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F O R M A D V P A R T 2 A
D I S C L O S U R E B R O C H U R E
Office Address:
7 Camino Osito
Sante Fe, NM 87505
Tel: 615-975-3635
chase@stonekeepinvestments.com
www.stonekeepinvestments.com
M A R C H 2 0 , 2 0 2 6
This brochure provides information about the qualifications and business practices of
Stonekeep Investment, LLC. Being registered as an investment adviser does not imply a
certain level of skill or training. If you have any questions about the contents of this
brochure, please contact us at 615-975-3635. 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 Stonekeep Investments, LLC (CRD #306144) is available on
the SEC’s website at www.adviserinfo.sec.gov
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when material
changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
Since the last filing of this brochure on January 29, 2026, there have been no material
changes. The version filed January 29, 2026 included the following changes since the
previous filing on March 31, 2025:
•
Item 4 was updated to disclose the most recent calculation for client assets under
management.
•
Item 5 was updated to disclose the current fee schedule.
Full Brochure Available
This Firm Brochure being delivered is the complete brochure for the Firm.
Item 3: Table of Contents
Form ADV – Part 2A – Firm Brochure
Item 1: Cover Page
Item 2: Material Changes .................................................................................................................... ii
Annual Update ................................................................................................................................................................... ii
Material Changes since the Last Update.................................................................................................................. ii
Full Brochure Available .................................................................................................................................................. ii
Item 3: Table of Contents ................................................................................................................... iii
Item 4: Advisory Business .................................................................................................................. 1
Firm Description ............................................................................................................................................................... 1
Types of Advisory Services ........................................................................................................................................... 1
Client Tailored Services and Client Imposed Restrictions ............................................................................... 1
Wrap Fee Programs ......................................................................................................................................................... 1
Client Assets Under Management .............................................................................................................................. 1
Item 5: Fees and Compensation ....................................................................................................... 2
Method of Compensation and Fee Schedule .......................................................................................................... 2
Client Payment of Fees ................................................................................................................................................... 3
Additional Client Fees Charged ................................................................................................................................... 3
Prepayment of Client Fees ............................................................................................................................................ 3
External Compensation for the Sale of Securities to Clients ........................................................................... 3
Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 3
Sharing of Capital Gains ................................................................................................................................................. 3
Item 7: Types of Clients ....................................................................................................................... 4
Description .......................................................................................................................................................................... 4
Account Minimums .......................................................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 4
Methods of Analysis ......................................................................................................................................................... 4
Investment Strategy ........................................................................................................................................................ 5
Security Specific Material Risks .................................................................................................................................. 5
Item 9: Disciplinary Information ..................................................................................................... 7
Criminal or Civil Actions ................................................................................................................................................ 7
Administrative Enforcement Proceedings ............................................................................................................. 7
Self- Regulatory Organization Enforcement Proceedings ............................................................................... 7
Item 10: Other Financial Industry Activities and Affiliations ............................................... 7
Broker-Dealer or Representative Registration .................................................................................................... 7
Futures or Commodity Registration ......................................................................................................................... 8
Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................... 8
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ................ 8
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ..................................................................................................................................................... 8
Code of Ethics Description ............................................................................................................................................ 8
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest.... 9
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest ... 9
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities
Transactions and Conflicts of Interest ..................................................................................................................... 9
Item 12: Brokerage Practices ........................................................................................................... 9
Factors Used to Select Broker-Dealers for Client Transactions .................................................................... 9
Aggregating Securities Transactions for Client Accounts ............................................................................. 11
Item 13: Review of Accounts ........................................................................................................... 11
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons
Involved ............................................................................................................................................................................. 11
Review of Client Accounts on Non-Periodic Basis ........................................................................................... 11
Content of Client Provided Reports and Frequency ........................................................................................ 11
Item 14: Client Referrals and Other Compensation ................................................................ 11
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of
Interest ............................................................................................................................................................................... 11
Advisory Firm Payments for Client Referrals .................................................................................................... 11
Item 15: Custody .................................................................................................................................. 12
Account Statements ...................................................................................................................................................... 12
Item 16: Investment Discretion ..................................................................................................... 12
Discretionary Authority for Trading...................................................................................................................... 12
Item 17: Voting Client Securities ................................................................................................... 12
Proxy Votes ...................................................................................................................................................................... 12
Item 18: Financial Information ...................................................................................................... 12
Balance Sheet .................................................................................................................................................................. 12
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments
to Clients ............................................................................................................................................................................ 13
Bankruptcy Petitions during the Past Ten Years .............................................................................................. 13
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 15
Principal Executive Officer – Michael Chase Reid, CFA, CPWA® ................................................................ 15
Item 2 - Educational Background and Business Experience ....................................................................... 15
Item 3 - Disciplinary Information ........................................................................................................................... 16
Item 4 - Other Business Activities Engaged In ................................................................................................... 17
Item 5 - Additional Compensation .......................................................................................................................... 17
Item 6 - Supervision ..................................................................................................................................................... 17
Brochure Supplement (Part 2B of Form ADV) .......................................................................... 19
Scott Geppert, CFA ......................................................................................................................................................... 19
Item 2 - Educational Background and Business Experience ....................................................................... 19
Item 3 - Disciplinary Information ........................................................................................................................... 19
Item 4 - Other Business Activities Engaged In ................................................................................................... 20
Item 5 - Additional Compensation .......................................................................................................................... 20
Item 6 - Supervision ..................................................................................................................................................... 20
Item 4: Advisory Business
Firm Description
Stonekeep Investments, LLC (“Stonekeep”) was founded in 2019. Michael Chase Reid and
Scott Geppert are Co-Owners.
