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GUYASUTA INVESTMENT ADVISORS, INC.
285 Kappa Drive, Suite 220
Pittsburgh, PA 15238
412-447-4560
412-447-4579 (fax)
www.Guyasuta.com
This brochure provides information about the qualifications and business practices of Guyasuta
Investment Advisors, Inc. (“Guyasuta”). If you have any questions about the contents of this
brochure, please contact us at 412-447-4560, or by email at invest@guyasuta.com. The
information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission (SEC), or by any state securities authority.
Guyasuta Investment Advisors, Inc. is registered with the SEC. Registration of an Investment
Advisor does not imply any level of skill or training. The oral and written communications of an
Advisor should be considered carefully in your decision to hire or retain the Advisor to provide
advisory services.
A copy of this brochure is always available free of charge by contacting us at 412-447-4560, by
e-mail at invest@guyasuta.com or via our website at www.guyasuta.com. Additional information
about Guyasuta can be found on the SEC’s website at https://adviserinfo.sec.gov.
January 31, 2026
Material Changes
Annual Update
Guyasuta Investment Advisors, Inc.’s last annual update was September 30, 2025.
Material Changes since the Last Annual Update
Ownership Changes
As of December 31, 2025, Albert H. Madison, Partner, has retired from Guyasuta Investment
Advisors, Inc. His ownership shares were sold in January 2026 to Henry S. Beukema III, Paul J.
Magovern, Jeffrey B. Todd and Ronald L. Bartosh, Jr.
Full Brochure Availability
The firm brochure for Guyasuta Investment Advisors, Inc. is available by contacting us at 412-
447-4560, by email at invest@guyasuta.com or via our website at www.Guyasuta.com.
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Table of Contents
Material Changes ....................................................................................................................................... 2
Annual Update ........................................................................................................................................ 2
Material Changes since the Last Update............................................................................................ 2
Full Brochure Availability ....................................................................................................................... 2
Table of Contents ....................................................................................................................................... 3
Advisory Business ...................................................................................................................................... 5
Firm Description ..................................................................................................................................... 5
Principal Owners .................................................................................................................................... 5
Types of Advisory Services .................................................................................................................. 5
Tailored Relationships ........................................................................................................................... 5
Wrap Fee Programs ............................................................................................................................... 6
Client Assets ........................................................................................................................................... 6
Fees and Compensation ........................................................................................................................... 6
Description .............................................................................................................................................. 6
Fee Billing ................................................................................................................................................ 7
Other Fees .............................................................................................................................................. 9
Fees Paid in Advance ............................................................................................................................ 9
Financial Planning .................................................................................................................................. 9
Additional Compensation ...................................................................................................................... 9
Performance-Based Fees & Side-by-Side Management ................................................................... 10
Sharing of Capital Gains or Capital Appreciation ............................................................................ 10
Types of Clients ........................................................................................................................................ 10
Description ............................................................................................................................................ 10
Account Minimums ............................................................................................................................... 10
Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 11
Methods of Investment Analysis ........................................................................................................ 11
Investment Strategies .......................................................................................................................... 11
Investment Process ............................................................................................................................. 13
Risk of Loss ........................................................................................................................................... 13
Disciplinary Information ........................................................................................................................... 14
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Other Financial Industry Activities and Affiliations .............................................................................. 14
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 15
Code of Ethics....................................................................................................................................... 15
Recommend Securities with Material Financial Interest ................................................................ 15
Invest in Same Securities Recommended to Clients ...................................................................... 15
Personal Trading Policies ................................................................................................................... 16
Brokerage Practices ................................................................................................................................. 17
Selecting Brokerage Firms ................................................................................................................. 17
Research and Soft Dollars .................................................................................................................. 17
Benefits of Schwab Relationship ....................................................................................................... 18
Trading Away from Schwab ................................................................................................................ 19
Brokerage for Client Referrals ............................................................................................................ 19
Directed Brokerage .............................................................................................................................. 19
Order Aggregation ................................................................................................................................ 20
Review of Accounts ................................................................................................................................. 20
Initial Reviews ....................................................................................................................................... 20
Periodic Reviews .................................................................................................................................. 21
Account Review Triggers .................................................................................................................... 21
Regular Reports ................................................................................................................................... 21
Client Referrals and Other Compensation ........................................................................................... 22
Custody ...................................................................................................................................................... 22
Account Statements ............................................................................................................................. 22
Investment Discretion .............................................................................................................................. 23
Discretionary Authority for Trading .................................................................................................... 23
Voting Client Securities ........................................................................................................................... 23
Proxy Voting .......................................................................................................................................... 23
Financial Information ............................................................................................................................... 24
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Advisory Business
Firm Description
Guyasuta Investment Advisors, Inc. (Guyasuta) is a privately held independent registered
investment advisory firm that works with individuals, families, and institutions to assist them in
defining and meeting their investment objectives in a highly personalized, client-focused, and
service-oriented environment. We have thirteen dedicated professionals who focus their energy,
resources and considerable experience on investment research, portfolio management and
client service. We offer our services and experience to a limited number of clients, each of
whom has a long-term commitment to diligent and prudent investing. By doing so, we can have
at least two portfolio managers working directly with each client, experience closer and more
frequent client contact and, most importantly, focus our time and talents on providing superior
risk adjusted investment returns to our clients.
