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3411 Wilson Avenue SW
Grandville, MI 49418
(616)878-4200
www.stw-adv.com
General Disclosure Statement and Firm
Brochure Part 2A of ADV
Revised February 25th, 2026
This brochure provides information about the qualifications and business practices of Stewardship Trust Advisors, Inc.
If you have any questions about the contents of this brochure, please contact us at (616)878-4200 or office@stw-
adv.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 Pilgrims Capital Advisors is also available on the SEC’s website at www.adviserInfo.sec.gov.
Registration with the SEC or any state securities authority does not imply a certain level of skill or training.
Item 2: Material Changes
There have been no material changes to this document since the last amendment dated February 2, 2024
Item 3: Table of Contents
Item 2: Material Changes ........................................................................................................................................ 2
Item 4: Advisory Business ........................................................................................................................................ 3
Investment Management Services ....................................................................................................................... 3
Financial Planning Services ................................................................................................................................... 3
Fiduciary Status ........................................................................................................................................ 4
Item 5: Fees and Compensation .............................................................................................................................. 5
Investment Management Fees ............................................................................................................................. 5
Legacy Fee Schedule ............................................................................................................................................ 5
Financial Planning Fees ......................................................................................................................................... 5
Item 6: Performance-Based Fees and Side-By-Side Management ........................................................................... 6
Item 7: Types of Clients ........................................................................................................................................... 6
Minimum Account Requirements ........................................................................................................................ 6
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................................... 6
Margin Trading ..................................................................................................................................................... 7
Item 9: Disciplinary Information .............................................................................................................................. 7
Item 10: Other Financial Industry Activities and Affiliations .................................................................................... 7
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................... 8
Item 12: Brokerage Practices. Research and Other Soft Dollar Benefits .................................................................. 8
Trading Practices .................................................................................................................................................. 8
Item 13: Review of Accounts ................................................................................................................................... 9
Item 14: Client Referrals and Other Compensation ................................................................................................. 9
Item 15: Custody ................................................................................................................................................... 10
Item 16: Investment Discretion ............................................................................................................................. 10
Item 17: Voting Client Securities ........................................................................................................................... 11
Item 18: Financial Information .............................................................................................................................. 11
Acknowledgements ............................................................................................................................................... 12
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Item 4: Advisory Business
STA is registered as an investment adviser with the Securities and Exchange Commission (“SEC”). STA was
founded in June 2023 when Todd Ackermann joined Pilgrims Capital Advisors, Inc. (PCA”), owned by John
Wierenga. Prior to STA’s creation, PCA was a state-registered investment adviser with the State of Michigan.
STA offers asset management, financial planning, and ERISA 3(21) and 3(38) retirement plan services. These
services are tailored to client needs based on risk, investment objectives, time horizons, and individual
income and liquidity needs. You may request reasonable restrictions be placed on your account as described
in Item 16: Investment Discretion.
Investment Management Services
Our investment management services include the ongoing account management of investments held in your
financial accounts. We provide investment management services on a discretionary and non-discretionary
basis. Our clients include individuals, corporations, charitable organizations, banks, trusts and estates, and
retirement accounts/plans (see Retirement Plan Services, below, for additional information). We provide
investment advice and management related to a variety of investments such as stocks, bonds, mutual funds,
ETFs, CDs, real estate investments, and commodities. Please see Item 8: Methods of Analysis, Investment
Strategies, and Risk of Investment Loss for additional information regarding how we manage accounts, and
the risks associated with our management style.
Our objective is to build a diverse portfolio based on your unique goals, objectives, risk appetite, and
preferences.
Financial Planning Services
STA provides clients with financial planning services, pursuant to a separate agreement. Financial planning
services do not involve the ongoing management of your account but instead focuses on your entire financial
situation. Through long-term planning, reviewing tax considerations, risk management, asset allocation,
retirement planning, charitable giving, and legacy planning, to name a few, our financial planning services
attempt to provide a high-level review of your investing goals and objectives while establishing a workable
game plan to meet them.
Fees are charged differently for Financial Planning Services compared to our Investment Management
Services. You can review all of STA’s fees in Item 5: Fees and Compensation.
Retirement Plan Services
We offer investment management services to retirement plans. Our retirement plan clients include pension,
profit sharing, and participant-directed, individual account plans (i.e., 401(k), 403(b), IRAs, etc.). STA offers
the following services to retirement plans:
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(1) Discretionary Investment Management Services,
(2) Non-Discretionary Investment Advisory Services, and/or
(3) Retirement Plan Fiduciary Services to employer-sponsored retirement plans and their participants
in either an ERISA 3(38) fiduciary or ERISA 3(21) co-fiduciary capacity.
