Firm Description Stephenson and Company, Inc. hereinafter ("the Adviser") is a registered investment adviser based in San Clemente, California. We are organized as a corporation under the laws of the State of California. We were founded and have been providing investment advisory services since 1991. We are primarily owned by the Bradley and Teresa Ann Stephenson Trust DTD 7/27/1998.
The Adviser is a fee-only investment management and financial planning firm. The firm does not sell securities on a commission basis.
Types of Advisory Services The Adviser provides investment advisory services, also known as asset management services and furnishes investment advice through consultations, which may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, education funding, retirement planning, and estate planning. The Adviser furnishes advice to clients on matters not involving securities. The Adviser provides several types of advisory services including comprehensive financial planning, custom-designed modular financial planning, fee-only financial planning, investment management and retirement plan consulting.
We offer discretionary and non-discretionary asset management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow us to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm and an account application, which includes the appropriate trading authorization. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing.
If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Comprehensive Financial Planning This service includes the gathering of complete financial information regarding the client's current and historical status in the areas of net worth, income, expenses, taxes, investments, retirement plans, life insurance, health and medical insurance, business arrangements and divorce agreements, as well as future goals and objectives.
A personalized plan is then developed which may include specific recommendations in all applicable areas. The financial plan may include, but is not limited to: a net worth statement; a cash flow statement; projections of future net worth and cash flow; discussion of probability of success in meeting financial goals and objectives, a review of investment accounts, including reviewing asset allocation and providing repositioning recommendations; strategic tax planning; a review of retirement accounts and plans including recommendations; a review of insurance policies and recommendations for changes, if necessary; one or more retirement scenarios; estate planning review and recommendations; and education planning with funding recommendations.
4 Custom Designed Modular Financial Planning This service consists of performing the financial planning services described above, but is limited to only those areas of the client's financial situation specified by the client. The scope of the areas to be included and the extent and nature of the service to be provided will be determined and agreed upon by the client and the planner in advance.
Hourly Consultations The services of Stephenson and Company, Inc. may be arranged for consultation regarding a specific, specialized look at a particular aspect of the client's financial situation, without engaging in any of the planning arrangements listed above.
Investment Management and Consulting Services The Adviser provides a variety of investment management, consulting and monitoring services in addition to the financial planning services listed above.
Investment advisory services include assisting the client with the formulation of an investment policy, assessment of risk tolerance and selection of an asset allocation that is appropriate given the client's financial goals and objectives and risk tolerance.
As part of the investment advisory service, all aspects of the client's financial affairs are reviewed and realistic, measurable goals are set and objectives to reach those goals are defined. As goals and objectives change over time, suggestions are made and implemented on an ongoing basis. The Adviser periodically reviews a client's financial situation and portfolio through regular contact with the client which often includes an annual meeting with the client. The scope of work and fee for an Investment Advisory Agreement is provided to the client in writing prior to the start of the relationship. The agreement sets forth the services to be provided, the fees for the service and the agreement may be terminated by either party in writing at any time.
Adviser may invest your assets according to one or more model portfolios developed by an unaffiliated investment manager on a discretionary or non-discretionary basis as described below. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. Advisor also provides investment management services in which investment portfolios are actively managed and monitored. For this type of service, Advisor may assist client in establishing a custodial clearing account with Charles Schwab & Co., Inc. ("Schwab"). The assets included in this service may include no-load mutual funds, exchange-traded funds ("ETFs") and individual stocks. Each portfolio will be constructed to suit the client's needs and risk tolerances, as best as those can be determined by the Advisor. Each portfolio will be diversified using a variety of investment vehicles of differing assets classes and management styles.
Schwab accounts invested in our model portfolios are rebalanced when funds are added or distributed from the account, or when advisor thinks a rebalancing of the account is warranted due to other factors such as market fluctuation.
5 The Advisor may assist the client in establishing a custodial clearing account with SEI Investments or affiliates of SEI. Based upon the client's current financial situation, risk tolerance, time horizon and asset class preference, the Advisor and client may select from one of many mutual fund asset allocation model portfolios developed by SEI and comprised of SEI's no-load mutual funds as described below.
