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Disclosure Brochure
April 10, 2026
STREAMSONG ADVISORS, LLC
Form ADV Part 2A
Firm Brochure
Item 1 Cover Page
3200 Broadmoor SE
Grand Rapids, Michigan 49512
(616) 433-6006
www.StreamSongAdvisors.com
This brochure provides information about the qualifications and business practices of StreamSong Advisors, LLC (also referred to in
this brochure as “StreamSong,” “the Firm,” or, “our Firm.”). If you have any questions about the contents of this brochure, please
contact us at this telephone number listed above. 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 the Firm is available on the SEC’s website at www.adviserinfo.sec.gov.
Disclosure Brochure
StreamSong Advisors, LLC
Item 2. Material Changes
The material changes in this brochure from the last annual updating amendment on 02/05/2026 of StreamSong
Advisors, LLC are described below. Material changes relate to StreamSong Advisors, LLC’s policies, practices or
conflicts of interests.
• The firm has successfully transitioned to formal registration with the Securities and Exchange Commission from its
previous registration at the state level.
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Item 3. Table of Contents
Item 2. Material Changes .............................................................................................................................................. 2
Item 3. Table of Contents .............................................................................................................................................. 3
Item 4. Advisory Business ............................................................................................................................................ 4
Item 5. Fees and Compensation .................................................................................................................................... 6
Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................ 8
Item 7. Types of Clients ................................................................................................................................................ 8
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 9
Item 9. Disciplinary Information ................................................................................................................................ 11
Item 10. Other Financial Industry Activities and Affiliations .................................................................................... 11
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................. 11
Item 12. Brokerage Practices ...................................................................................................................................... 12
Item 13. Review of Accounts ...................................................................................................................................... 15
Item 14. Client Referrals and Other Compensation .................................................................................................... 15
Item 15. Custody ......................................................................................................................................................... 15
Item 16. Investment Discretion ................................................................................................................................... 16
Item 17. Voting Client Securities ................................................................................................................................ 16
Item 18. Financial Information ................................................................................................................................... 17
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StreamSong Advisors, LLC
Item 4. Advisory Business
StreamSong offers a variety of advisory services, which include financial planning, consulting, and investment
management services. Prior to StreamSong rendering any of the foregoing advisory services, clients are required to
enter into one or more written agreements with StreamSong setting forth the relevant terms and conditions of the
advisory relationship (the “Advisory Agreement”).
StreamSong has been a registered investment adviser since September 2014 and is owned by StreamSong Holdings,
Inc., which is owned by Thomas A. Braun.
As of December 2025, StreamSong has approximately $124,394,948.00 of assets under management.
$117,806,433.00 of the assets are managed on a discretionary basis, while $6,588,515.00 are managed on a non-
discretionary basis.
Financial Planning and Consulting Services
StreamSong offers clients a broad range of financial planning and consulting services, which may include any or all
of the following functions:
• Business Planning
• Retirement Planning
• Cash Flow Forecasting
• Risk Management
• Trust and Estate Planning
• Charitable Giving
• Financial Reporting
• Distribution Planning
•
Investment Consulting
• Tax Planning
•
Insurance Planning
• Manager Due Diligence
While each of these services is available on a stand-alone basis, certain of them may also be rendered in conjunction
with investment portfolio management as part of a comprehensive wealth management engagement (described in
more detail below).
In performing these services, StreamSong will rely on information received from the client or from the client’s other
professionals (e.g., attorneys, accountants, etc.,) and will not independently verify the accuracy of the information
received. Therefore, clients should take care to ensure that the information they provide is accurate and complete.
StreamSong may recommend clients engage the Firm for additional related services, its Investment Advisory
Representatives in their individual capacities as insurance producers and/or other professionals to implement its
recommendations. Clients are advised that a conflict t of interest exists if clients engage StreamSong or its affiliates to
provide additional services for compensation. Clients retain absolute discretion over all decisions regarding
implementation and are under no obligation to act upon any of the recommendations made by StreamSong under a
financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify
the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating,
or revising StreamSong’s recommendations and/or services.