Depending on the type of plan and the specific arrangement with the plan sponsor, we may provide one or
more of these services. Prior to being engaged by the plan sponsor, we will provide a copy of this Form ADV
Part 2A along with a copy of our Privacy Policy and the applicable Agreement that contains the information
required to be disclosed under Sec. 408(b)(2) of the Employee Retirement Income Security Act (“ERISA”), as
applicable.
In providing these retirement plan services; a plan participant or beneficiary may request additional services
from STA. If they do, STA may establish a separate client relationship with one or more plan participants or
beneficiaries through a separate agreement.
If you choose to execute a rollover from a plan to a IRA account advised or managed by STA, or if we make a
recommendation to affect a rollover, we will have a conflict of interest given that our IRA advisory fees are
likely higher than those charged by the plan or that we receive in connection with our retirement plan
services, due to the individualized nature of our IRA-related services compared to group services related to
plans. To mitigate this conflict, STA will disclose relevant information about the applicable fees we charge
for advising or managing an IRA prior to opening an account and executing the rollover. Please note that STA
does not make decisions regarding whether clients should take a distribution from a retirement account,
distribution decisions rest solely with the individual participant and beneficiaries.
Fiduciary Status
STA is a fiduciary, and, as a fiduciary, we are obligated to place your interests ahead of ours at all times.
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
(“ERISA”) 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 interests ahead of yours. Under this special rule’s
provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and 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.
STA manages approximately $268,900,000 in assets managed on a discretionary basis and $26,730,000 on a
non-discretionary basis.
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Item 5: Fees and Compensation
Investment Management Fees
Advisory fees for STA’s investment management services are based on a percentage of the assets under
management or a flat fee. Annual fees range from one half of one percent (½ of 1% or 0.5%) to one and a
half percent (1.5%) or an equivalent flat fee. Fees are negotiable depending on the size and complexity of
your account.
Fees are payable on a quarterly basis in advance based on the market value of the assets under management
at the end of the preceding quarter. You are responsible for all brokerage commissions and any other charges
incurred by the custodian. Fees are deducted directly from your account by the Custodian. The custodian
will send you statements, at least quarterly, showing all disbursements for the account, including the amount
of the advisory fee. From time to time, STA may provide you with written updates and/or performance
reports for your accounts. You should carefully compare the reports and/or statements we send you to the
custodian’s official statements.
If your account is not invested for the full billing period (i.e., a full quarter), unearned fees will be repaid to
you based on a pro rata calculation. You may terminate your investment management agreement with us at
any time by providing us with written notice and such termination will be effective immediately upon receipt
of such notice.
Custodians may impose additional transactional or account-related fees. These fees are separate from STA’s
fees described in this Brochure and you are responsible for paying the Custodian’s fees.
Legacy Fee Schedule
As referenced in Item 2: Material Changes and Item 4: Advisory Business, Todd Ackermann recently joined
STA as an owner and brought his clients with him. Prior to joining STA, Mr. Ackermann’s clients signed
advisory contracts and agreed to specific fees (referred to as “Legacy Clients” and/or “Legacy Fees”). STA will
honor the Legacy Fees clients were being charged prior to Mr. Ackermann joining STA. As a result, there will
be Clients paying more or less than other clients for the same services. The maximum Legacy Fee is one and
a half percent (1.5%), consistent with STA’s maximum fee.
Additionally, the frequency and timing of billing may be different for Legacy Clients. Over time, we will work
to transition Legacy Clients to a unified STA investment management agreement to ensure operational
consistency across all valued clients.
Financial Planning Fees
Fees for financial planning depend on the complexity of the financial plan. Our max fee is $275 per hour.
Fees are paid after the consultation. Under no circumstances will our firm collect more than $1200 six or
more months in advance. You determine how many hours of financial counseling you will need. You may
terminate your financial planning agreement at any time by providing written notice, which will be effective
when received by STA. Any fees paid for which services have not been rendered, will be refunded to you on
a pro rata basis based on work performed.
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We do not earn sales commissions for the sale of securities or other investment products, including asset-
based sales charges or service fees from the sale or servicing of mutual funds although clients may pay other
types of fees or expenses such as custodian fees or mutual fund expenses. Clients will also incur brokerage
and other transaction costs assessed by the custodian. These charges are separate and distinct from STA’s
fees and you are responsible for paying them. See Item 12: Brokerage Practices. Research and Other Soft
Dollar Benefits. STA does receive an annual revenue-sharing fee of 0.20bp from Eventide Funds on
Institutional Class Shares held in custodian client account that constitutes a conflict of interest. This creates
an incentive for the advisor. It is important that you review the disclosures related to this conflict of interest
in Item 14: Client Referrals and Other Compensation.
