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24 Greenway Plaza, Suite 1507
Houston, TX 77046
Loyd Stegent: 713-840-9300
Loyd@StegentEquity.com
www.StegentEquity.com
February 2026
This brochure provides information about the qualifications and business practices of
Stegent Equity Advisors, Inc. If you have any questions about the contents of this
brochure, please contact us at 713-840-9300 x104 and/or Loyd@StegentEquity.com.
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any state securities authority.
Additional information about Stegent Equity Advisors, Inc. also is available on the SEC’s
website at www.adviserinfo.sec.gov. Registration does not imply a certain level of skill
or training.
Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
Material Changes
The last annual update of this brochure was in March 2025. No material changes have
occurred since that update.
Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
Table of Contents
Advisory Business ............................................................................................................. 1
Fees and Compensation ................................................................................................... 2
Performance-Based Fees and Side-By-Side Management .............................................. 3
Types of Clients ................................................................................................................ 3
Methods of Analysis, Investment Strategies and Risk of Loss .......................................... 4
Disciplinary Information ..................................................................................................... 4
Other Financial Industry Activities and Affiliations ............................................................ 4
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..... 5
Brokerage Practices .......................................................................................................... 6
Review of Accounts ........................................................................................................... 7
Client Referrals and Other Compensation ........................................................................ 7
Custody ............................................................................................................................. 7
Investment Discretion ........................................................................................................ 8
Voting Client Securities ..................................................................................................... 8
Financial Information ......................................................................................................... 8
Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
ADVISORY BUSINESS
Advisory Firm Description
Stegent Equity Advisors, Inc. (“SEA” or the “Firm”), a registered investment advisor, has
been in business since October 1995. Registration does not require or imply a certain
level of skill or training. The principal owner is Loyd J. Stegent, CPA/PFS, CFP®.
Types of Advisory Services
Personal financial planning and investment management services are provided to SEA
clients. Each of these services is described in more detail below.
SEA is responsible for the investment services provided by Stegent Financial Services,
PC personnel. SEA supervises personnel of Stegent Financial Services, PC, a related
public accounting firm, as they complete financial plans for SEA clients.
Personal Financial Planning and Investment Management Services
Personal financial planning services are provided to a variety of distinct market
segments:
• High net worth individuals
• Closely held business owners
• Charitable institutions and private foundations
In general, the personal financial planning services include:
• Assistance in defining and quantifying an individual’s financial planning goals and
priorities
• The evaluation of an individual’s needs with respect to:
Income tax
o
o Cash flow and retirement planning
o Education funding alternatives
o Risk management
o Compensation planning
To this end, financial plans and analyses are prepared, as well as personal financial
statements reflecting net worth, cash flow and income tax projections.
SEA will also provide investment management (consulting and advising) services in
conjunction with the personal financial planning services described above. These
services include the following:
• Analyzing current portfolio, investment strategy and risk tolerance.
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
• Educating clients about investment principles and how to relate an investment
plan to specific financial goals.
• Assisting in the drafting of an investment plan which would be reviewed and
approved by the client.
• Developing asset allocation models to assist in the selection of asset classes that
are consistent with the client’s stated objectives, personal risk tolerance and
overall financial goals.
• Assisting the client in the selection of securities, mutual funds and/or money
managers that are compatible with the client’s objectives, risk tolerance and
financial goals. This assistance will be based upon published performance data
and analyses by SEA.
• Placing trades in the client’s account enacting the investment plan as outlined.
• Monitoring investment results and performance of a client’s portfolio and/or
money manager.
SEA will either implement the strategy utilizing the services of an unaffiliated investment
manager or through its internal investment management.
SEA also publishes and distributes to clients and others a newsletter containing items on
general financial planning topics, income tax strategies, and investment awareness and
education.
Tailored Advisory Services
Clients can restrict SEA from purchasing or selling particular securities. Each client can
change these restrictions at any time by notifying SEA staff.
Client Assets Under Management
As of December 31, 2025, the Firm had approximately $242,500,000 of discretionary
assets under management and approximately $1,250,000 of non-discretionary assets
under management.
FEES AND COMPENSATION
SEA’s fees are negotiable depending upon the services rendered and will be based
upon a percentage of the total value of the client’s portfolio.
Fees based upon a percentage of the client’s portfolio will generally range from 0.50% to
1.0% of assets under supervision per year, depending on the nature of the services
provided and the portfolio size. Investment management fees are paid in advance on a
quarterly basis, at the beginning of each calendar quarter, and can be deducted from
client accounts. (Please see the section titled “Custody” for more details.) The annual
fee is divided by four before being applied as a percentage of the closing market value of
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
all assets in all accounts under management as of the last trading day of each calendar
quarter. Fees for the initial quarter are prorated to the end of the quarter and are due
upon execution of the advisory agreement. If a client terminates the relationship with
SEA mid-quarter, any unearned fees will be returned to the client.
Other Charges
When SEA recommends a mutual fund, including closed end funds, for a client’s
account, three separate fees may be charged to the client, either directly or indirectly.