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StreamSong Advisors, LLC
Investment and Wealth Management Services
StreamSong manages client investment portfolios on a discretionary or non-discretionary basis. In addition, StreamSong
may provide clients with wealth management services, which may include a broad range of comprehensive financial
planning and consulting services as well as discretionary and/or non-discretionary management of investment
portfolios.
StreamSong primarily allocates client assets among various individual equity securities, debt securities, exchange-traded
funds (“ETFs”), mutual funds, and independent investment managers (“Independent Managers”) in accordance with
their stated investment objectives. In addition, StreamSong may also recommend that certain eligible clients invest in
privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge
funds) among other alternative products.
Where appropriate, the Firm may also provide advice about any type of legacy position or other investments held client
portfolios. Clients may engage StreamSong to manage and/or advise on certain investment products that are not
maintained at their primary custodian, such as the separate accounts within variable and other life insurance and annuity
contracts, as well as assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In
these situations, StreamSong directs or recommends the allocation of client assets among the various investment options
available with these products. These assets are generally maintained at the underwriting insurance company or the
custodian designated by the product’s provider.
StreamSong tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous
basis, that client portfolios are managed in a manner consistent with those needs and objectives. StreamSong consults
with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints
and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify
StreamSong if there are changes in their financial situation or if they wish to place any limitations on the management
of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if
StreamSong determines, in its sole discretion, the conditions would not materially impact the performance of a
management strategy or prove overly burdensome to the Firm’s management efforts.
Retirement Plan Consulting Services
StreamSong provides various consulting services to qualified employee benefit plans and their fiduciaries. This suite
of institutional services is designed to assist plan sponsors in structuring, managing and optimizing their corporate
retirement plans. Each engagement is individually negotiated and customized, and may include any or all of the
following services:
• Plan Design and Strategy
• Plan Fee and Cost Analysis
• Plan Review and Evaluation
• Plan Committee Consultation
• Executive Planning & Benefits
• Fiduciary and Compliance
•
Investment Selection
• Participant Education
As disclosed in the Advisory Agreement, certain of the foregoing services are provided by StreamSong as a fiduciary
under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA
Section 408(b)(2), each plan sponsor is provided with a written description of StreamSong’s fiduciary status, the
specific services to be rendered and all direct and indirect compensation the Firm reasonably expects under the
engagement.
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Disclosure Brochure
StreamSong Advisors, LLC
Use of Independent Managers
As mentioned above, StreamSong may select certain Independent Managers to actively manage a portion of its clients’
assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a
separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also
receive the written disclosure documents of the respective Independent Managers engaged to manage their assets.
StreamSong evaluates a variety of information about Independent Managers, which may include the Independent
Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-
party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’
investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and
risk exposure. StreamSong also takes into consideration each Independent Manager’s management style, returns,
reputation, financial strength, reporting, pricing, and research capabilities, among other factors.
StreamSong continues to provide services relative to the discretionary or non-discretionary selection of Independent
Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent
Managers. StreamSong seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with
its clients’ investment objectives and overall best interests.
Item 5. Fees and Compensation
StreamSong offers services on a fee basis, which may include fixed and/or hourly fees, as well as fees based upon assets
under management or advisement. Additionally, certain of the Firm’s Investment Advisory Representatives, in their
individual capacities, may offer insurance products under a separate commission- based arrangement.
Financial Planning, Consulting and Certified Divorce Financial Analysis Fees
StreamSong generally charges a fixed and/or hourly fee for providing financial planning and consulting services under
a stand-alone engagement. These fees are negotiable, but generally range from $200 to $500 on an hourly basis,
depending upon the scope and complexity of the services and the professional rendering the financial planning and/or
the consulting services. If the client engages the Firm for additional investment advisory services, StreamSong may
offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or
consulting services.
The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory
Agreement and StreamSong generally requires one-half of the fee (estimated hourly or fixed) payable upon execution
of the Advisory Agreement. The outstanding balance is generally due upon delivery of the financial plan or completion
of the agreed upon services. The Firm does not, however, take receipt of $500 or more in prepaid fees in excess of six
months in advance of services rendered.