Types of Advisory Services
ASSET MANAGEMENT
Stonekeep offers discretionary asset management services to advisory Clients. Stonekeep
will offer Clients ongoing asset management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies,
investment selection, asset allocation, portfolio monitoring and the overall investment
program will be based on the above factors. The Client will authorize Stonekeep
discretionary authority to execute selected investment program transactions as stated
within the Investment Advisory Agreement.
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, a thorough review of all applicable topics
including but not limited to, Retirement Planning, Succession Planning, Education Planning,
Legacy Planning, Insurance Planning, Investment Planning, Budget Planning, Personal
Financial Planning, Tax Planning, Major Purchase Planning, Divorce Planning, Debt
Management Planning, Business Exit Planning, and Cash Flow Analysis will be reviewed. If
a conflict of interest exists between the interests of Stonekeep and the interests of the
Client, the Client is under no obligation to act upon Stonekeep’s recommendation. If the
Client elects to act on any of the recommendations, the Client is under no obligation to
affect the transaction through Stonekeep. Financial plans will be completed and delivered
inside of ninety (90) days contingent upon timely delivery of all required documentation.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. Agreements may not be
assigned without written Client consent.
Wrap Fee Programs
Stonekeep does not sponsor any wrap fee programs.
Client Assets Under Management
Stonekeep has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts:
$169,575,000
$0
Date Calculated:
December 31, 2025
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Item 5: Fees and Compensation
Method of Compensation and Fee Schedule
ASSET MANAGEMENT
Stonekeep offers discretionary direct asset management services to advisory Clients.
Stonekeep charges an annual investment advisory fee based on the total assets under
management as follows:
First $0 - $1,000,000
All Assets Above $1,000,000
Assets Under Management Annualized Fee Monthly Fee
0.104167%
0.042%
1.25%
0.50%
Quarterly Fee
0.3125%
0.125%
This is a blended fee schedule; the asset management fee is calculated by applying different
rates to different portions of the portfolio. Stonekeep may group certain related Client
accounts for the purposes of achieving the minimum account size and determining the
annualized fee.
For example, a Client with $1,500,000 under management would pay $15,000 on an annual
basis.
First $1,000,000 x .0125 = $12,500
Next $500,000 x .0050 = $2,500
The annual fee may be negotiable based upon certain criteria (e.g., historical relationship,
type of assets, anticipated future earning capacity, anticipated future additional assets,
dollar amounts of assets to be managed, related accounts, account composition,
negotiations with Clients, etc.). Fees are billed quarterly or monthly in advance based on
the amount of assets managed as of the close of business on the last business day of the
previous billing period. Stonekeep does not charge a management fee on cash accounts.
Clients utilizing Altruist’s Tax IQ feature will pay an additional fee annually to Altruist that
will be disclosed in the Client agreement or an addendum. This feature is utilized at
Stonekeep’s discretion in the best interest of the Client.
Lower fees for comparable services may be available from other sources. Clients may
terminate their account within five (5) business days of signing the Investment Advisory
Agreement with no obligation and without penalty. Clients may terminate advisory
services with thirty (30) days written notice. For accounts opened or closed mid-billing
period, fees will be prorated based on the number of days that services are provided during
the given period. All unpaid earned fees will be due to Stonekeep. Additionally, all
unearned fees will be refunded to the Client. Client shall be given thirty (30) days prior
written notice of any increase in fees. Any increase in fees will be acknowledged in writing
by both parties before any increase in said fees occurs.
FINANCIAL PLANNING AND CONSULTING
Stonekeep charges an hourly fee for financial planning. Prior to the planning process the
Client will be provided an estimated plan fee. Services are completed and delivered inside
of ninety (90) days contingent upon timely delivery of all required documentation. Client
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may cancel within five (5) business days of signing Agreement with no obligation and
without penalty. If the Client cancels after five (5) business days, any unpaid earned fees
will be due to Stonekeep. Stonekeep reserves the right to waive the fee should the Client
implement the plan through Stonekeep. Fees for financial plans are due upon delivery of
the completed plan.
