Ownership and Mission
Stakeholders Capital, Inc. ("Stakeholders Capital") is a registered investment adviser primarily based in
Amherst, Massachusetts. We are organized as a corporation under the laws of the Commonwealth of
Massachusetts. We have been providing investment advice since 2009. The company currently has
four shareholders: Andrew Bellak, Terry Mollner, Eileen Spira and Brad Stonberg. Mr. Bellak is the
majority shareholder of the company.
Stakeholders Capital's mission is to provide wealth planning and investment management services to
individuals, families, non-profits, estates, trusts, and corporations. We specialize in Socially
Responsible Investing ("SRI"), community investing, impact investing, and ethical investing.
Stakeholders Capital provides financial advice that allows people to invest in companies that reflect
their values, risk profile and time horizon to meet their financial objectives.
Services Available
Stakeholders Capital provides fee-only, comprehensive investment management services. Our
purpose is to help you create, grow, protect and disburse wealth. We achieve this by understanding
client goals, creating a plan to achieve those goals and practicing disciplined asset allocation. We
believe in a portfolio of assets that fits your risk profile. Matching your time horizon and risk tolerance
with your overall objectives is our goal. Stakeholders Capital offers different services depending on
your needs:
Continuous Investment Management for Assets under Management ("AUM") Accounts
Stakeholders Capital's primary focus is to provide clients with on-going, continuous investment
management. We analyze existing portfolios, establish or assess financial goals and objectives, and
make recommendations. In accordance with the clients' risk profile and investment goals, we
recommend securities, buy and sell them, and monitor their performance through the investing cycle.
Every client has a unique portfolio guided by his or her individual Investment Policy Statement. We
consider all client assets to provide a holistic investment approach for your regulatory assets under
management. This may include the use of margin or options transactions if consistent with the client's
stated tolerance for risk. Because margin and options involve a certain degree of additional risk, it will
only be recommended when consistent with the client's stated tolerance for risk. Clients receive an
independent statement of the portfolio directly from the custodian.
We offer discretionary portfolio management services. Our investment advice is tailored to meet our
clients' needs and investment objectives as discussed above.
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 the appropriate trading authorization forms.
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.
4
We may also offer non-discretionary portfolio management services. 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.
Consultative Financial Planning
There are times in life when you come to a financial crossroad. How should we pay for college? How
much money do we need to accumulate in order to retire? What should I do with my old 401k? What
investments should I be choosing in my new one? These types of questions are best answered in a
financial planning engagement. This type of advice is provided in our service to our Asset Under
Management ("AUM") clients. For other clients, Stakeholders Capital offers these services in a
consultative engagement format.
Investment Adviser Representatives of
Stakeholders Capital engage in hourly financial planning and
provide life and health insurance to clients on a commission basis. Investment Adviser
Representatives of Stakeholders Capital have an incentive to recommend insurance products to you
for the purpose of generating commissions rather than solely based on your needs.
However, you are under no obligation, contractually or otherwise contractually or otherwise to
purchase insurance products through our Investment Adviser Representatives or Stakeholders Capital.
Selection of Other Advisers
We may recommend that you use the services of a third party money manager ("TPMM") to manage
all, or a portion of, your investment portfolio. After gathering information about your financial situation
and objectives, we may recommend that you engage a specific TPMM or investment program. Factors
that we take into consideration when making our recommendation(s) include, but are not limited to, the
following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals,
risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its
management and investment style remains aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority
over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate
your assets to other TPMM(s) where we deem such action appropriate.
Types of Investments
We offer advice on equity securities, mutual funds, ETFs, and certain index options, as well as other
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.
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.
Wrap Fee Programs
Stakeholders Capital is not a portfolio manager of, nor a sponsor of, wrap fee programs. Our clients
may participate in wrap fee programs through the use of third party money managers. (See disclosure
above regarding Selection of Other Advisers).
5
IRA 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 and regulations
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 February 28, 2023, we provide continuous management services for $130,283,246 in client
assets on a discretionary basis, and $15,405,969 in client assets on a non-discretionary basis.