Guyasuta was founded in 1983 as Scheetz, Smith and Company and in 1994, through a
corporate restructuring, changed our name to Guyasuta Investment Advisors, Inc. We are 100%
owned by four full-time investment professionals active in our business.
Principal Owners
Name
Title
Joined Guyasuta
Became Owner
Henry S. Beukema III
Chairman & CEO
2005
2009
Paul J. Magovern
Partner
2007
2017
Jeffrey B. Todd
Partner
2014
2018
Ronald L. Bartosh, Jr.
Partner & CCO
1999
2009
Types of Advisory Services
We provide fee-only investment advice and financial planning servicers. Our clients are
individuals, families, trusts, pooled investment vehicles, endowment funds, retirement plans,
governments, non-profits, corporations, and foundations. Guyasuta is structured so that all of
our employees can work as collaboratively as possible. Each client relationship is confidential.
The portfolio manager is responsible for knowing and understanding the investment objectives,
risk tolerance and goals of each client. Our advisory services are designed to deliver our
collective investment expertise in a highly personalized and effective manner, tailored for the
unique needs of each client.
A detailed description of our fees (see page 6) and our investment strategies (see page 11) are
covered later in this brochure.
Tailored Relationships
Each client relationship and account structure are customized to meet the client's unique
investment objectives, risk tolerance and financial goals. The client is always free to place
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restrictions on any account(s). These restrictions are then monitored by the portfolio manager
assigned to that account.
Wrap Fee Programs
We do not participate in any wrap fee programs. Brokerage firms commonly offer a wrap fee
program to provide clients with access to various non-affiliated investment advisors. The
brokerage firm charges a comprehensive fee to the client for providing a bundle of services,
such as investment advice, investment research and brokerage services.
Client Assets
As of December 31, 2025, our assets under management were $2,437,458,000. All managed
assets are considered discretionary assets, defined as assets over which we have full authority
to make investment decisions for our clients, consistent with their objectives and our fiduciary
responsibilities.
Fees and Compensation
Description
Our investment management fee is negotiated and typically based on a percentage of the
client’s assets under our management. Fees represent our only form of compensation, so fee
negotiation represents a conflict of interest with each client. We attempt to lessen this conflict of
interest by documenting the fee in the contract executed with each client at the onset of our
relationship. This contract is commonly referred to as the Investment Management Agreement.
In addition, we also present our invoices directly to our clients with their quarterly statements.
We calculate fees on the market value of the accounts under management. We have a few
clients who pay us a fixed fee, such as a fixed dollar amount each quarter, regardless of the
value of their investments. We usually reduce or waive advisory fees for Guyasuta employees,
retirees, their family members, and related parties.
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Fee Billing
Below is the starting point of our negotiations with a new client regarding our annual fee
calculation:
Account Size
100% Equity
100% Fixed-Income
1st $2mm
1.00%
.60%
.80%
.50%
Assets from
$2mm – 4mm
.65%
.40%
Assets from
$4mm – 7mm
.50%
.30%
Assets from
$7mm – 10mm
.35%
.20%
Assets over
$10mm
(mm = million)
Most of our clients are invoiced quarterly, in advance, based on the quarter end valuation in
March, June, September, and December. We also have a few clients who prefer to have their
fees calculated in arrears, (representing the prior quarterly period) based on the quarter end
valuation.
Typically, a client with less than $2 million invested only in equity securities will be invoiced 1%
of assets under management, while an account under $2 million invested only in fixed-income
securities will be invoiced 0.60%.
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Most of our client accounts are invested in a mixed allocation of both equities and fixed-income,
with the allocation customized to meet their specific objectives. In these cases, we typically
negotiate with the client a set fee schedule (see example of 60/40 illustration below) so as to
recognize and eliminate the potential conflict of interest of potentially recommending a higher
allocation towards equities, with the perceived motive of earning higher fees. These negotiated
fees will be listed on our Investment Management Agreement and are clearly shown and
calculated on each quarterly invoice.
Account Size
Blended Asset Example
60% Equity / 40% Fixed
Effective Rate for
Blended Example
1st $2mm
.85%
$1.5mm 60/40
$1.5mm x .85% = $12,750
.70%
Assets from
$2mm – 4mm
$3mm 60/40
$2mm x .85% = 17,000
$1mm x .70% = 7,000
Total $24,000 0.80%
.55%
Assets from
$4mm – 7mm
$6mm 60/40
$2mm x .85% = 17,000
$2mm x .70% = 14,000
$2mm x .55% = 11,000
Total $42,000 0.70%
.40%
Assets from
$7mm – 10mm
.30%
Assets over
$10mm
(mm = million)
$9mm 60/40
$2mm x .85% = 17,000
$2mm x .70% = 14,000
$3mm x .55% = 16,500
$2mm x .40% = 8,000
Total $55,500 0.62%
$15mm 60/40
$2mm x .85% = 17,000
$2mm x .70% = 14,000
$3mm x .55% = 16,500
$3mm x .40% = 12,000
$5mm x .30% = 15,000
Total $74,500 0.496%
Regardless of the allocation of assets between equities and fixed-income investments, the
invoice rates will be tiered as the account assets increase. The $15mm example in the table
above uses all 5 of the breakpoints for a sample 60% equity - 40% fixed-income client:
The first $2mm would be invoiced at 0.85%,
the next $2mm would be invoiced at 0.70%,
the next $3mm would be invoiced at 0.55%,
the next $3mm would be invoiced at 0.40%,
and then any assets over $10mm would be invoiced at 0.30%.