HOURLY FEES
Financial Planning Services are offered based on an hourly fee of $200 per hour.
Client Payment of Fees
Investment management fees are billed monthly or quarterly in advance. Fees are usually
deducted from a designated Client account to facilitate billing. The Client must consent in
advance to direct debiting of their investment account.
Fees for financial plans are due upon delivery of the completed plan.
Stonekeep, in its sole discretion, may charge a lesser investment advisory fee based upon
certain criteria (e.g., historical relationship, type of assets, anticipated future earning
capacity, anticipated future additional assets, dollar amounts of assets to be managed,
related accounts, account composition, negotiations with Clients, etc.).
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds,
equities, and exchange-traded funds. These charges may include mutual fund transaction
fees, postage and handling and miscellaneous fees. For more details on the brokerage
practices, see Item 12 of this brochure.
Prepayment of Client Fees
Stonekeep does not require any prepayment of fees of more than $1,200 per Client and six
months or more in advance.
Investment management fees are billed monthly or quarterly in advance.
If the Client cancels after five (5) business days, any unearned fees will be refunded to the
Client, or any unpaid earned fees will be due to Stonekeep.
External Compensation for the Sale of Securities to Clients
Stonekeep does not receive any external compensation for the sale of securities to Clients,
nor do any of the investment advisor representatives of Stonekeep.
Item 6: Performance-Based Fees and Side-by-Side Management
Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed
securities.
Stonekeep does not use a performance-based fee structure because of the conflict of
interest. Performance based compensation may create an incentive for Stonekeep to
recommend an investment that may carry a higher degree of risk to the Client.
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Item 7: Types of Clients
Description
Stonekeep generally provides investment advice to individuals, high net worth individuals,
charitable organizations, corporations or business entities. Client relationships vary in
scope and length of service.
Account Minimums
Stonekeep does not require a minimum to open an account.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, charting,
and cyclical analysis. Investing in securities involves risk of loss that Clients should be
prepared to bear. Past performance is not a guarantee of future returns.
Fundamental analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is that
the market will fail to reach expectations of perceived value.
Technical analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these patterns
can be identified then a prediction can be made. The risk is that markets do not always
follow patterns and relying solely on this method may not take into account new patterns
that emerge over time.
Charting analysis strategy involves using and comparing various charts to predict long and
short term performance or market trends. The risk involved in using this method is that
only past performance data is considered without using other methods to crosscheck data.
Using charting analysis without other methods of analysis would be making the
assumption that past performance will be indicative of future performance. This may not
be the case.
Cyclical analysis assumes that the markets react in cyclical patterns which, once identified,
can be leveraged to provide performance. The risks with this strategy are twofold: 1) the
markets do not always repeat cyclical patterns; and 2) if too many investors begin to
implement this strategy, then it changes the very cycles these investors are trying to
exploit.
In developing a financial plan for a Client, Stonekeep’s analysis may include cash flow
analysis, investment planning, risk management, tax planning and estate planning. Based
on the information gathered, a detailed strategy is tailored to the Client’s specific situation.
The main sources of information include financial newspapers and magazines, annual
reports, prospectuses, and filings with the Securities and Exchange Commission.
Use of Technology and Artificial Intelligence Stonekeep utilizes various technologies,
including Artificial Intelligence (AI), to assist in market research, data analysis, and firm
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operations. While these tools enhance productivity, all investment decisions and client
communications undergo human review and verification to ensure accuracy and suitability.
Investment Strategy
The investment strategy for a specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by
providing written notice to Stonekeep. Each Client executes a Client profile form or similar
form that documents their objectives and their desired investment strategy.
Other strategies may include long-term purchases, short-term purchases, trading, and
option writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
All investment programs have certain risks that are borne by the investor. Our investment
approach constantly keeps the risk of loss in mind. Investors face the following investment
risks and should discuss these risks with Stonekeep:
• Market Risk: The prices of securities held by mutual funds in which Clients invest
may decline in response to certain events taking place around the world, including
those directly involving the companies whose securities are owned by a fund;
conditions affecting the general economy; overall market changes; local, regional or
global political, social or economic instability; and currency, interest rate and
commodity price fluctuations. Investors should have a long-term perspective and be
able to tolerate potentially sharp declines in market value.
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become
less attractive, causing their market values to decline.
•
Inflation Risk: When any type of inflation is present, a dollar today will buy more
than a dollar next year, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also
referred to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have
to be reinvested at a potentially lower rate of return (i.e. interest rate). This
primarily relates to fixed income securities.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties
are not.
• Management Risk: The advisor’s investment approach may fail to produce the
intended results. If the advisor’s assumptions regarding the performance of a
specific asset class or fund are not realized in the expected time frame, the overall
performance of the Client’s portfolio may suffer.