Investment Management Fees
StreamSong offers investment management services for an annual fee based on the amount of assets under the Firm’s
management. This management fee generally varies between 50 and 100 basis points (0.50 %– 1.00 %), depending
upon the size and composition of a client’s portfolio and the type of services rendered, and based on the following fee
schedule:
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StreamSong Advisors, LLC
PORTFOLIO VALUE
First $2,000,000
$2,000,001-$5,000,000
$5,000,001-$10,000,000
Above $10,000,000
BASE FEE
1.00%
0.8%
0.60%
0.50%
StreamSong generally requires a minimum account size of $500,000. StreamSong may, in its sole discretion, elect to
waive its minimum fee based upon certain criteria, including anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client,
account retention, and pro bono activities. If StreamSong waives the minimum account size, the client with a portfolio
under $500,000 will be charged a negotiated fee as outlined in the agreement but will never exceed 2.50%.
The schedule above applies to investment accounts with a balanced / growth objective and with an account size over
$500,000. Accounts which are managed entirely for safety / income / liquidity and invested in all cash / fixed income
assets will be charged a flat 0.25% annually.
The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed
by StreamSong on the last day of the billing period.
For the initial period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement
is terminated, the fee for the final billing period is prorated through the effective date of the termination and the
outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away
assets, accommodation accounts, alternative investments, etc.), StreamSong may negotiate a fee rate that differs from
the range set forth above.
Retirement Plan Consulting Fees
StreamSong generally charges a fixed project-based fee to provide clients with retirement plan consulting services.
Each engagement is individually negotiated and tailored to accommodate the needs of the individual plan sponsor, as
memorialized in the Agreement. These fees vary, based on the scope of the services to be rendered. In those situations
where StreamSong has agreed to manage a plan’s assets, the Firm may also charge an annual asset-based fee which
typically ranges from 25 to 75 basis points (0.25% to 0.75%).
Independent Managers’ Fees
The fees charged by Independent Managers that StreamSong may recommend are described in each of their separate
Disclosure Brochures. As a practice StreamSong does not use outside managers.
Fee Discretion
StreamSong may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated
future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts,
account composition, pre-existing/legacy client relationship, account retention and pro bono activities.
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StreamSong Advisors, LLC
Additional Fees and Expenses
In addition to the advisory fees paid to StreamSong, clients may also incur certain charges imposed by other third parties,
such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial
Institutions”). These additional charges may include securities brokerage commissions, transaction fees, custodial fees,
fees attributable to alternative assets, reporting charges, fees charged by the Independent Managers, charges imposed
directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management
fees and other fund expenses),deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices
are described at length in Item 12, below.
Direct Fee Debit
Clients generally provide StreamSong and/or certain Independent Managers with the authority to directly debit their
accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for
client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to
clients not less than quarterly detailing all account transactions, including any amounts paid to StreamSong.
Alternatively, clients may elect to have StreamSong send a separate invoice for direct payment.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to StreamSong’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to liquidate any
transferred securities or declines to accept particular securities into a client’s account. Clients may withdraw account
assets on notice to StreamSong, subject to the usual and customary securities settlement procedures. However, the Firm
generally designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of
a client’s investment objectives. StreamSong may consult with its clients about the options and implications of
transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to
transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales
charges) and/or tax ramifications.
Item 6. Performance-Based Fees and Side-by-Side Management
StreamSong does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital
appreciation of a client’s assets).
Item 7. Types of Clients
StreamSong typically offers services to individuals, high net worth individuals and pension and profit sharing plans.
Minimum Account Fee
StreamSong generally requires a minimum account size of $500,000. StreamSong may, in its sole discretion, elect to
waive its minimum fee based upon certain criteria, including anticipated future earning capacity, anticipated future
additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client,
account retention, and pro bono activities. If StreamSong waives the minimum account size, the client with a portfolio
under $500,000 will be charged a negotiated fee as outlined in the agreement but will never exceed 2.50%.
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Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
StreamSong utilizes a combination of fundamental, technical and cyclical methods of analysis.