This results in an effective rate of 0.496% for a $15mm account with a 60% equity and 40%
fixed allocation.
Again, these fees are annual rates and are negotiable.
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For the client’s convenience, most of our clients provide us with signed permission to deduct
their investment management fees directly from their accounts at their respective custodians.
Direct debit clients should note that their custodian pays us based on our invoice and the
custodian does not independently verify the fee amount to be debited. Clients are always able to
pay Guyasuta directly for their management fees. Guyasuta does not accept third party
payment services.
Other Fees
Given the nature of our advisory business of buying and selling securities for our clients, we use
outside brokers and custodians for their services. Our clients pay other fees to outside service
providers integral to the investment management process. Clients pay transaction and custodial
fees to their custodian, as well as any commissions or charges to brokers who execute
transactions on their behalf. (Please see page 17 for more information regarding Brokerage
Practices). Guyasuta has no affiliation with any third-party custodians/brokers.
Occasionally clients request exposure to certain asset classes not directly represented by our
recommended investments in equity and fixed-income securities. In these situations, we may
invest in mutual funds, exchange-traded funds, money markets, checking accounts and other
collective funds. We select these third-party investment products based upon desired asset
classes, fee profile, past performance record and a subjective review of the underlying service
provider. Clients will pay embedded management fees and other operating expenses charged
by these providers. Guyasuta is not formally affiliated with these third-party service providers or
investment advisors and receives no compensation from them. Clients also may direct us to
invest in mutual funds, exchange-traded funds, and similar investment products directly in
accounts managed by Guyasuta but without service or advice from Guyasuta on these assets.
Fees Paid in Advance
We refund advanced fees if the client terminates the relationship for any reason or if Guyasuta
terminates the relationship for any reason permitted within the terms of our Investment
Management Agreement. Any unearned fees are prorated on a daily basis and refunded within
30 days of termination.
Financial Planning
We occasionally charge for our Financial Planning services. These services are billed in 30
minute increments and invoiced at the conclusion of the Planning project if no other Investment
Management Services are engaged.
Additional Compensation
Given the close personal relationship which often develops with our clients, employees of
Guyasuta are occasionally requested to provide services such as serving as an Independent
Trustee or as an Executor of a client’s estate. In those circumstances, Guyasuta reserves the
right to request additional compensation beyond our investment management fees. These fees
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are negotiated and collected by Guyasuta and invoiced directly to the client. Revenue earned
from these practices has historically represented less than 1% of our annual revenue.
Performance-Based Fees & Side-by-
Side Management
Sharing of Capital Gains or Capital Appreciation
We do not charge performance-based fees, nor do we have any side-by-side management
accounts. Performance fees are based on a share of capital gains on, or capital
appreciation of the assets held within a client account. Side-by-side management is the
practice of an advisor managing accounts that charge a performance-based fee and also
managing accounts that charge an asset-based fee.
Types of Clients
Description
Guyasuta offers investment advisory services for individuals, families, trusts, pooled investment
vehicles, endowment funds, retirement plans, governments, non-profits, corporations, and
foundations. On occasion we also serve certain investors whose assets are below our stated $1
million minimum; these individuals typically become our clients because of their personal
relationships with Guyasuta employees, other Guyasuta clients or they have the potential to
increase account size above our minimum in the near future after becoming a client.
Account Minimums
We generally require a minimum of $1,000,000 in investable assets to begin a client
relationship, but we reserve the right to waive this minimum. When smaller accounts are
accepted, we seek sufficient diversification in line with unique client objectives to fulfill our
fiduciary duty.
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Methods of Analysis, Investment
Strategies and Risk of Loss
Methods of Investment Analysis
Our investment approach begins with “top down” analysis of the global economy where we
consider a variety of factors, including but not limited to:
• GDP growth factors and how these affect industries/sectors
• Demographic changes and emerging middle-class populations
•
Infrastructure/Technology/Healthcare requirements
From here, our process moves to “bottom up” analysis of individual companies:
• 10-K/annual report review with an emphasis on footnotes to fully analyze "hidden" risks
• Comprehensive analysis of balance sheet and cash flow statement
• Phone or face-to-face meetings with management; Guyasuta asks its own due diligence
questions
• Guyasuta often talks with competing companies to increase our understanding of the
industry and confirm/deny various investment assumptions of our target companies
Investment Strategies
Equity Investment Strategy
We believe the purpose of investing in equity securities (stocks) is to grow your capital.
Investing in equity securities involves a risk of loss and Guyasuta cannot guarantee the results
or return of any investment or advice provided.
We take an ownership perspective to investing in individual equities with an objective to grow
capital and minimize risk. Through the direct ownership of individual companies, we base every
investment decision on a thorough fundamental analysis of the underlying business and
financial statements. By thoroughly analyzing the merits of each investment individually and as
a portion of a larger portfolio, we focus on protecting our clients' assets from permanent capital
loss. Our typical holding period for an individual stock is between 3 – 5 years, but we are
constantly monitoring the price movements of each security. The Investment Committee has
discretion to fine tune the timing of security purchases and sales. (Please see the section on our
Investment Strategies below).
We maintain a consistent process designed to own a diversified portfolio of up to 40 high quality
companies with strong balance sheets that generate a significant free cash flow yield and have
sustainable revenue growth opportunities. Free cash flow is the amount of money a company
has left after paying all expenses, including capital investments for future growth. We invest
across multiple market capitalizations, seeking the most favorable risk/reward opportunities with
a focus on protecting each investment from permanent capital loss.