The first fee is SEA’s investment management fee where the fund is included in the
asset base for the quarterly fee calculation. The second is the set of internal fees
charged by the investment company for the fund’s investment management, marketing,
administration and marketing assistance. These internal expenses are disclosed in each
fund’s prospectus which is provided to each client by the custodian. (This set of fees
also applies to any money market fund purchased in the client’s account.) The third fee
may be a transaction fee which is assessed by the custodian for its service of providing
access to a universe of mutual fund families through one account. To avoid such fees a
client would be required to open a separate account with each individual mutual fund
company instead of using the custodian recommended by SEA, which would also
negatively affect SEA’s ability to deliver its services efficiently. Not all mutual fund
trades enacted by SEA incur this transaction fee. No fund utilized by SEA pays
remuneration back to SEA. SEA may invest in certain mutual funds, including money
market funds, charging fees for distribution known as Rule 12b-1 fees if in SEA’s
judgment such investments are appropriate. Rule 12b-1 fees, like all other mutual fund
fees expenses, are deducted from the net asset value of the mutual fund and are an
expense to the client. Certain mutual funds pay a portion of their Rule 12b-1 fees to the
custodian or an affiliate of the custodian. For trades under $2,500, SEA will use a share
class with 12b-1 fees, if available, to avoid custodian transaction fees if that is in the
client’s best interest.
Some managed accounts, such as employer 401(k) plans are not custodied with
Schwab; therefore, they generally do not have access to lower cost share classes. SEA
does not share in any mutual fund charges, including 12b-1 fees or transaction fees
charged by the custodian, but may indirectly benefit from the services provided by the
custodian.
PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
This section does not apply to SEA.
TYPES OF CLIENTS
SEA provides investment advisory services to:
Individuals
•
• High net worth individuals
• Pension and profit sharing plans
• Trusts, estates or charitable organizations
• Corporations and other businesses
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
SEA has a minimum account size of $250,000 and a minimum fee of $625 per quarter
without proration. These minimums are waived under certain circumstances. For
example, clients have the ability to household accounts with their descendants to meet
account minimums.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
SEA considers investments for client accounts in light of fundamental and technical
analysis. Fundamental analysis entails using current data to evaluate an investment’s
current and expected price. Technical analysis reviews past performance of an
investment’s market price.
Trading for SEA client accounts is limited to general securities, ETFs, mutual funds and
government securities, unless otherwise agreed to in writing by the client.
SEA maintains a buy and hold strategy, buying for the long-term rather than attempting
to catch short-term market moves. SEA has developed several distinct investment
strategies for its clients, rebalancing to “models” on at least an annual basis, but maybe
as often as monthly, depending upon the size and objective of each account. These
strategies range from very conservative to aggressive and are used in rebalancing as
guidelines, depending upon a client’s investment objective, age and risk tolerance.
SEA does not guarantee the future performance of the account or any specific level of
performance, the success of any investment decision or strategy that the Firm uses, or
the success of the Firm’s overall management of the account. The client understands
that investment decisions made for the client’s account by the Firm are subject to
various market, currency, economic, political and business risks, and that those
investment decisions will not always be profitable. The client understands that investing
in any security entails risk of loss.
DISCIPLINARY INFORMATION
There have been no disciplinary actions against SEA or Mr. Stegent.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Mr. Stegent, President of SEA, is also President of Stegent Financial Services, PC
(“SFS, PC”), a public accounting firm. Some of the clients of SFS, PC, become
investment advisory clients, and vice versa. SEA and SFS, PC, share common office
space.
Mr. Stegent spends approximately 25% of his time as a practicing CPA.
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
Code of Ethics
SEA has adopted a Code of Ethics which describes the general standards of conduct
that the Firm expects of all Firm personnel (collectively referred to as “employees”) and
focuses on three specific areas where employee conduct has the potential to adversely
affect the client:
• Misuse of nonpublic information
• Personal securities trading
• Outside business activities
Failure to uphold the Code of Ethics could result in disciplinary sanctions, including
termination with the Firm. Any client or prospective client can request a copy of SEA’s
Code of Ethics which will be provided at no cost.
The following basic principles guide all aspects of the Firm’s business and represent the
minimum requirements to which the Firm expects employees to adhere:
• Clients’ interests come before employees’ personal interests and before the
Firm’s interests.
• The Firm must fully disclose all material facts about conflicts of which it is aware
between the Firm and its employees’ interests on the one hand and client and
the Firm’s interests on the other.
• Employees must operate on the Firm’s behalf and on their own behalf
consistently with the Firm’s disclosures and to manage the impacts of those
conflicts.
• The Firm and its employees must not take inappropriate advantage of their
positions of trust with or responsibility to clients.
• The Firm and its employees must always comply with all applicable securities
laws.
Misuse of Nonpublic Information
The Code of Ethics contains a policy against the use of non-public information in
conducting business for the Firm. Employees cannot convey non-public information nor
depend upon it in placing personal or clients’ securities trades.
Personal Securities Trading
SEA permits itself or its employees to purchase or sell recommended securities, as long
as transactions for clients in the same securities are placed before or at the same time
as employee transactions. SEA’s Code of Ethics also prohibits the purchase of IPOs or
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
private placements without prior permission from Mr. Stegent, SEA’s Chief Compliance
Officer.