Fundamental analysis involves an evaluation of the fundamental financial condition and competitive position of a
particular fund or issuer. For StreamSong, this process typically involves an analysis of an issuer’s management team,
investment strategies, style drift, past performance, reputation and financial strength in relation to the asset class
concentrations and risk exposures of the Firm’s model asset allocations. A substantial risk in relying upon fundamental
analysis is that while the overall health and position of a company may be good, evolving market conditions may
negatively impact the security.
Technical analysis involves the examination of past market data rather than specific issuer information in determining
the recommendations made to clients. Technical analysis may involve the use of mathematical based indicators and
charts, such as moving averages and price correlations, to identify market patterns and trends which may be based on
investor sentiment rather than the fundamentals of the company. A substantial risk in relying upon technical analysis
is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually
reoccur, there is no guarantee that StreamSong will be able to accurately predict such a reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the assessment of market conditions at a macro (entire
market or economy) or micro (company specific) level, rather than focusing on the overall fundamental analysis of the
health of the particular company that StreamSong is recommending. The risks with cyclical analysis are like those of
technical analysis.
Investment Strategies
Prior to developing an investment strategy tailored to each client, StreamSong gathers and analyzes detailed information
about the client, including goals, existing investments, insurance coverage, sources of income and other assets and
liabilities. The Firm then seeks to define the client’s investment objectives and risk profile, which together form the
basis for the selection and diversification of investments. Once an initial investment strategy is established,
StreamSong’s portfolio managers continually monitor its clients’ portfolios, making changes as needed.
As part of establishing the guidelines for the portfolio, long term asset allocation targets are set. Ranges are identified
around these targets to enable StreamSong to move the portfolio tactically as part of their ongoing management. In
extreme circumstances, such as the COVID-19 pandemic, StreamSong may (and did) move allocations outside these
ranges if it believes such a move is prudent. Clients will be notified of the fact that the portfolio is outside its customary
allocations.
Risk of Loss
Market Risks
Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The
profitability of a significant portion of StreamSong’s recommendations and/or investment decisions may depend to a
great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes.
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There can be no assurance that StreamSong will be able to predict those price movements accurately or capitalize on
any such assumptions.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders
are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities.
Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by
law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting
on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value
(“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual
fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the
market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the
NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a
premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market.
Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for
indexed based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may
cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active
secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when
aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist
for shares of a particular ETF, a shareholder may have no way to dispose of such shares.
Use of Independent Managers
As stated above, StreamSong may select certain Independent Managers to manage a portion of its clients’ assets. In
these situations, StreamSong continues to conduct ongoing due diligence of such managers, but such recommendations
rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In
addition, StreamSong generally may not have the ability to supervise the Independent Managers on a day-to-day basis.
Use of Private Funds
StreamSong recommends that certain clients invest in privately placed pooled investment vehicles (e.g., hedge funds,
private equity funds, etc.). The managers of these funds have broad discretion in selecting the investments. There are
few limitations on the types of securities or other financial instruments which may be traded and no requirement to
diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to
the fund. In addition, because the funds are not registered as investment companies, there is an absence of regulation.
There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement
memorandum and/or other documents explaining such risks prior to investing.
Master Limited Partnerships (MLPs)
Master Limited Partnerships (“MLPs”) are pooled investment funds, the partnership interests of which are publicly
traded on national securities exchanges. MLPs invest primarily in companies within the energy sector that engage in
qualifying lines of business, such as natural resource production and mineral refinement. MLPs are therefore subject
to the underlying volatility of the energy industry and may be adversely affected by changes to supply and demand,
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regional instability, currency spreads, inflation and interest rate fluctuations, among other such factors. In addition,
MLPs operate as pass-through tax entities, meaning that investors are liable for their pro rata share of the partnership
taxes, regardless of the types of accounts where the interests are held.
Item 9. Disciplinary Information
StreamSong has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its
advisory business or the integrity of its management.
Item 10. Other Financial Industry Activities and Affiliations
This item requires investment advisers to disclose certain financial industry activities and affiliations.