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Our clients are owners of the companies in which we invest on their behalf. We believe in direct
stock ownership so that our clients are as close as possible to their investments. This removes
layers of fees and provides more control.
Equity Selection Process:
• Screen for companies with sound balance sheets and substantial “free cash flow;”
companies must have well defined revenue growth plans
• Evaluate company management and define potential risks
• Select 25 - 40 holdings diversified by industry and sector, with 15 – 30% annual turnover
resulting in an average holding period of 3 – 5 years
• Sales of holdings are triggered by a fundamental deterioration in the business, declining
free cash flow yields, and/or exceeding price expectations
We do not have a defined allocation to international equities, though we own non-U.S. domiciled
companies. In certain circumstances, we will utilize a mutual fund or ETF to have exposure to
International or Emerging Markets.
We occasionally recommend equity securities characterized by high dividend yields, including
Real Estate Investment Trusts (REITs) and Master Limited Partnerships (MLPs). According to
the IRS, to qualify as a REIT, a real estate company must agree to pay-out in dividends at least
90% of its taxable income. An MLP has no tax at the corporate level as long as the entity
derives at least 90% of its income from real estate, commodities, or natural resources. These
investments are more volatile and riskier than our conservative bond strategy, which is
explained in the next section, but offer growth potential and income for equity investors. The
REITs and MLPs we recommend for clients are subject to the same rigorous analysis and due
diligence as our equity investments.
We utilize an ETF strategy for accounts where it aligns with the client’s investment guidelines.
The ETF strategy mirrors the asset allocation to the same S&P Sector weighting as the core
equity strategy but is able to gain diversification through sector based ETFs. We also offer fixed-
income ETFs to mimic the Fixed-income strategy listed below.
Fixed-Income Investment Strategy
We believe the purpose of a fixed-income portfolio is to provide a steady and dependable
stream of income, while reducing the volatility of the overall portfolio. Guyasuta uses our own
fundamental research for the purchase decision of each individual bond issue, carefully
weighing macroeconomic and issue-specific risks. When buying bonds, we consider the
underlying credit quality of the issuer, the term structure of each offering and credit spreads to
similar offerings. We consider, but do not rely upon rating agencies or insurance-backed bond
issues. We are conservative. We believe that risk and volatility are best absorbed by an
investor’s equity holdings. The portion of an investor’s total portfolio dedicated to fixed-income
should offer very few surprises.
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Key Points of Fixed-Income Strategy:
• Structure individualized portfolios to minimize both credit and interest rate risks
• Customized structure with a percentage of bonds maturing each year, generally from
year two through year fifteen, with the proceeds of maturing bonds invested in additional
bonds. This ‘laddered approach’
o Reduces the risk of changing economic conditions
o Captures a high percentage of the 30-year maximum yield with far less downside
exposure
• We buy both new issue bonds and secondary bond offerings
The taxable equivalent yields of municipal debt issues are evaluated versus taxable bonds
for non-tax-sheltered accounts.
Investment Process
Members of our Investment Committee include Henry Beukema III, Paul Magovern, Jeffrey
Todd, Henry Kincaid, Emily Weimer, Jimil Wilson, Andrew Sencindiver, and Adam Szymanski.
(See the accompanying brochure Supplement for biographical information). The Committee
meets regularly to discuss capital markets, global economic activity, individual securities,
industry sectors and asset allocation. Each of these individuals is a portfolio manager; the
investment decisions of the Investment Committee are not binding on the individual portfolio
managers as we recognize that each client has unique needs and may place restrictions on
certain investments.
We manage each client relationship through separate accounts, to meet individualized
investment goals. Most client accounts fall within the following investment strategies:
Equity: See Equity Investment Strategy on page 11
Fixed-Income: See Fixed-Income Investment Strategy on page 12
Balanced: A combination of both our Equity and Fixed-Income Investment Strategies
Risk of Loss
Our clients face the risk of loss when investing in any type of securities, whether an equity or
fixed-income vehicle. Your principal investment and expected income stream and/or growth of
that investment has the potential to be lost. There are no guarantees when investing; past
performance may not be indicative of future results and does not guarantee gain or loss in the
future.
As with any investment program, specific risks to your account may include:
Market Fluctuation - financial markets and the value of investments change substantially
over time, which may lead to loss of portfolio value, especially in a short-term time horizon.
Equity Investments - equities are exposed to general stock market swings and unpredictable
changes in value, as market confidence and opinions of their issuers change.
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Fixed-Income Investments – prices of fixed-income (bond) securities typically fall when
interest rates rise. This risk is usually greater for longer-maturity bond securities.
Investments in bonds with lower credit ratings (and non-rated credits) are subject to a
greater risk of loss to principal and interest than those with higher credit ratings.
Income Risk - risk that an investment strategy designed to produce income falls short,
resulting in the failure to meet cash flow demands or the need to sell assets to produce
these demands.
Liquidity Risk - risk that you may not have full access to your funds if your account assets
cannot be converted into cash according to normal market settlement standards.
Smaller Company Investments - investments in smaller companies involve added risks such
as limited liquidity and greater volatility, which may hinder our ability to sell these
investments in a timely manner at a fair and competitive price.