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• Equity Risk: Equity securities tend to be more volatile than other investment choices.
The value of an individual mutual fund or ETF can be more volatile than the market
as a whole. This volatility affects the value of the Client’s overall portfolio. Small-
and mid-cap companies are subject to additional risks. Smaller companies may
experience greater volatility, higher failure rates, more limited markets, product
lines, financial resources, and less management experience than larger companies.
Smaller companies may also have a
lower trading volume, which may
disproportionately affect their market price, tending to make them fall more in
response to selling pressure than is the case with larger companies.
• Fixed Income Risk: The issuer of a fixed income security may not be able to make
interest and principal payments when due. Generally, the lower the credit rating of a
security, the greater the risk that the issuer will default on its obligation. If a rating
agency gives a debt security a lower rating, the value of the debt security will
decline because investors will demand a higher rate of return. As nominal interest
rates rise, the value of fixed income securities held by a fund is likely to decrease. A
nominal interest rate is the sum of a real interest rate and an expected inflation rate.
•
Investment Companies Risk: When a Client invests in open end mutual funds or ETFs,
the Client indirectly bears their proportionate share of any fees and expenses
payable directly by those funds. Therefore, the Client will incur higher expenses,
which may be duplicative. In addition, the Client’s overall portfolio may be affected
by losses of an underlying fund and the level of risk arising from the investment
practices of an underlying fund (such as the use of derivatives). ETFs are also
subject to the following risks: (i) an ETF’s shares may trade at a market price that is
above or below their net asset value or (ii) trading of an ETF’s shares may be halted
if the listing exchange’s officials deem such action appropriate, the shares are de-
listed from the exchange, or the activation of market-wide “circuit breakers” (which
are tied to large decreases in stock prices) halts stock trading generally. Adviser has
no control over the risks taken by the underlying funds in which Client invests.
• REIT Risk: To the extent that a Client invests in REITs, it is subject to risks generally
associated with investing in real estate, such as (i) possible declines in the value of
real estate, (ii) adverse general and local economic conditions, (iii) possible lack of
availability of mortgage funds, (iv) changes in interest rates, and (v) environmental
problems. In addition, REITs are subject to certain other risks related specifically to
their structure and focus such as: dependency upon management skills; limited
diversification; the risks of locating and managing financing for projects; heavy cash
flow dependency; possible default by borrowers; the costs and potential losses of
self-liquidation of one or more holdings; the possibility of failing to maintain
exemptions from securities registration; and, in many cases, relatively small market
capitalization, which may result in less market liquidity and greater price volatility.
• Long-term purchases: Long-term investments are those vehicles purchased with the
intension of being held for more than one year. Typically, the expectation of the
investment is to increase in value so that it can eventually be sold for a profit. In
addition, there may be an expectation for the investment to provide income. One of
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the biggest risks associated with long-term investments is volatility, the fluctuations
in the financial markets that can cause investments to lose value.
• Short-term purchases: Short-term investments are typically held for one year or less.
Generally, there is not a high expectation for a return or an increase in value.
Typically, short-term investments are purchased for the relatively greater degree of
principal protection they are designed to provide. Short-term investment vehicles
may be subject to purchasing power risk — the risk that your investment’s return
will not keep up with inflation.
• Trading risk: Investing involves risk, including possible loss of principal. There is no
assurance that the investment objective of any fund or investment will be achieved.
• Options Trading: The risks involved with trading options are that they are very time
sensitive investments. An options contract is generally a few months. The buyer of
an option could lose his or her entire investment even with a correct prediction
about the direction and magnitude of a particular price change if the price change
does not occur in the relevant time period (i.e., before the option expires).
Additionally, options are less tangible than some other investments. An option is a
“book-entry” only investment without a paper certificate of ownership.
• Cryptocurrency: Investing in cryptocurrency carries high risks, primarily driven by
extreme price volatility, potential for total loss of capital, and vulnerability to
hacking, fraud, and scams. Investors face regulatory uncertainty, limited investor
protection, and technical complexities in storing assets securely. The market is
largely unregulated, making it difficult to recover stolen assets.
Item 9: Disciplinary Information
Criminal or Civil Actions
Stonekeep and its management have not been involved in any criminal or civil action.
Administrative Enforcement Proceedings
Stonekeep and its management have not been involved in administrative enforcement
proceedings.
Self- Regulatory Organization Enforcement Proceedings
Stonekeep and its management have not been involved in legal or disciplinary events that
are material to a Client’s or prospective Client’s evaluation of Stonekeep or the integrity of
its management.
Item 10: Other Financial Industry Activities and Affiliations
Broker-Dealer or Representative Registration
Stonekeep is not registered as a broker-dealer and no affiliated representatives of
Stonekeep are registered representatives of a broker-dealer.