Additionally, we may select and monitor other money managers, on your behalf. If so, the overall AUM fee
is split and billed separately by other money manager and STA. For example: If a Third-Party Manager's total
AUM fee is 1%, a portion of the 1%, normally half, will be quarterly billed separately by both TPM and STA.
TPMs do not pay STA directly and the overall fee would be the same as if STA managed 100% of funds. You
are free to select any broker you wish for implementation of our advice and are not obligated to use brokers
or agents affiliated with STA.
Item 6: Performance-Based Fees and Side-By-Side Management
STA does not charge performance-based fees, which is a fee based on a share of capital gains or capital
appreciation of your assets. Because we do not charge a performance-based fee, we also do not engage in
side-by-side management, which occurs when a firm manages accounts that are charged a performance-
based fee alongside accounts that are charged another type of fee (such as an hourly, flat, or asset-based
fee).
Item 7: Types of Clients
Most of our clients are individuals, but we also we may also work with retirement plans, businesses,
charitable organizations, trusts & estates, and banks.
Minimum Account Requirements
STA has established account minimums. In order to work with STA, you must have $250,000 or annual
minimum fee of $3,000 (collectively, the “Account Minimum Standards”). We reserve the right to accept or
reject accounts based on our Account Minimum Standards, in our sole discretion.
Additionally, some of the third-party managers STA recommends may have account minimums, as well.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
We give advice on—but do not necessarily recommend—all types of securities, ranging from government
bonds through mutual funds to commodities. We engage in fundamental securities analysis. Our main
sources of financial information are financial newspapers & magazines, research materials prepared by
others, corporate rating services, annual reports and company press releases. Our investment strategy is
investing primarily for the long term, but occasionally capitalizing on short term opportunities.
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Investments are subject to various market, political, currency, economic, and business risks, and may not
always be profitable. Past performance of any investments, including those recommended by STA, should
not be construed as an indication of future results, which will prove to be better or worse than past results.
INVESTMENTS WILL GO UP OR DOWN, DEPENDING ON MARKET CONDITIONS. We make no promises,
guarantees or warranties that any of our services will result in a profit to you. Investing in securities involves
risk of loss, which you must be prepared to bear.
Margin Trading
Some of our clients choose to engage in options trading and/or trading on margin. These methods require
additional assumptions of risk. It is possible to lose more funds than you deposited in an account.
Furthermore, your custodian can force the sale of securities in your account without contacting you and, in
this event, you are not entitled to choose which securities are liquidated to meet the demands of the margin
call or options contract. Also, the custodian may move securities held in your cash account to your margin
account and pledge the transferred securities. The custodian can also increase its “house” maintenance
requirements at any time and is not required to provide you with written notice in advance or offer an
extension on any margin call. For these reasons, disclosure statements regarding options and/or margin
trading should be provided by your custodian, and you may be required to sign additional
acknowledgements describing the associated risks.
To the extent that margin is employed in the management of your investment portfolio, the market value of
your account will be increased. Therefore, the corresponding fee you pay us will increase because we include
the margin balance in your overall management fee calculation. As a result, in addition to understanding and
assuming the additional principal risks associated with the use of margin, authorizing margin creates a
conflict of interest between us because recommending margin will increase the management fee you pay
us. This affects clients who have a margin balance at the time of billing. If you have a concern about margin
and its implications on your account, please contact John Wierenga or Todd Ackermann to discuss.
Item 9: Disciplinary Information
This section is dedicated to informing you of all material facts regarding any legal or disciplinary events that
are material to your evaluation of our advisory business or the integrity of our management. We have no
legal or disciplinary events to disclose.
Item 10: Other Financial Industry Activities and Affiliations
STA’s owners, Mr. Wierenga and Mr. Ackermann, are licensed insurance agents. As such, they receive
commissions and other income with the sale of insurance products. This represents a conflict of interest
because Mr. Wierenga and Mr. Ackermann have an incentive to sell you insurance in order to receive
additional compensation. However, you are not required to purchase insurance through STA.
information regarding each
Additional
investment adviser representatives’ business background,
educational experience, other activities or affiliations, and disciplinary history can be found in their ADV Part
2B (“Disclosure Brochure”), available by searching “Stewardship Trust Advisors” on the SEC’s website:
www.adviserinfo.sec.gov.