Disciplinary Information
As an SEC-registered investment advisor, we are required to disclose all material facts about
any legal or disciplinary events that would be material to your evaluation of Guyasuta or the
integrity of our management team. Guyasuta has no disciplinary information to report.
Other Financial Industry Activities and
Affiliations
We have no broker-dealer or registered representative affiliations.
We are not affiliated with any type of futures or commodity advisers or associated persons.
We have no material relationships or arrangements with any other participant in the financial
industry.
Guyasuta does not recommend or select other investment advisers for compensation. As
described above, we may on occasion utilize no-load mutual funds or exchange traded funds as
requested by certain clients or for smaller accounts that are unable to diversify properly with our
equity or fixed-income investment methods. In addition to the embedded advisory and service-
related fees, these accounts will pay commissions for these trades to their custodians, but
Guyasuta receives no compensation, and we have no affiliation with any of the companies that
manage or distribute these fund products.
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Code of Ethics, Participation or Interest
in Client Transactions and Personal
Trading
Code of Ethics
Guyasuta has adopted a Code of Ethics (“Code”) which requires our principals and employees
(“Access Persons”) to adhere to the highest ethical standards and always place the interests of
our clients ahead of their own personal interests. The Code describes our fiduciary duty to
clients and is designed to ensure that we treat all clients fairly and equitably. The Code includes
specific compliance policies and procedures designed to identify and ban certain types of
personal securities transactions thought to create a conflict of interest. The Code is also an aid
to the company in preventing, detecting, and imposing sanctions for “insider trading” or the use
of material, non-public information. All of our principals and employees must certify each year
their understanding of and compliance with all provisions of the Code and related policies and
procedures.
A copy of our Code of Ethics is available at no charge to any client or prospective client upon
request by calling 412-447-4560 or by e-mail at invest@guyasuta.com.
Recommend Securities with Material Financial Interest
Guyasuta does not recommend to clients, or buy or sell for client accounts, securities in which
any principal or employee has a material interest.
Invest in Same Securities Recommended to Clients
Guyasuta has adopted Personal Trading Policies and Procedures (“Personal Trading Policy”) to
avoid either actual or potential conflicts of interests. The Personal Trading Policy prohibits
certain types of personal securities transactions for all Access Persons and requires pre-
approval of others thought to create a potential conflict of interest. Access Persons must
conduct all personal security transactions in accordance with the Code and Personal Trading
Policy. An Access Person is an employee involved in policy-making (e.g., member of
management or investment committee), or ongoing investment and administrative decision-
making for client accounts. Because of our team approach to our clients, Guyasuta considers all
of our employees’ access persons.
The Code permits officers, employees, and the firm to personally invest in the same securities
that are bought and sold for clients. We may also own securities of issuers subsequently
purchased for clients. Under the heading of Personal Trading Policies, we describe our process
for creating a fair and equitable distribution of trades when we combine personal trades with
client trades. We may also buy or sell a specific security for our own accounts, based on
personal investment considerations, which we do not deem appropriate to buy or sell for clients.
Access Persons may also be involved in other business ventures and investment opportunities
15
which are not offered or available to Guyasuta clients. In such situations, Access Persons may
encounter conflicts of interest between their personal investment activity and their fiduciary duty
to Guyasuta clients. We follow strict policies to remove or limit these conflicts of interest. If not
fully resolved or avoided, conflicts of interest are disclosed as soon as prudently possible.
Personal Trading Policies
As mentioned above, when we combine personal trades with client trades there could be a
conflict of interest in the manner in which we allocate the executed prices for each buy and sell
transaction. To eliminate the possible conflict, we have developed the following policy to create
a fair and equitable price distribution for each transaction. When possible, we combine (“block”)
all of our clients, our firm’s profit-sharing plan accounts, company accounts and our employees'
personal trades together and utilize the services of a third-party trader/brokerage firm to execute
the transaction at the best price for the entire block of shares. Sometimes these trades take a
day or more to complete; at the end of each trading session, we instruct the trader to combine
the results of all transactions for the day, compute and then report the average price for each
security traded. When a trade takes more than one trading session to complete; we maintain a
listing of all the affected client accounts, sorted by account number, and follow a consistent
process to fairly allocate securities. In these cases, all employee, employee related accounts,
the firm’s profit-sharing accounts and company accounts will always be filled last after all client
accounts have received their full allocation.
For example, a list of all accounts to be traded is created and sorted by account number starting
with account number 1000-0000. When the first trade that is not fully executed occurs, we will
begin allocating shares to the accounts starting at 1000-0000 until all shares acquired or sold
are allocated to the appropriate accounts. When the next lot of shares is bought or sold, the
next account in the list will receive the shares until the order has been completely filled. If this
allocation process causes an account to receive a partial fill of their allocation, for example 400
of 500 shares total, we have discretion to place the allocation in the next account that matches
the number of shares remaining or partially fill that account’s position. Given the nature of the
financial markets, despite our best efforts, some clients may be disadvantaged by this process
and the accounts of our Access Persons may on occasion receive better prices on certain
transactions.
To keep the process orderly and fair, when the next partially filled block trade is executed the
first accounts to receive shares will start with 2000-0000, and then the next will start with 3000-
0000 and so on until account number 9000-0000 is the starting group for a partial execution.
Once all the accounts have had a partial fill start with their grouping of accounts, we will start
back at 1000-0000.
