. Therefore, this situation
creates a conflict of interest.
GuideStream Financial has a personal securities transaction policy in place to monitor the
personal securities transactions and securities holdings of each of GuideStream Financial’s
“Access Persons.” GuideStream Financial’s securities transaction policy requires that an
Access Person of GuideStream Financial must provide the Chief Compliance Officer or
his/her designee with a written report of their current securities holdings within ten (10)
days after becoming an Access Person. Additionally, each Access Person must provide the
Chief Compliance Officer or his/her designee with a written report of the Access Person’s
current securities holdings at least once each twelve (12) month period thereafter on a date
GuideStream Financial selects; provided, however that at any time that GuideStream
Financial has only one Access Person, he or she shall not be required to submit any
securities report described above.
D. GuideStream Financial and/or representatives of GuideStream Financial may buy or sell
securities, at or around the same time as those securities are recommended to clients. This
practice creates a situation where GuideStream Financial and/or representatives of
GuideStream Financial are in a position to materially benefit from the sale or purchase of
those securities. Therefore, this situation creates a conflict of interest. As indicated above
in Item 11.C, GuideStream Financial has a personal securities transaction policy in place
to monitor the personal securities transaction and securities holdings of each of
GuideStream Financial’s Access Persons.
Item 12
Brokerage Practices
A. In the event that the client requests that GuideStream Financial recommend a broker-
dealer/custodian for execution and/or custodial services (exclusive of those clients that may
19
direct GuideStream Financial to use a specific broker-dealer/custodian), GuideStream
Financial generally recommends that investment management accounts be maintained at
Pershing. Prior to engaging GuideStream Financial to provide investment management
services, the client will be required to enter into a formal Investment Advisory Agreement
with GuideStream Financial setting forth the terms and conditions under which
GuideStream Financial shall manage the client's assets, and a separate custodial/clearing
agreement with each designated broker-dealer/custodian.
Factors that GuideStream Financial considers in recommending Pershing (or any other
broker-dealer/custodian to clients) include historical relationship with GuideStream
Financial, financial strength, reputation, execution capabilities, pricing, research, and
service. Although the commissions and/or transaction fees paid by GuideStream
Financial's clients shall comply with GuideStream Financial's duty to seek best execution,
a client may pay a commission that is higher than another qualified broker-dealer might
charge to effect the same transaction where GuideStream Financial determines, in good
faith, that the commission/transaction fee is reasonable. In seeking best execution, the
determinative factor is not the lowest possible cost, but whether the transaction represents
the best qualitative execution, taking into consideration the full range of a broker-dealer’s
services, including the value of research provided, execution capability, commission rates,
and responsiveness. Accordingly, although GuideStream Financial will seek competitive
rates, it may not necessarily obtain the lowest possible commission rates for client account
transactions. The brokerage commissions or transaction fees charged by the designated
broker-dealer/custodian are exclusive of, and in addition to, GuideStream Financial's
investment management fee. GuideStream Financial’s best execution responsibility is
qualified if securities that it purchases for client accounts are mutual funds that trade at net
asset value as determined at the daily market close.
1. Research and Benefits. Although not a material consideration when determining
whether to recommend that a client utilize the services of a particular broker-
dealer/custodian, GuideStream Financial receives from Pershing (or another
broker-dealer/custodian, investment platform, unaffiliated investment manager,
vendor, and/or product/fund sponsor) without cost (and/or at a discount) support
services and/or products, certain of which assist GuideStream Financial to better
monitor and service client accounts maintained at such institutions. Included
within the support services that may be obtained by GuideStream Financial may
be investment-related research, pricing information and market data, software and
other technology that provide access to client account data, compliance and/or
practice management-related publications, discounted or gratis consulting
services, discounted and/or gratis attendance at conferences, meetings, and other
educational and/or social events, marketing support, computer hardware and/or
software and/or other products used by GuideStream Financial in furtherance of
its investment advisory business operations.
GuideStream Financial’s clients do not pay more for investment transactions
effected and/or assets maintained at Pershing as the result of this arrangement.
There is no corresponding commitment made by GuideStream Financial to
Pershing or any other entity to invest any specific amount or percentage of client
assets in any specific mutual funds, securities or other investment products as a
result of the above arrangement.
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GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client
may have regarding the above arrangement and any corresponding conflict
of interest.