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Futures or Commodity Registration
Neither Stonekeep nor its affiliated representatives are registered or have an application
pending to register as a futures commission merchant, commodity pool operator, or a
commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
Mr. Reid is a Special Projects Manager for Bretagne, LLC. Mr. Reid spends approximately
10% of his time in this business. This business practice is not a conflict of interest as it is
not investment related and Stonekeep Clients will not be solicited and there will not be any
crossover clients.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
Stonekeep does not select or recommend other investment advisors for compensation.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics Description
include employees and/or
The affiliated persons (affiliated persons
independent
contractors) of Stonekeep have committed to a Code of Ethics (“Code”). The purpose of our
Code is to set forth standards of conduct expected of Stonekeep affiliated persons and
addresses conflicts that may arise. The Code defines acceptable behavior for affiliated
persons of Stonekeep. The Code reflects Stonekeep and its supervised persons’
responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for
their personal accounts and how to mitigate any conflict of interest with our Clients. We do
not allow any affiliated persons to use non-public material information for their personal
profit or to use internal research for their personal benefit in conflict with the benefit to
our Clients.
Stonekeep’s policy prohibits any person from acting upon or otherwise misusing non-
public or inside information. No advisory representative or other affiliated person, officer
or director of Stonekeep may recommend any transaction in a security or its derivative to
advisory Clients or engage in personal securities transactions for a security or its
derivatives if the advisory representative possesses material, non-public information
regarding the security.
Stonekeep’s Code is based on the guiding principle that the interests of the Client are our
top priority. Stonekeep’s officers, directors, advisors, and other affiliated persons have a
fiduciary duty to our Clients and must diligently perform that duty to maintain the
complete trust and confidence of our Clients. When a conflict arises, it is our obligation to
put the Client’s interests over the interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have
access to non-public information regarding any Clients' purchase or sale of securities, or
non-public information regarding the portfolio holdings of any reportable fund, who are
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involved in making securities recommendations to Clients, or who have access to such
recommendations that are non-public.
Stonekeep will provide a copy of the Code of Ethics to any Client or prospective Client upon
request.
Investment Recommendations Involving a Material Financial Interest and Conflict of
Interest
Stonekeep and its affiliated persons do not recommend to Clients securities in which we
have a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
Stonekeep and its affiliated persons may buy or sell securities that are also held by Clients.
In order to mitigate conflicts of interest such as trading ahead of Client transactions,
affiliated persons are required to disclose all reportable securities transactions as well as
provide Stonekeep with copies of their brokerage statements.
The Chief Compliance Officer of Stonekeep is Michael Chase Reid. He reviews all trades of
the affiliated persons each quarter. The personal trading reviews ensure that the personal
trading of affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
Stonekeep does not have a material financial interest in any securities being recommended.
However, affiliated persons may buy or sell securities at the same time they buy or sell
securities for Clients. In order to mitigate conflicts of interest such as front running,
affiliated persons are required to disclose all reportable securities transactions as well as
provide Stonekeep with copies of their brokerage statements.
The Chief Compliance Officer of Stonekeep is Michael Chase Reid. He reviews all employee
trades each quarter. The personal trading reviews ensure that the personal trading of
affiliated persons does not affect the markets and that Clients of the firm receive
preferential treatment over associated persons’ transactions.
Item 12: Brokerage Practices
Factors Used to Select Broker-Dealers for Client Transactions
Stonekeep will recommend the use of a particular broker-dealer based on their duty to
seek best execution for the client, meaning they have an obligation to obtain the most
favorable terms for a client under the circumstances. The determination of what may
constitute best execution and price in the execution of a securities transaction by a broker
involves a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with which
the transaction is affected, the ability to effect the transaction where a large block is
involved, the operational facilities of the broker-dealer, the value of an ongoing
relationship with such broker and the financial strength and stability of the broker.
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Stonekeep will select appropriate brokers based on a number of factors including but not
limited to their relatively low transaction fees and reporting ability. Stonekeep relies on its
broker to provide its execution services at the best prices available. Lower fees for
comparable services may be available from other sources. Clients pay for any and all
custodial fees in addition to the advisory fee charged by Stonekeep. Stonekeep does not
receive any portion of the trading fees.
Stonekeep will recommend the use of Charles Schwab & Co., Inc., Altruist, and/or My529.
• Directed Brokerage
In circumstances where a Client directs Stonekeep to use a certain broker-dealer,
Stonekeep still has a fiduciary duty to its Clients. The following may apply with
Directed Brokerage: Stonekeep's inability to negotiate commissions, to obtain
volume discounts, there may be a disparity in commission charges among Clients
and conflicts of interest arising from brokerage firm referrals. The firm may be
unable to achieve most favorable execution of client transactions, and this practice
may cost clients more money.