We use this block trading process for all accounts custodied with Charles Schwab & Company,
Inc. and accounts that have Delivery vs. Payment (DVP) trading accounts with Schwab. (DVP
accounts allow us to trade with Schwab but have the securities delivered to or from the specific
broker/dealer that holds custody of that client’s assets). This allows us to batch nearly all of our
accounts into one trading group. Any account held with a custodian that cannot be traded with a
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DVP account at Schwab (a client directed trading/custodian account), must have their trades
phoned into their respective trading desks. These accounts will be executed in the allocation as
if their account numbers were before 1000-0000. (For example, if a block trade starts with 9000-
0000, once account number 9999-9999 is allocated the portfolio managers of the non-DVP
accounts will call in their trades to their respective trading desks. Once execution is completed
for these accounts the block trade will continue with account number 1000-0000).
Our employees are permitted to hold personal investment accounts that are not formally
supervised by the firm. All statements for these accounts are received by the firm. Employee
trading is continually monitored by the Chief Compliance Officer under the Code of Ethics to
reasonably prevent conflicts of interest between Guyasuta and our clients.
Brokerage Practices
Selecting Brokerage Firms
Guyasuta is independently owned and operated and is not affiliated with any broker or
custodian. Except under a directed brokerage arrangement, Guyasuta generally has discretion
over the selection of the broker to be used and the commission rates to be paid when executing
client trades. In selecting a broker, we may consider a number of factors, including, for example,
net price, reputation, financial strength and stability, efficiency of execution and error resolution,
block trading and block position capabilities, offering us on-line access to computerized data
regarding clients’ accounts, and other matters involved in the receipt of brokerage services.
Research and Soft Dollars
We may also purchase from a broker or allow a broker to pay for certain research services such
as those terms that are defined in Section 28(e) of the Securities Exchange Act of 1934 which
are deemed “Research” including, economic and market information, industry and company
comments, technical data, recommendations, general reports, on-line pricing, quotation services
and industry conference fees (a “soft-dollar” relationship). We may or may not pay a higher
brokerage commission than another broker-dealer might charge for effecting the same
transaction to cover soft-dollar services. In such a case, however, Guyasuta determines in good
faith that such commission is reasonable in relation to the value of brokerage, research, other
services and soft-dollar relationships provided by such broker/dealers, viewed in terms of either
the specific transaction or Guyasuta’s overall responsibilities to the discretionary portfolios.
Some, but not all soft dollar research services benefit the accounts which pay the commission to
the broker providing such services. Use of soft dollar commissions represents a conflict of
interest. Without soft dollars, we would pay for certain research and brokerage services out of
pocket with fee revenues rather than with client commissions. We have adopted strict
compliance policies to ensure that our soft dollar practices are consistent with our duty to
achieve best execution and that soft dollar services represent fair and measurable value for our
clients. This includes thorough pre-approval and reconciliation of soft dollar expenses by
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investment and compliance professionals. We believe that soft dollar services improve the
overall quality of our investment advisory services.
Benefits of Schwab Relationship
Since 1989, Guyasuta has had a professional relationship with Schwab Advisor Services
(Schwab), a division of The Charles Schwab & Co. Inc. For many years we have had an annual
soft dollar agreement with Schwab. Schwab has canceled this agreement as of December 31,
2019.
As mentioned previously, we have the ability to work with any custodian or broker, but Schwab
is the provider of choice for most of our clients’ business. Schwab is one of the largest providers
of brokerage services to the independent advisor industry, providing web-based operational and
technological support and client reporting. While there is no direct linkage between the
investment advice given and participation in the Schwab program, economic benefits are
received for our entire client base which would not be received if Guyasuta did not utilize
Schwab's services. These benefits include, but are not limited to, the following:
• Receipt of duplicate client confirmations in either paper or electronic form and bundled
duplicate statements
• Access to a trading desk serving investment advisor participants exclusively
• Access to block trading which provides the ability to aggregate securities transactions
and then allocate the appropriate shares to clients’ accounts at the same average price
for all accounts (see Personal Trading Policies on page 15)
• The ability to trade outside custodial accounts through Schwab with a DVP (Deliver vs.
Payment) account, which allows for average pricing on accounts outside of Schwab
• Ability to have investment advisory fees deducted directly from client accounts
• Access to an electronic communication network for client order entry and account
information
• Receipt of compliance publications
• Access to mutual funds which generally require significantly higher initial investment
minimums and typically have lower expense ratios or are available only to institutional
investors
• Access to Schwab’s industry conferences and locally sponsored investment, technology,
•
and compliance events
In January 2022, we participated in Schwab’s Client Benefit Program. This program
made available $7,500 for Guyasuta to utilize towards technology, research, marketing,
or compliance consulting related expenses. This program was used to offset costs of our
Tamarac Advisor View system, which benefits all Guyasuta clients, regardless of the
client’s respective custodian.
In 2002, 2003, 2005, 2009, 2010, 2011, 2012, 2016, 2019 and 2025 Schwab paid conference
dues (value to Guyasuta of over $1,000 annually) for one Guyasuta employee to attend
IMPACT, their annual investment industry conference. In 2004 and 2006 Schwab paid the dues
for two employees to attend the annual conference. We believe that our access to these
benefits does not depend upon transaction volumes directed to Schwab or the value of client
assets under management custodied with Schwab.