2. GuideStream Financial does not receive referrals from broker-dealers.
3. GuideStream Financial recommends that its clients utilize the brokerage and
custodial services provided by Pershing. GuideStream Financial does not generally
accept directed brokerage arrangements (when a client requires that account
transactions be effected through a specific broker-dealer). In such client directed
arrangements, the client will negotiate terms and arrangements for their account
with that broker-dealer, and GuideStream Financial will not seek better execution
services or prices from other broker-dealers or be able to "batch" the client's
transactions for execution through other broker-dealers with orders for other
accounts managed by GuideStream Financial. As a result, client may pay higher
commissions or other transaction costs or greater spreads, or receive less favorable
net prices, on transactions for the account than would otherwise be the case.
In the event that the client directs GuideStream Financial to effect securities
transactions for the client's accounts through a specific broker-dealer, the client
correspondingly acknowledges that such direction may cause the accounts to incur
higher commissions or transaction costs than the accounts would otherwise incur
had the client determined to effect account transactions through alternative
clearing arrangements that may be available through GuideStream Financial.
Higher transaction costs adversely impact account performance.
Transactions for directed accounts will generally be executed following the
execution of portfolio transactions for non-directed accounts.
GuideStream Financial’s Chief Compliance Officer, Joseph Crupper,
remains available to address any questions that a client or prospective client
may have regarding the above arrangements and the corresponding conflict
of interest presented by such arrangements.
B. To the extent that GuideStream Financial provides investment management services to its
clients, the transactions for each client account generally will be effected independently,
unless GuideStream Financial decides to purchase or sell the same securities for several
clients at approximately the same time. GuideStream Financial may (but is not obligated
to) combine or “bunch” such orders to seek best execution, to negotiate more favorable
commission rates or to allocate equitably among GuideStream Financial’s clients
differences in prices and commissions or other transaction costs that might have been
obtained had such orders been placed independently. Under this procedure, transactions
will be averaged as to price and will be allocated among clients in proportion to the
purchase and sale orders placed for each client account on any given day. GuideStream
Financial shall not receive any additional compensation or remuneration as a result of such
aggregation.
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Item 13
Review of Accounts
A. For those clients to whom GuideStream Financial provides investment supervisory
services, account reviews are conducted on an ongoing basis by GuideStream Financial.
All investment supervisory clients are advised that it remains their responsibility to advise
GuideStream Financial of any changes in their investment objectives and/or financial
situation. All clients (in person or via telephone) are encouraged to review financial
planning issues (to the extent applicable), investment objectives and account performance
with GuideStream Financial on an annual basis.
B. GuideStream Financial may conduct account reviews on an other than periodic basis upon
the occurrence of a triggering event, such as a change in client investment objectives
and/or financial situation, market corrections and client request.
C. Clients are provided, at least quarterly, with transaction confirmation notices and regular
written summary account statements directly from the broker-dealer/custodian and/or
program sponsor for the client accounts. GuideStream Financial may also provide a
written periodic report summarizing account activity and performance.
Item 14
Client Referrals and Other Compensation
A. As referenced in Item 12 above, GuideStream Financial without cost (and/or at a discount),
may receive support services and/or products from Pershing. GuideStream Financial’s
clients do not pay more for investment transactions effected and/or assets maintained at
Pershing (or any other institution) as result of this arrangement.
There is no corresponding commitment made by GuideStream Financial to Pershing or
any other entity to invest any specific amount or percentage of client assets in any specific
mutual funds, securities or other investment products as a result of the above arrangement.
GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, remains
available to address any questions that a client or prospective client may have
regarding the above arrangements and the corresponding conflict of interest
presented by such arrangements.
B. Neither GuideStream Financial, nor any related person, compensates any non-supervised
person for client referrals.
Item 15
Custody
Clients typically grant GuideStream Financial the authority to debit its advisory fee from
the client’s account. Clients are provided, at least quarterly, with written transaction
confirmation notices and regular written summary account statements directly from the
broker-dealer/custodian and/or program sponsor for the client accounts. GuideStream
Financial may also provide a written periodic report summarizing account activity and
performance. To the extent that GuideStream Financial provides clients with periodic
account statements or reports, the client is urged to compare any statement or report
provided by GuideStream Financial with the account statements received from the account
custodian. The account custodian does not verify the accuracy of GuideStream Financial’s
advisory fee calculation.
22
In addition, GuideStream Financial engages in certain custody-related services and/or
practices (i.e., trustee service, password possession, and asset transfer authorizations) that
are disclosed at Item 9 of Part 1 of Form ADV. These services and practices are subject to
an annual surprise CPA examination. GuideStream Financial is deemed to have custody of
client funds or securities because certain investment adviser representatives of
GuideStream Financial have agreed to client requests that they serve as trustees for the
same client trusts that GuideStream Financial manages. GuideStream Financial also views
itself as being deemed to have custody over certain client accounts if those clients are also
income beneficiaries of a charitable trust for which FMF is trustee or of a gift annuity
issued by FMF.