Licensed Insurance Agents
Thomas Braun, the Firm’s Managing Member and one of its Investment Advisory Representatives is a licensed
insurance agent and can offer certain insurance products on a fully-disclosed, commissionable basis. A conflict of
interest exists to the extent that StreamSong recommends the purchase of insurance products where an Investment
Advisory Representative is entitled to insurance commissions or other additional compensation. The Firm seeks to
mitigate the conflict of interest by its procedures to ensure that all recommendations are made in its clients’ best interest
regardless of any such affiliations. Clients are under no obligation to implement insurance recommendations made by
the Firm or through any insurance companies with which Investment Advisor Representatives are contracted or
licensed.
Members of Clarity Innovative Wealth Solutions, LLC
Thomas Braun, the Firm’s Managing Member is also a member of Clarity Innovative Wealth Solutions, LLC (CIWS)
a wealth planning consulting firm, and as such is entitled to distributions relative to his membership interests. As a
result, a conflict of interest exists to the extent that StreamSong recommends the consulting services of CIWS to its
clients and organizations, corporations and business entities with which they are affiliated. The Firm seeks to mitigate
that conflict by its procedures to ensure that any such recommendations are provided on a fully-disclosed basis and
only when aligned with its clients’ bests interests.
Owner of StreamSong Advisors Montana LLC
Thomas Braun is the owner of StreamSong Advisors Montana LLC, involved in real estate in Montana. He does not devote
any time or compensation to the business, either during or outside trading hours.
Member of BKV Ventures
Thomas Braun is a member of BKV Ventures, involved in buying into a current office building. He does not devote
any time or compensation to the business, either during or outside trading hours.
Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
StreamSong has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets
forth the standards of conduct expected of its Investment Advisory Representatives. This Code contains written
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policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information
by the Firm or any of its Investment Advisory Representatives and the trading by the same of securities ahead of
clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of StreamSong’s personnel to report their personal securities holdings and
transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). It is the
Firm’s policy not to engage in agency cross or principal transactions.
However, the Firm’s Investment Advisory Representatives are permitted to buy or sell securities that it also
recommends to clients or it has a material financial interest if done in a fair and equitable manner that is consistent
with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities
trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable
impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the
policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person
will access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor
children and adults living in the same household) a transaction in that security unless:
•
the transaction has been completed;
•
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
• a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money
market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and
other high quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds
or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more
mutual funds.
Clients and prospective clients may contact StreamSong to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Recommendation of Broker/Dealers for Client Transactions
StreamSong generally recommends that clients utilize the custody, brokerage and clearing services of Schwab Advisor
Services™ (“Schwab”) for investment management accounts.
Factors which StreamSong considers in recommending Schwab or any other broker- dealer to clients include their
respective financial strength, reputation, execution, pricing, research and service. Schwab may enable the Firm to
obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The
commissions and/or transaction fees charged by Schwab may be higher or lower than those charged by other Financial
Institutions.
The commissions paid by StreamSong’s clients to Schwab comply with the Firm’s duty to obtain “best execution.”
Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the
same transaction where StreamSong determines that the commissions are reasonable in relation to the value of the
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brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible
cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a
Financial Institution’s services, including among others, the value of research provided, execution capability,
commission rates and responsiveness. StreamSong seeks competitive rates but may not necessarily obtain the lowest
possible commission rates for client transactions.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker/dealers in return
for investment research products and/or services which assist StreamSong in its investment decision-making process.
Such research generally will be used to service all of the Firm’s clients, but brokerage commissions paid by one client
may be used to pay for research that is not used in managing that client’s portfolio. The receipt of investment research
products and/or services as well as the allocation of the benefit of such investment research products and/or services
poses a conflict of interest because StreamSong does not have to produce or pay for the products or services.