• Best Execution
Investment advisors who manage or supervise Client portfolios have a fiduciary
obligation of best execution. The determination of what may constitute best
execution and price in the execution of a securities transaction by a broker involves
a number of considerations and is subjective. Factors affecting brokerage selection
include the overall direct net economic result to the portfolios, the efficiency with
which the transaction is affected, the ability to affect the transaction where a large
block is involved, the operational facilities of the broker-dealer, the value of an
ongoing relationship with such broker and the financial strength and stability of the
broker. The firm does not receive any portion of the trading fees.
• Soft Dollar Arrangements
The Securities and Exchange Commission defines soft dollar practices as
arrangement under which products or services other than execution services are
obtained by Stonekeep from or through a broker-dealer in exchange for directing
Client transactions to the broker-dealer. As permitted by Section 28(e) of the
Securities Exchange Act of 1934, Stonekeep receives economic benefits as a result of
commissions generated from securities transactions by the broker-dealer from the
accounts of Stonekeep. These benefits include both proprietary research from the
broker and other research written by third parties.
A conflict of interest exists when Stonekeep receives soft dollars. This conflict is
mitigated by the fact that Stonekeep has a fiduciary responsibility to act in the best
interest of its Clients and the services received are beneficial to all Clients.
Stonekeep utilizes the services of custodial broker dealers. Economic benefits are
received by Stonekeep which would not be received if Stonekeep did not give
investment advice to Clients. These benefits include: A dedicated trading desk, a
dedicated service group and an account services manager dedicated to Stonekeep's
accounts, ability to conduct "block" Client trades, electronic download of trades,
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balances and positions, duplicate and batched Client statements, and the ability to
have advisory fees directly deducted from Client accounts.
Aggregating Securities Transactions for Client Accounts
Stonekeep is authorized in its discretion to aggregate purchases and sales and other
transactions made for the account with purchases and sales and transactions in the same
securities for other Clients of Stonekeep. All Clients participating in the aggregated order
shall receive an average share price with all other transaction costs shared on a pro-rated
basis.
Item 13: Review of Accounts
Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory
Persons Involved
Account reviews are performed at least annually by investment advisor representatives of
Stonekeep. Account reviews are performed more frequently when market conditions
dictate. Reviews of Client accounts include, but are not limited to, a review of Client
documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability.
Financial plans generated are updated as requested by the Client and pursuant to a new or
amended agreement, Stonekeep suggests updating at least annually.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by Stonekeep’s custodian. Client receives confirmations of
each transaction in account from Custodian and an additional statement at least quarterly.
Item 14: Client Referrals and Other Compensation
Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts
of Interest
Stonekeep receives additional economic benefits from external sources as described above
in Item 12.
Stonekeep has an agreement with Altruist Financial, LLC where Stonekeep refers
unaffiliated registered investment advisors to Altruist to act a custodian. Altruist will pay
Stonekeep 5 basis points of the total assets the referred advisor manages on Altruist.
Advisory Firm Payments for Client Referrals
Stonekeep does not compensate for Client referrals.
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Item 15: Custody
Account Statements
All assets are held at qualified custodians, which means the custodians provide account
statements directly to Clients at their address of record at least quarterly. Clients are urged
to compare the account statements received directly from their custodians to any
documentation or reports prepared by Stonekeep.
Stonekeep is deemed to have limited custody solely because advisory fees are directly
deducted from Client’s accounts by the custodian on behalf of Stonekeep.
Item 16: Investment Discretion
Discretionary Authority for Trading
Stonekeep requires discretionary authority to manage securities accounts on behalf of
Clients. Stonekeep has the authority to determine, without obtaining specific Client
consent, the securities to be bought or sold, and the amount of the securities to be bought
or sold.
Stonekeep allows Client’s to place certain restrictions, as outlined in the Client’s Investment
Policy Statement or similar document. These restrictions must be provided to Stonekeep in
writing.
The Client approves the custodian to be used and the commission rates paid to the
custodian. Stonekeep does not receive any portion of the transaction fees or commissions
paid by the Client to the custodian.
Item 17: Voting Client Securities
Proxy Votes
We do not vote Client proxies or advise clients as to how they should vote. Therefore,
Clients maintain exclusive responsibility for: (1) voting proxies, and (2) acting on corporate
actions pertaining to the Client’s investment assets. To the extent that a client has
designated Stonekeep to receive proxy voting materials on its behalf by indicating as such
on his or her brokerage account paperwork, we will not notify such client that it has
received any proxy voting materials or forward any proxy voting materials to such client
unless it is specifically requested by client in writing that we do so. Clients reserve the right
to instruct the custodian to deliver proxy voting materials directly to them at any time.
Item 18: Financial Information
Balance Sheet
A balance sheet is not required to be provided because Stonekeep does not serve as a
custodian for Client funds or securities and Stonekeep does not require prepayment of fees
of more than $1,200 per Client and six months or more in advance.