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Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
On occasion, we may buy or sell securities that we recommend to you. This presents a conflict of interest.
However, we believe this conflict is mitigated by the fact that the securities are widely held and publicly
traded. Our trading volume is not significant enough to affect the market and we always place your interests
ahead of our own interests. We have developed policies and procedures under our Code of Ethics that
require our employees to submit their personal securities holdings and transactions to the Firm for review
and/or approval. We believe this also helps ensure that your interests are paramount and trading decisions
are made with your best interests in mind, not STA’s or our employees’ interests.
Item 12: Brokerage Practices. Research and Other Soft Dollar Benefits
Broker dealers and or custodians that STA utilizes for its management business are chosen for several
reasons such as reputation, compliance with various security and regulatory laws, diversity of investments,
trade execution efficiencies and are economically competitive. STA receives both proprietary and third-party
research from both its current custodians Schwab Institutional and Axos Financial Inc. which is considered a
conflict of interest (called a “soft dollar benefit).” This benefit creates a conflict of interest because we do
not have to produce it or pay for the third-party research and creates an incentive for us to place business
with the custodian providing the soft dollars.
You may decide to take our investment advice and implement it yourself at a broker-dealer of your choosing.
If you choose to do this, you must understand that we may be unable to effectively negotiate compensation
on your behalf. You should consider whether the commissions, expenses, execution, clearance, and
settlement capabilities that you will obtain through the broker-dealer your select are favorable compared to
what we obtain for our clients.
Trading Practices
STA generally trades client accounts on an individual basis. In cases when we need to implement buys or
sells of the same security for numerous accounts, we may elect to purchase or sell such securities at
approximately the same time as a block trade. This process is also referred to as aggregating orders and
batch trading and is used by our Firm when we believe such action may prove advantageous to clients. If we
aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. The
process of aggregating client orders is done to achieve better execution across client accounts. We may also
do it to achieve more favorable commission rates or to allocate orders among clients on a more equitable
basis to avoid differences in prices and transaction fees or other transaction costs that might be obtained
when orders are placed independently.
We use the pro rata allocation method for transaction allocation. Under this procedure, pro rata trade
allocation means an allocation of the trade is issued among applicable advisory clients in amounts that are
proportional to the participating advisory client’s intended investment. We will calculate the pro rata share
of each transaction included in a block order and assign the appropriate number of shares of each allocated
transaction executed for the client’s account.
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Item 13: Review of Accounts
We review managed accounts frequently and financial planning accounts annually. The calendar is the
triggering factor. Accounts at other money managers are reviewed when we receive their statements,
usually quarterly. Your financial advisor reviews your accounts on a portfolio-analysis basis. We may prepare
reports for, but not on a regular basis, unless otherwise specified. You will get statements from your
broker/dealers, custodians, TPA, mutual funds and other money managers, as appropriate.
Item 14: Client Referrals and Other Compensation
We do not earn sales commissions for selling securities. As referenced above, STA’s advisers are licensed
insurance agents. As such, we may receive normal commissions and other income associated with insurance
sales. This creates a conflict of interest because the compensation creates an incentive to recommend
insurance to you. You are not required to purchase insurance through STA, which we believe mitigates this
conflict. At all times, your best interests are paramount.
We do not compensate anyone, either directly or indirectly, for client referrals. We also do not have any
arrangements, oral or in writing, whereby we are compensated by a third party for giving client advice.
Advisor may receive general revenue sharing from certain mutual fund companies as described in this
disclosure brochure. In the case of qualified plans, these revenues are shared back into the plan to offset
overall fund expenses. When referring clients to Third Party Managers (“TPMs”), the AUM fee is split
between the TPM and STA. For example: If a TPM's total AUM fee is 1%, a portion of the 1%, normally half,
will be quarterly billed separately by both the TPM and STA. TPMs do not pay STA directly and the overall
fee you are charged will be the same as if STA managed 100% of funds.