StreamSong periodically and systematically reviews its policies and procedures regarding its recommendation of
Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
StreamSong may receive without cost from Schwab computer software and related systems support, which allow
StreamSong to better monitor client accounts maintained at Schwab. StreamSong may receive the software and related
support without cost because the Firm renders investment management services to clients that maintain assets at
Schwab. The software and support is not provided in connection with securities transactions of clients (i.e., not “soft
dollars”). The software and related systems support may benefit StreamSong, but not its clients directly. In fulfilling
its duties to its clients, StreamSong endeavors at all times to put the interests of its clients first. Clients should be aware,
however, that StreamSong’s receipt of economic benefits from a broker/dealer creates a conflict of interest since these
benefits may influence the Firm’s choice of broker/dealer over another that does not furnish similar software, systems
support or services.
Specifically, StreamSong may receive the following benefits from Schwab:
• Receipt of duplicate client confirmations and bundled duplicate statements;
• Access to a trading desk that exclusively services its institutional traders;
• Access to block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to client accounts; and
• Access to an electronic communication network for client order entry and account information.
There is no direct link between StreamSong’s participation in Schwab’s institutional programs and the investment
advice it gives to its clients, although StreamSong receives economic benefits through its participation in the programs
that are typically not available to Schwab retail investors. Additionally, StreamSong may receive the following benefits
from Schwab through their programs for registered investment advisers: receipt of duplicate client confirmations and
bundled duplicate statements; access to a trading desk that exclusively services its Registered Investment Adviser
participants; access to block trading which provides the ability to aggregate securities transactions and then allocate
the appropriate shares to client accounts; and access to an electronic communication network for client order entry
and account information. The Firm also has the ability deduct advisory fees directly from client accounts; access to
an electronic communications network for client order entry and account information; access to mutual funds with no
transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research,
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technology, and practice management products or services provided to the Firm by third party vendors. Schwab may
fund business consulting and professional services received by StreamSong’s related persons.
Some of the products and services made available by Schwab through the programs may benefit StreamSong but not
its clients. These products or services may assist StreamSong in managing and administering client accounts, including
accounts not maintained at Schwab. Other services made available by Schwab are intended to help StreamSong manage
and develop its business enterprise. The benefits received by StreamSong’s participation in the programs do not
depend on the amount of brokerage transactions directed to Schwab.
Brokerage for Client Referrals
StreamSong does not consider, in selecting or recommending broker/dealers, whether the Firm receives client
referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct StreamSong in writing to use a particular Financial Institution to execute some or all transactions
for the client. In that case, the client will negotiate terms and arrangements for the account with that Financial
Institution and the Firm will not seek better execution services or prices from other Financial Institutions or be able to
“batch” client transactions for execution through other Financial Institutions with orders for other accounts managed
by StreamSong (as described above). As a result, the client may pay higher commissions or other transaction costs,
greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the
case. Subject to its duty of best execution, StreamSong may decline a client’s request to direct brokerage if, in the
Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties.
Trade Aggregation
Transactions for each client generally will be effected independently, unless StreamSong decides to purchase or sell
the same securities for several clients at approximately the same time. StreamSong may (but is not obligated to) combine
or “batch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably
among the Firm’s clients differences in prices and commissions or other transaction costs that might not have been
obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as
to price and allocated among StreamSong’s clients pro rata to the purchase and sale orders placed for each client on any
given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities,
including securities in which StreamSong’s Investment Advisory Representatives may invest, the Firm generally does
so in accordance with applicable rules promulgated under the Advisers Act and no-action guidance provided by the
staff of the U.S. Securities and Exchange Commission. StreamSong does not receive any additional compensation or
remuneration as a result of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances,
the allocation will be made based upon other relevant factors, which may include: (i) when only a small pe percentage
of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an
account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates;
(ii) allocations may be given to one account when one account has limitations in its investment guidelines which
prohibit it from purchasing other securities which are expected to produce similar investment results and can be
purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an
allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets
after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in
cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more
accounts, the Firm may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis
among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares
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may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
StreamSong monitors client portfolios on an ongoing basis as part of its advisory services.