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Trading Away from Schwab
Although Schwab is our provider of choice for custodial and brokerage services, we may
execute transactions for our clients with other brokers based on our analysis of receiving a
better qualitative execution. In these cases, the option to execute a transaction at a brokerage
firm which is not also the client’s custodian is known as ‘trading away.’ The decision to trade
away is subjective which considers not only the net security price, trading costs, commissions,
the outside broker’s reputation, access to security market flows and ability to block and settle
trades, but also a judgment on the quality of the investment research provided by the broker. In
these situations, when a client’s assets are held at Schwab and we execute the trade through a
different broker, the client pays a trade away fee to Schwab in addition to the negotiated
commission to the executing broker. In these cases, we believe the additional cost is
reasonable given our analysis of best qualitative execution. Clients may restrict us from trading
away; by not signing the Prime Broker authorization, however, their executions generally will not
be aggregated and will most likely receive different prices from the average price we receive for
most clients.
We highly recommend that clients allow us to trade away from Schwab for fixed-income trades
as we have developed many long-standing relationships with the fixed-income trading desks at
firms which greatly benefit our clients. The fixed-income markets are not as efficient as the
equity markets and often we can negotiate more favorable prices with access to more
appropriate bond issues at these other firms.
Brokerage for Client Referrals
We have never received any brokerage credit for client referrals.
From April 1, 2002, through December 31, 2006, we did participate in a project known as the
Schwab Advisor Network (Network). During this time period our participation in the Network
program entitled us to receive client referrals from Schwab Advisor Services in exchange for a
referral fee of 15% of our standard client advisory fee, paid quarterly to Schwab. During our
participation in the Network, we received fewer than 10 client accounts. Our agreement with the
Network was jointly terminated on December 31, 2006. As a result, we will no longer have to
pay Schwab for any referrals from the retail branch offices. However, for those clients who were
referred under the Network arrangement, we will continue to pay a referral fee of 15% quarterly
to Schwab. These clients’ fees were not raised to make up for this referral fee. The 15% is
deducted from the overall Guyasuta investment management fee before Guyasuta’s fee is paid
from the client’s accounts at Schwab. In 2019, these referral fees were eliminated by a one-time
buy-out of the referral program. Schwab no longer collects these referral fees from our clients.
Directed Brokerage
Certain clients may tell us to trade all or a portion of their portfolio transactions with a
designated broker-dealer. This practice is known as ‘directed brokerage.’ We accept client
directed brokerage as long as it does not materially undermine our ability to provide best
qualitative execution for these clients. We make no attempt to negotiate commissions for clients
who direct brokerage. As a result, clients who direct brokerage may pay higher commissions
than clients who do not direct brokerage. Commission rates will depend on each client’s
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commission arrangement with the referring broker-dealer as well as other factors such as the
number of shares, round and odd lots, and the market for the security.
Directed brokerage may result in less favorable stock prices, especially for illiquid securities and
during volatile market conditions compared to other clients who do not direct brokerage. When
the client directs brokerage, the client represents that he has negotiated and is satisfied with the
terms and conditions (including commission rates) of all brokerage services. We are not
responsible to obtain the best prices or any particular commission rates for transactions with or
through any such broker for the client’s account.
When we are instructed to direct brokerage away from the broker executing the bulk of our
trading activity that client may not receive the same price of execution and may pay a higher
commission rate for those transactions. For example, if we block a purchase for 100,000 shares
of XYZ stock at “Broker A” we may get an average price of $10.00 per share and pay a
commission of only $0.02 per share due to the large size of the trade (executing broker
receives $2,000). However, the directed trade will most likely be a smaller trade which can
affect the execution price received (for instance $10.03) and be subject to a higher commission
rate such as $0.07 per share. Although it is possible that the directed account will benefit on
price and commission charges from time to time, clients should regularly review the information
they receive from their brokers.
Order Aggregation
Please see the section labeled Code of Ethics, sub-section Personal Trading Policies on page
14 for our order aggregation policy.
Review of Accounts
Initial Reviews
Before initiating a formal relationship with a prospect, we review several pertinent issues to
make certain that our investment philosophy and style is appropriate given the prospect's
objectives. These issues usually include reviewing risk tolerance, age, lifestyle, income
statement, balance sheet, estate plans and tax sensitivity. The answers to these questions
assist both the prospective client and the portfolio manager in formulating our investment plan.
We also review certain documents in accordance with the USA PATRIOT Act Section 326
Customer Identification Program (CIP). This information helps the government fight the funding
of terrorism and money laundering activities. Federal law requires all financial institutions to
obtain, verify, and record information that identifies each person who opens an account.
What this means for you: When you open an account, we will ask for your name, address, date
of birth, and other information that will allow us to identify you. We may also ask to see your
driver's license or other identifying documents. These identifying documents will then be
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checked against government listings such as the OFAC (The Office of Foreign Asset Control)
List. These procedures are for your protection.
Periodic Reviews
Mr. Beukema, Mr. Magovern, Mr. Todd, Mr. Kincaid, Mrs. Weimer, Mr. Wilson, and Mr.
Sencindiver are the portfolio managers. As a group and individually we monitor and review our
client accounts on a regular basis. We use Envestnet’s Tamarac Reporting system to update
and reconcile our clients' holdings on a daily basis for all accounts. We currently receive this
electronic feed of data from Schwab Advisor Services, BNY Mellon, PNC Financial, Wells
Fargo/FCC, AmeriServ Trust Company, Fidelity Trust Company, Vanguard and Smithfield Trust
Company. This system allows us to electronically download transactions, prices, cost basis, and
reconciliation files daily. Accounts that are not available in this system are reconciled manually
to the custodial statements on a quarterly basis.