Revenue Share Conflict of Interest
As referenced above, STA receives an annual revenue sharing fee of 0.20bp from Eventide Funds on
Institutional Class Shares held in client accounts. Revenue sharing, as received by STA, involves a payment
from a mutual fund company to STA. The amount paid to STA is not an additional charge to you. The revenue-
share compensation creates a conflict of interest because the revenue is provided to STA and is not
credited back to retail client accounts, creating an incentive for STA to allocate to Eventide Funds over other
funds that may be better suited for you or better aligned with your needs and objectives. The Eventide Fund
assets represent approximately 10% of STA’s overall allocations and are part of a general strategy
recommended by STA that includes no-load funds and ETFs held in your account with the custodian
(investments are not held directly with Eventide). Revenue sharing payments increase or decrease from year
to year with changes in the value of the invested assets. Again, this creates a conflict of interest because we
have an incentive to increase the value of assets invested with Eventide so that we can receive higher
revenue share payments. While this revenue does create a conflict of interest, we attempt to mitigate this
conflict by providing you with information related to the revenue and reminding you that you do not have
to purchase Eventide Funds, even if we recommend them. You can ask us to recommend other investment
products that do not provide revenue share to STA.
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Item 15: Custody
Custody occurs when a financial institution has control over client funds/securities or the ability to obtain
control over them. STA does not have custody and does not act as custodian for any client assets. The
Custodian will deduct fees from your account, as described above, and provide you with account statements.
If STA provides you with a report or other written documentation related to your account, we strongly
encourage you to compare the documents you receive from us to the Custodian’s statements to ensure
accuracy. All fees are deducted directly from your account by the Custodian.
Item 16: Investment Discretion
When engaging STA as your investment adviser, you will sign our firm’s discretionary investment
management agreement (the “Agreement”). The Agreement outlines the parameters of our relationship
with you, including the authorization you grant us to make trades within your account on a discretionary
basis. This means that we have authority over your account to place trades on your behalf without express
consent. All trades will be executed according to our discussion of your needs and goals, but we will not
obtain your prior approval for trading within your account.
When we manage your accounts on a discretionary basis, our discretion is limited to making
recommendations, effecting trades, and reallocating investments within your account. We are not
authorized to withdraw funds and/or securities from your accounts. In addition, discretionary transactions
are limited to stocks & bonds, mutual funds, ETFs, options, government securities and brokered CD’s.
Discretionary authorization is granted in our Agreement. You will authorize the custodian, via your separate
agreement with the custodian, to withdraw fees directly from your account. When granting us discretionary
authorization, we will be responsible for making decisions regarding the timing of buying or selling an
investment and the price at which the investment is bought or sold.
If you choose non-discretionary management, we must obtain your permission prior to placing trades or
reallocating your account to align with your investment goals and objectives. Please understand that if we
are unable to reach you or you are slow to respond to our request, we cannot proceed with trading and that
may have an adverse impact on the timing of trade implementations. As a result, we may not achieve the
best trading price.
You may limit this authority by notifying us in writing. You may also place reasonable restrictions on the type
of investments that may be purchased for your account. STA reserves the right to accept or reject any
discretionary or non-discretionary trading arrangements you propose, in our sole discretion. You may
terminate your Agreement at any time by providing written notice, which will be effective when received by
STA.
When providing Retirement Plan Services, described in Item 4: Advisory Business, above, STA may be
granted limited discretionary authority to select and replace investment alternatives for the retirement plan
(or to allocate, reallocate, and rebalance model portfolios for plan participants). When these plans are
covered by Title I of ERISA, STA is providing these services as an “investment manager” and “fiduciary” as
those terms are defined in ERISA Sections 3(38) and 3(21).
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Item 17: Voting Client Securities
STA votes proxies on behalf of our clients. If we vote proxies for you, you are entitled to review the voting
history attached to your account and may request those records at any time, along with STA’s proxy voting
policy. STA votes proxies based on the best interest of each account.
STA will not be responsible for voting (or recommending how to vote) proxies of the mutual fund shares held
by a qualified retirement plan (or its trust). Responsibility for voting proxies of investments held by a plan or
its trust remain with the plan sponsor (or, if applicable, the plan participants). Proxies are sent by custodians,
and each proxy vote is maintained by STA. At this time, the total AUM of STA would not present any conflict
of interest to have a material effect on outcomes of STA voting.
Item 18: Financial Information
This item is not applicable to STA. STA does not require or solicit prepayment of more than $1200 in fees per
client, six or more months in advance. Therefore, we are not required to include a balance sheet for the
most recent fiscal year.
Furthermore, STA is not subject to any financial conditions that would be reasonably likely to impair our
firm’s ability to meet our contractual commitments to you.
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Acknowledgements
This is to acknowledge that I/we have read and understood STA’s General Disclosure Statement and Firm
Brochure Part 2A of ADV.
X
(Date)
X
(Date)
X
(Date)
STEWARDSHIP TRUST ADVISORS, INC.
Signature
(Date)
Name
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