Portfolio managers may review accounts periodically and are available to discuss clients’
needs, goals, and objectives whenever requested. Clients are encouraged to inform the
Firm of any changes to their financial situation or investment objectives so that their
portfolios can be evaluated in light of those updates. StreamSong may reach out from time
to time to discuss its services or relevant changes in a client’s circumstances, but no
specific meeting schedule is implied or required
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly from the
Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also
receive written or electronic reports from StreamSong and/or an outside service provider, which contain certain account
and/or market-related information, such as an inventory of account holdings or account performance. Clients should
compare the account statements they receive from their custodian with any documents or reports they receive from
StreamSong or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
In the event a client is introduced to StreamSong by either an unaffiliated or an affiliated solicitor, the Firm may pay
that solicitor a referral fee in accordance with applicable state securities laws. Unless otherwise disclosed, any such
referral fee is paid solely from StreamSong’s investment management fee and does not result in any additional charge
to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the solicitor is required to provide the
client with StreamSong’s written brochure(s) and a copy of a solicitor’s disclosure statement containing the terms and
conditions of the solicitation arrangement. Any affiliated solicitor of StreamSong is required to disclose the nature of
his or her relationship to prospective clients at the time of the solicitation and will provide all prospective clients with a
copy of the Firm’s written brochure(s) at the time of the solicitation.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize StreamSong
and/or the Independent Managers to debit client accounts for payment of the Firm’s fees and to directly remit that
those funds to the Firm in accordance with applicable custody rules. The Financial Institutions that act as the qualified
custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send
statements to clients not less than quarterly detailing all account transactions, including any amounts paid to
StreamSong.
In addition, as discussed in Item 13, StreamSong may also send periodic supplemental reports to clients. Clients should
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carefully review the statements sent directly by the Financial Institutions and compare them to those received from
StreamSong.
Item 16. Investment Discretion
StreamSong may be given the authority to exercise discretion on behalf of clients. StreamSong is considered to
exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without
first seeking their consent. StreamSong is given this authority through a power- of-attorney included in the agreement
between StreamSong and the client. Clients may request a limitation on this authority (such as certain securities not to
be bought or sold). StreamSong takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold;
• When transactions are made; and
• The Independent Managers to be hired or fired.
Item 17. Voting Client Securities
Acceptance of Proxy Voting Authority
StreamSong may accept the authority to vote a client’s securities (i.e., proxies) on their behalf. When StreamSong
accepts such responsibility, it will only cast proxy votes in a manner consistent with the best interest of its clients.
Absent special circumstances, which are fully-described in the Firm’s Proxy Voting Policies and Procedures, all
proxies will be voted consistent with guidelines established and described in StreamSong’s Proxy Voting Policies and
Procedures, as they may be amended from time-to-time. Clients may contact StreamSong to request information about
how the Firm voted proxies for that client’s securities or to get a copy of StreamSong’s Proxy Voting Policies and
Procedures. A brief summary of StreamSong’s Proxy Voting Policies and Procedures is as follows:
• StreamSong has formed a Proxy Voting Committee that will be responsible for monitoring corporate
actions, making voting decisions in the best interest of clients, and ensuring that proxies are submitted in a
timely manner.
• The Proxy Voting Committee will generally vote proxies according to StreamSong’s then current Proxy
Voting Guidelines. The Proxy Voting Guidelines include many specific examples of voting decisions for the
types of proposals that are most frequently presented, including: composition of the board of directors;
approval of independent auditors; management and director compensation; anti-takeover mechanisms and
related issues; changes to capital structure; corporate and social policy issues; and issues involving mutual
funds.
• Although the Proxy Voting Guidelines are followed as a general policy, certain issues are considered on a case-
by-case basis based on the relevant facts and circumstances. Since corporate governance issues are diverse and
continually evolving, the Firm devotes an appropriate amount of time and resources to monitor these changes.
• Clients cannot direct StreamSong’s vote on a particular solicitation but can revoke the Firm’s authority to vote
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proxies.
In situations where there may be a conflict of interest in the voting of proxies due to business or personal relationships
that StreamSong maintains with persons having an interest in the outcome of certain votes, the Firm takes appropriate
steps to ensure that its proxy voting decisions are made in the best interest of its clients and are not the product of such
conflict.
Item 18. Financial Information
StreamSong is not required to disclose any financial information due to the following:
• The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance
of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual
commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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