Employees are required to submit reports of personal securities trades on a quarterly
basis, and securities holdings annually. These are reviewed by the Chief Compliance
Officer to ensure compliance with the Firm’s policies.
Outside Business Activities
Employees are required to report any outside business activities generating revenue. If
any are deemed to be in conflict with clients, such conflicts will be fully disclosed or SEA
will require that such activity stop.
BROKERAGE PRACTICES
SEA does not require clients to use any particular broker/dealer. SEA will recommend a
broker/dealer based on costs, skills, reputation, dependability and compatibility with the
client. The value of products, research or services provided to SEA or a related person
is not a factor in broker/dealer selection. SEA does not receive any sales commissions
from any broker/dealer utilized by the client.
SEA recommends Charles Schwab as custodian for its clients’ accounts, although SEA
does not require that trades be executed by the custodian. This custodian has been
selected for access to investment products, efficiency of operation, provision of
electronic downloads to SEA, as well as availability of information over the internet to
clients. Clients must sign applications in order to open accounts with any custodian.
Research and Other Soft-Dollar Benefits
SEA has no formal or informal soft-dollar relationships with Charles Schwab, where
commissions generated by client transactions are used to purchase research or other
services that might benefit all clients of the Firm. Charles Schwab does provide SEA
with access to industry information, newsletters, seminars and conferences in the
package of services it provides all investment advisors using its custodial services.
Charles Schwab provides these services in its effort to compete for the Firm’s custodial
business rather than on a soft-dollar basis.
Brokerage for Client Referrals
The Firm does not receive referrals from a broker/dealer or third party providing service
to SEA.
Directed Brokerage
For clients who choose to execute trades through broker/dealers with whom they have
an existing relationship, the Firm cannot meet its fiduciary duty to obtain best execution
for transactions enacted for those clients. Clients selecting their own broker could pay
more than those using those selected by SEA.
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
Order Aggregation
Mutual funds are traded separately for each client on the Charles Schwab electronic
trading platform. When an ETF or stock position is being taken in or sold from a large
number of client accounts during the same rebalancing period, then a block trade is
generally utilized. All block trades will be allocated by close of business on the day of the
trade and all participating accounts receive the same price.
When an aggregated order is only partially filled (and there is no reasonable expectation
that the entire transaction will be completed within a reasonable period), the order will
generally be allocated to participating clients on a pro rata basis based upon the relative
amounts allocated in the preliminary allocation.
REVIEW OF ACCOUNTS
SEA reviews managed accounts on at least an annual basis, but could be as often as
monthly, depending upon the size and objective of each account. The calendar is the
triggering factor for all account reviews. Accounts at other money managers are
reviewed when SEA receives their statements, usually on a quarterly basis.
Mr. Stegent reviews all client accounts for consistency with investment allocations of the
model portfolio being utilized.
Performance reports are provided quarterly by SEA and realized gain and loss
statements are provided annually, but more frequently if requested by client. SEA will
provide unrealized gain and loss statements upon request at any time.
CLIENT REFERRALS AND OTHER COMPENSATION
SEA does not pay outside parties to solicit clients.
CUSTODY
Because SEA generally has the authority to instruct the account custodian to deduct the
investment management fee directly from the client’s account, SEA is considered to
have “custody” of client assets. Custody is defined as having any access to client funds
or securities. This limited access is monitored by the client through receipt of account
statements directly from the custodian. These statements all show the deduction of the
management fee from the account. Otherwise, SEA can only direct the movement of
funds from one account in the client’s name to another such titled account but has no
other access to funds.
When clients receive their statements from the account custodian, they should carefully
review those statements and take the time to compare them with those received from
SEA. If the client finds significant discrepancies, the custodian and SEA should be
notified.
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Part 2A of Form ADV: Firm Brochure
Stegent Equity Advisors, Inc.
February 2026
SEA has standing letters of authorization to third parties to withdraw client funds or
securities maintained with a qualified custodian upon its instruction to the qualified
custodian. According to the SEC, this means that SEA has custody of those clients’
assets and is required to comply with the Custody Rule. Because the SEC’s seven
conditions have been met, a surprise exam is not required.
INVESTMENT DISCRETION
SEA manages most client accounts on a discretionary basis. The discretionary authority
is restricted by the limited power of attorney assigned to SEA, granting SEA only trading
authority, fee deduction and receipt of duplicate statements and confirmations. Trading
is limited to general securities, ETFs, mutual funds and government securities, unless
otherwise agreed to in writing by the client. Nondiscretionary accounts are managed for
clients not willing or unable to provide limited power of attorney to SEA.
VOTING CLIENT SECURITIES
SEA does not vote proxies or participate in class action shareholder suits on behalf of
clients. Clients receive proxy material directly from their account custodian by either
email or U.S. mail. Clients can address questions concerning any proxy or class action
matter to SEA personnel.
FINANCIAL INFORMATION
SEA is not required to provide financial information, as it does not have custody of client
assets beyond the deduction of investment management fees from client accounts.
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