Advisor also provides investment management services for SEI accounts in which a separate investment portfolio is actively managed and monitored within the client's existing SEI account. A separate Advisor-Guided portfolio is established within the client's existing SEI account, which may include no-load mutual funds, exchange-traded funds ("ETFs") and individual stocks. Each Advisor- Guided portfolio will be constructed to suit the client's needs and risk tolerances, as best as those can be determined by the Advisor. Each Advisor-Guided portfolio will be diversified using a variety of investment vehicles of differing assets classes and management styles.
The Advisor-Guided portfolio within an SEI account may be rebalanced when funds are added or distributed from the account, or when advisor thinks a rebalancing

of the account is warranted due to other factors such as market fluctuation.
The SEI Mutual Fund Models part of the account is managed as outlined below under Mutual Fund Models Program. Mutual Fund Models Program: Under this program, we act as the sole adviser to your account. SEI makes available to us a selection of asset allocation models, the underlying investments of which are generally comprised entirely of mutual funds that are managed by SEI (the "Mutual Fund Allocation Models"). The Mutual Fund Allocation Models are designed (and periodically updated) by SEI to meet with a stated investment objective or goal (i.e., defensive, short-term, moderate, market growth, core, aggressive, etc.) and are not designed to meet any particular investor's specific investment needs or circumstances. When you participate in this program, we select an initial Mutual Fund Allocation Model (or Models) in which to invest your assets based upon our evaluation of your particular investment needs and circumstances. SEI will advise us of any changes to the selected Mutual Fund Allocation Model(s) used in your account. We will contact you prior to reallocating your assets to different Mutual Fund Allocation Models, in accordance with the terms of our written non-discretionary advisory agreement with you.
Investment Consulting for Retirement Plan Participants Stephenson and Company, Inc. provides investment advisory services for individual plan participants in 401(k) and deferred compensation plans. Advisory services include: Review and evaluation of investment objectives; selection of an asset allocation model which is appropriate for the client; review of all investment options offered by the plan; recommendation and selection of plan investment options; monitoring of investments selected and any new investment options added; and notification to client when changes or repositioning are appropriate.
Retirement Plan Consulting Services We offer retirement plan consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These retirement plan consulting services will generally be non- discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
6 We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of retirement plan consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the retirement plan advisory agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The retirement plan advisory fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.
Imposed Restrictions Clients may request restrictions on an investment account, such as when a client needs to keep a minimum level of cash in the account or does not want to invest in certain securities or types of securities in the account. The Adviser reserves the right to not accept and/or terminate management of a client's account if Adviser feels that the client-imposed restrictions would limit or prevent Adviser from meeting or maintaining the client's investment strategy.
Wrap Fee Programs We are not a wrap fee sponsor nor a portfolio manager to a wrap fee program. However, we may recommend that you invest in a wrap fee program sponsored by a third-party sponsor and is managed by a third-party portfolio manager. Wrap fee accounts are typically more appropriate for active accounts and are managed accordingly. If you participate in a wrap fee program, you will be provided with a separate Wrap Fee Program Brochure explaining the program and costs associated with the program. You should also review this Part 2A thoroughly to evaluate any differences between the services we offer as non-wrap versus a wrap fee program.
Types of Investments We offer advice on equity securities, mutual fund shares, exchange traded funds, corporate debt securities, certificates of deposit, municipal securities, United States government securities, real estate investment trusts ("REITs"), and money market funds. When offering advice on equity securities, our recommendations for purchasing stocks have been primarily limited to one specific stock in recent years (Berkshire Hathaway B shares). Otherwise, with respect to offering advice on equity securities, we generally advise clients on the timing of possible liquidations of existing positions in individual stocks that were previously chosen or held by clients, as opposed to purchasing more of these securities or purchasing other equity securities. Initial public offerings (IPOs) are not available through the Adviser.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
7 Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Assets Under Management As of December 31, 2023, we provide continuous management services for $197,973,835 in client assets on a discretionary basis, and $68,399,389 in client assets on a non-discretionary basis. The Adviser also oversees on a non-continuous basis approximately $95,933,725 in client assets, some of which are managed by third-party managers.