As described above in Item 4, GuideStream Financial’s President, Mark S. Olson, is also
the President of FMF and oversees the Free Methodist Investment and Loan Fund (the
“Fund”). GuideStream Financial does not exercise any discretionary authority to place any
client assets into the Fund, nor does GuideStream Financial provide any investment
advisory services to the Fund. GuideStream Financial does not believe that it is deemed to
have custody over the Fund’s assets or any client assets invested in the Fund, because its
advisory services are separate and distinct from the charitable endeavors of FMF and the
Fund.
However, there is significant overlap between GuideStream Financial’s management
personnel and FMFs management personnel who have access to the Fund in their separate
capacities. Therefore, even though GuideStream Financial does not view itself as being
deemed to have custody over Fund’s assets or any client assets invested in the Fund, there
are safeguards to protect clients’ investments in the Fund. In that respect, the Fund is
subject to an annual audit and investors receive the audited financial statements as part of
the annual offering circular.
to address any questions
ANY QUESTIONS: GuideStream Financial’s Chief Compliance Officer, Joseph
Crupper, remains available
that a client or
prospective client may have regarding custody-related issues.
Item 16
Investment Discretion
The client can determine to engage GuideStream Financial to provide investment advisory
services on a discretionary basis. Prior to GuideStream Financial assuming discretionary
authority over a client’s account, the client shall be required to execute an Investment
Advisory Agreement, naming GuideStream Financial as the client’s attorney and agent in
fact, granting GuideStream Financial full authority to buy, sell, or otherwise effect
investment transactions involving the assets in the client’s name found in the discretionary
account.
Clients who engage GuideStream Financial on a discretionary basis may, at any time,
impose restrictions, in writing, on GuideStream Financial’s discretionary authority (i.e.,
limit the types/amounts of particular securities purchased for their account, exclude the
ability to purchase securities with an inverse relationship to the market, limit or proscribe
GuideStream Financial’s use of margin, etc.).
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Item 17
Voting Client Securities
Unless provided otherwise in writing*, GuideStream Financial shall vote client proxies in
conjunction with the proxy voting administrative and due diligence services provided by
ProxyEdge, an unaffiliated nationally recognized proxy voting service of Broadridge
Financial Solutions, Inc. (“Broadridge”). GuideStream, in conjunction with the services
provided by Broadridge, shall monitor corporate actions of investment companies
consistent with GuideStream’s fiduciary duty to vote proxies in the best interests of its
clients. With respect to individual issuers, (to the limited extent applicable) GuideStream
may be solicited to vote on matters including corporate governance, adoption or
amendments to compensation plans (including stock options), and matters involving social
issues and corporate responsibility. With respect to investment companies (e.g., mutual
funds), GuideStream may be solicited to vote on matters including the approval of advisory
contracts, distribution plans, and mergers. GuideStream (in conjunction with the services
provided by Broadridge) shall maintain records pertaining to proxy voting as required
under the Advisers Act. Information pertaining to how GuideStream voted on any specific
proxy issue is also available upon written request. Any questions regarding GuideStream’s
proxy voting policy should be directed to Joseph Crupper, Chief Compliance Officer of
GuideStream. Please Note: No client is under any obligation to have GuideStream (in
conjunction with Broadridge) vote the client’s proxies per the above proxy voting process.
In the event that a client wants to vote his/her/its own proxies, the client can advise
GuideStream’s Chief Compliance Officer, Joseph Crupper, in writing.
*Please Note:
The client shall maintain exclusive responsibility for all legal proceedings or other
type events pertaining to the assets, including, but not limited to, class action
lawsuits; and,
GuideStream does not vote proxies for securities maintained in a courtesy
account or non-discretionary account.
Item 18
Financial Information
A. GuideStream Financial does not solicit fees of more than $1,200, per client, six months or
more in advance.
B. GuideStream Financial is unaware of any financial condition that is reasonably likely to
impair its ability to meet its contractual commitments relating to its discretionary authority
over certain client accounts.
C. GuideStream Financial has not been the subject of a bankruptcy petition.
GuideStream Financial’s Chief Compliance Officer, Joseph Crupper, remains
available to address any questions that a client or prospective client may have
regarding the above disclosures and arrangements.
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