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Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet
Commitments to Clients
Stonekeep has no condition that is reasonably likely to impair our ability to meet
contractual commitments to our Clients.
Bankruptcy Petitions during the Past Ten Years
Stonekeep has not had any bankruptcy petitions in the last ten years.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Michael Chase Reid, CFA, CPWA®
Office Address:
7 Camino Osito
Sante Fe, NM 87505
Tel: 615-975-3635
chase@stonekeepinvestments.com
www.stonekeepinvestments.com
This brochure supplement provides information about Michael Chase Reid and
supplements the Stonekeep Investments, LLC brochure. You should have received a
copy of that brochure. Please contact Michael Chase Reid if you did not receive the
brochure or if you have any questions about the contents of this supplement.
M A R C H 2 0 , 2 0 2 6
Additional information about Michael Chase Reid (CRD #6919056) is available on the
SEC’s website at www.adviserinfo.sec.gov.
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Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Principal Executive Officer – Michael Chase Reid, CFA, CPWA®
• Year of birth: 1988
Item 2 - Educational Background and Business Experience
Educational Background:
• Vanderbilt University; B.A. Economics with a Minor in Finance; 2011
Business Experience:
• Bretagne, LLC; Special Projects Manager; 12/2021 - Present
• Stonekeep Investments, LLC; Managing Member/Investment Advisor
Representative; 09/2019 – Present
• La Caballeria, LLC; Co-Owner; 02/2022 - 06/2025
• Exacta Systems, LLC; Advisory Board Member; 01/2021 – 08/2023
• Westwood Wealth Management; Investment Advisor Representative; 03/2018–
10/2019
• Westwood Holding Group; Associate Analyst; 02/2017 – 03/2018
• Westwood Holding Group; Research Associate; 12/2013 – 02/2017
• Westwood Holdings Group; Intern; 07/2013 – 12/2013
• Avondale Partners; Intern; 04/2013 – 05/2013
• Unemployed; 11/2012 – 03/2013
• St. Louis Cardinals; Pitcher; 06/2010 – 10/2012
• Vanderbilt University; Student; 07/2007 – 12/2011
Professional Designations:
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded
by the CFA Institute. CFA certification requirements:
• Hold a bachelor’s degree from an accredited institution or have equivalent
educational or work experience.
• Successful completion of all three exam levels of the CFA Program.
• Have 48 months of acceptable professional work experience in the investment
decision-making process.
• Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
• Agree to adhere to and sign the Member's Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
Certified Private Wealth Advisor (CPWA): issued by the Investment Management
Consultants Association. Candidates must have:
• A satisfactory record of ethical conduct, as determined by IMCA’s Admissions
Committee.
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• Five years of professional Client-centered experience in financial services or a
related industry.
• Bachelor's degree from an accredited college or university or one of the following
designations or licenses: CIMA, CIMC, CFA, CFP, ChFC or CPA license.
• Complete a six-month pre-study education component and five day university-
sponsored classroom training.
• Pass a final exam.
• Complete 40 hours of Continuing Education every two years.
Item 3 - Disciplinary Information
A. Mr. Reid has never been involved in a criminal or civil action in a domestic, foreign
or military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any
felony; (b) misdemeanor that involved investments or an investment-related
business, fraud, false statement or omissions, wrongful taking of property,
bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any
of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses;
3. Was found to have been involved in a violation of an investment-related statute
or regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B. Mr. Reid never had an administrative proceeding before the SEC, any other federal
regulatory agency, any state regulatory agency, or any foreign financial regulatory
authority in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or the subject of an order by the agency or
authority;
2. Was found to have been involved in a violation of an investment-related statute
or regulation or was the subject of an order by the agency or authority
(a) denying, suspending or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
C. Mr. Reid has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or
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2. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members,
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D. Mr. Reid has not been involved in Any other hearing or formal adjudication in which
a professional attainment, designation, or license of the supervised person was
revoked or suspended because of a violation of rules relating to professional
conduct.
Item 4 - Other Business Activities Engaged In
Mr. Reid is a Special Projects Manager for Bretagne, LLC. Mr. Reid spends approximately
10% of his time in this business. This business practice is not a conflict of interest as it is
not investment related and Stonekeep Clients will not be solicited and there will not be any
crossover clients.
Item 5 - Additional Compensation
Mr. Reid receives compensation for his role as a project manager. Mr. Reid does not receive
commissions or any performance-based fees.
Item 6 - Supervision
Since Mr. Reid is the CCO and investment adviser representative of Stonekeep he is solely
responsible for all supervision and formulation and monitoring of investment advice
offered to Clients. He will adhere to the policies and procedures as described in the firm’s
Compliance Manual. He can be reached at chase@stonekeepinvestments.com or 615-975-
3635.