Account Review Triggers
Client accounts are reviewed regularly by the portfolio managers assigned to the account and
by our portfolio administrators for any irregularities. For instance, each day once all information
is reconciled, the cash balance audit report is processed to make sure no account has become
overdrawn (i.e., moved into a negative cash balance). The accounts are also monitored for
compliance within their respective asset allocation targets. Given our relatively small ratio of
clients to portfolio managers we enjoy close relationships with clients and their respective
investment objectives. We do not require our clients or portfolio managers to sign specific
Investment Policy Statements (“IPS”), but we do keep a suitability profile for each client. When a
portfolio moves outside of its targeted asset mix range, the portfolio manager is responsible for
deciding when to rebalance the account. Many factors can move an account out of balance with
its target allocation, including financial market movements, new monies deposited to the
accounts, withdrawals from the portfolio, or even new securities added to the accounts. When
these types of transactions occur, our portfolio managers take appropriate action.
In general, our institutional (non-profit, corporate and government) accounts do require us to
manage their portfolios to a more formalized IPS. In those cases, as well as instances when our
individual clients request strict adherence to a specific asset allocation, the portfolio managers
must rebalance to comply with the written IPS.
Regular Reports
Each client receives a regular quarterly report at the end of each calendar quarter (March 31,
June 30, September 30, and December 31). We produce these customized reports internally
and typically include detailed portfolio appraisals, purchases, and sales, realized gains and
losses, contributions and withdrawals, and performance information for the individual or group of
client accounts as well as a timely market commentary. These reports are available in mailed
paper form or via our secure portal via our website at www.Guyasuta.com. Clients may request
monthly statements. These reports are separate from the monthly or quarterly statements our
clients receive from their qualified custodians.
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Client Referrals and Other
Compensation
We do not currently use outside parties or solicitors for client referrals.
Custody
Account Statements
The assets of each client account are held by a qualified custodian, generally a bank, trust
company, or broker-dealer. As detailed in the above section on Brokerage Practices, on page
16, clients select the custodian to maintain their assets. These custodians send to each of their
clients, confirmations of all trading activity, at least quarterly account statements, as well as
information updates for their accounts. Most custodians offer this information in paper format or
electronically. Clients are urged to compare custodial reports to Guyasuta reports for accuracy,
even though we reconcile these accounts regularly to assure accurate reporting. Custody
occurs when an adviser or related person directly or indirectly holds client funds or securities or
has the ability to obtain possession of them. Guyasuta does claim “custody” according to the
SEC because several of our employees serve as Trustee for client trust accounts. These clients
have asked Guyasuta to serve as Trustee because of our long-standing relationships and trust
that has been placed in our employees.
Because of this claim of “custody” we are subject to an annual surprise audit by a public
accounting firm according to SEC rules. This audit is conducted by Urish Popeck each year.
The last audit covered the period from May 1, 2024, through September 30, 2025. A copy of our
audit report is available by calling us at 412-447-4560 or by email at invest@guyasuta.com.
Although we claim “custody” we do not actually hold any cash or securities for any client
account(s).
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Investment Discretion
Discretionary Authority for Trading
We have complete discretion over the selection and amount of securities to be bought and sold
without obtaining specific client consent according to our signed Investment Management
Agreements with each client. Because we serve many clients, there may be conflicts of interest
over our time devoted to managing any one account and the allocation of investment
opportunities among all accounts managed by Guyasuta. We attempt to resolve all such
conflicts in a manner that is generally fair and equitable to all clients. We may give advice and
act with respect to any of our clients and individual accounts that may differ from advice given or
the timing or nature of action taken for another client. In so doing, it is Guyasuta’s policy, where
practicable, to allocate investment opportunities over time on a fair and equitable basis relative
to other clients. We are not obligated to buy or sell the same security for all accounts. We may
buy or sell securities for our own account or employee accounts that we believe are not well
suited for client accounts. In all these cases, we follow compliance policies to ensure that client
interests come before the interests of the firm and our employees.
The only limit to our discretionary trading authority occurs under directed brokerage
arrangements, as outlined above. We will then execute their transactions in the most prudent
fashion. Some clients place restrictions on our asset allocation policy and security selection for
their accounts which may require pre-approval to buy or sell certain securities. Portfolio
managers handle client pre-approvals.
Voting Client Securities
Proxy Voting
We have adopted a Proxy Voting Policy to handle all client Proxy Voting for discretionary
accounts. We utilize a proxy voting service, ProxyEdge from Broadridge, to facilitate voting
client proxies. This service allows us to consolidate account voting across all of our custodians.
Upon written request, any client may review this Policy or any of the details of a proxy vote, as
long as the client's account was involved in the vote.
Any Non-ERISA account has the option to vote the proxies for the client's account on their own,
but, in general, Guyasuta votes all proxies. If a client reserves the right to vote proxies, we
require instructions in writing.
As a matter of policy, we maintain detailed records of all client proxy votes. Please contact us
for a copy of our proxy voting policies and a history of how proxies have been voted for your
account.
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Financial Information
As an SEC-registered investment advisor, we must disclose information about our financial
condition. Guyasuta has no financial obligation that impairs the firm’s capacity to meet
contractual and fiduciary commitments to our clients, nor has the firm been the subject of a
bankruptcy proceeding. Guyasuta has no short or long-term debt.
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