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Item 1 Cover Page
S U P E R V I S E D P E R S O N B R O C H U R E
F O R M A D V P A R T 2 B
Scott Geppert, CFA
Office Address:
7759 La Haye Drive
Irving, TX 75063
Tel: 972-965-5803
scott@stonekeepinvestments.com
www.stonekeepinvestments.com
M A R C H 2 0 , 2 0 2 6
This brochure supplement provides information about Scott Geppert and
supplements the Stonekeep Investments, LLC brochure. You should have received a
copy of that brochure. Please contact Scott Geppert if you did not receive the brochure
or if you have any questions about the contents of this supplement.
Additional information about Scott Geppert (CRD #5548961) is available on the SEC’s
website at www.adviserinfo.sec.gov.
- 18 -
Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure
Scott Geppert, CFA
• Year of birth: 1986
Item 2 - Educational Background and Business Experience
Educational Background:
• Southern Methodist University; Bachelor of Arts in Finance; 05/2009
• Southern Methodist University; Bachelor of Science in Economics; 05/2009
Business Experience:
• Stonekeep Investments, LLC; Member; 08/2020 - Present
• Stonekeep Investments, LLC; Investment Advisor Representative; 01/2020 – Present
• LCM Group; Senior Portfolio Associate; 03/2011 – 01/2020
• Toyota Financial Services; Finance Analytics Manager; 06/2016 – 03/2019
• Westwood Holdings Group; Research Analyst; 03/2012 – 05/2016
• Prudential Capital Group; Senior Investment Analyst; 07/2009 – 03/2012
Professional Designations:
Chartered Financial Analyst (CFA): Chartered Financial Analysts designation is awarded
by the CFA Institute. CFA certification requirements:
• Hold a bachelor’s degree from an accredited institution or have equivalent
educational or work experience.
• Successful completion of all three exam levels of the CFA Program.
• Have 48 months of acceptable professional work experience in the investment
decision-making process.
• Fulfill society requirements, which vary by society. Unless you are upgrading from
affiliate membership, all societies require two sponsor statements as part of each
application; these are submitted online by your sponsors.
• Agree to adhere to and sign the Member's Agreement, a Professional Conduct
Statement, and any additional documentation requested by CFA Institute.
Item 3 - Disciplinary Information
A. Mr. Geppert has never been involved in a criminal or civil action in a domestic,
foreign or military court of competent jurisdiction for which he:
1. Was convicted of, or pled guilty or nolo contender (“no contest”) to (a) any
felony; (b) misdemeanor that involved investments or an investment-related
business, fraud, false statement or omissions, wrongful taking of property,
bribery, perjury, counterfeiting, or extortion; or (c) a conspiracy to commit any
of these offenses;
2. Is the named subject of a pending criminal proceeding that involves an
investment-related business, fraud, false statements or omissions, wrongful
taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a
conspiracy to commit any of these offenses;
- 19 -
3. Was found to have been involved in a violation of an investment-related statute
or regulation; or
4. Was the subject of any order, judgement or decree permanently or temporarily
enjoining, or otherwise limiting, him from engaging in any investment related
activity, or from violating any investment-related statute, rule, or order.
B. Mr. Geppert never had an administrative proceeding before the SEC, any other
federal regulatory agency, any state regulatory agency, or any foreign financial
regulatory authority in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or the subject of an order by the agency or
authority;
2. Was found to have been involved in a violation of an investment-related statute
or regulation or was the subject of an order by the agency or authority
(a) denying, suspending or revoking the authorization of the supervised person
to act in an investment-related business; (b) barring or suspending his
association with an investment-related business; (c) otherwise significantly
limiting his investment-related activities; or (d) imposing a civil money penalty
of more than $2,500 on him.
C. Mr. Geppert has never been the subject of a self-regulatory organization (SRO)
proceeding in which he:
1. Was found to have caused an investment-related business to
lose its
authorization to do business; or
2. Was found to have been involved in a violation of the SRO’s rules and was: (a)
barred or suspended from membership or from association with other members,
or was expelled from membership; (b) otherwise significantly limited from
investment-related activities; or (c) fined more than $2,500.
D. Mr. Geppert has not been involved in Any other hearing or formal adjudication in
which a professional attainment, designation, or license of the supervised person
was revoked or suspended because of a violation of rules relating to professional
conduct.
Item 4 - Other Business Activities Engaged In
Mr. Geppert does not maintain any material relationships or outside business activities to
disclose.
Item 5 - Additional Compensation
Mr. Geppert does not receive commissions or any performance-based fees.
Item 6 - Supervision
Scott Geppert is supervised by Michael Chase Reid, Owner and Chief Compliance Officer of
Stonekeep Investments, LLC. Mr. Reid reviews Mr. Geppert’s work through client account
reviews, quarterly personal transaction reports as well as face-to-face and phone
interactions. Mr. Reid can be contacted at chase@stonekeepinvestments.com or 615-975-
3635.
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