A. Charleston Investment Advisors, LLC (the “Adviser,” “we,” “us,” or “our”) is an investment adviser
founded in 2019, registered with the U.S. Securities and Exchange Commission (“SEC”), and is
principally owned by Stephanie Mackara.
Investment Management
Adviser implements asset-class allocation programs approved by clients, typically utilizing a
group of no-load mutual funds and exchange traded funds (“ETFs”), as well as individual bonds
when appropriate for the client. Adviser typically recommends the advisory and administrative
services of Buckingham Strategic Partners LLC (referred to herein as “Buckingham” or the
“Platform Provider”) to its clients, and also leverages their investment and research team. Clients
are under no obligation to implement the asset allocation programs developed by Adviser, and
may specify other investment strategies and restrictions upon opening an account or at any time
thereafter. Clients pre-authorization to Adviser to trade the approved mutual funds, ETFs and any
individual securities that may be held in the account. A client who establishes an account with
Adviser must agree that the risks of such account are borne solely by the client.
Adviser provides a variety of services to its clients either directly or through the Platform Provider,
including but not limited to quarterly reporting, fee reporting and debiting, transaction data
processing, and proposed portfolio construction. As part of its portfolio management services,
Adviser offers periodic portfolio rebalancing designed to keep portfolios consistent with the client’s
desired asset allocation target amounts within Adviser’s usual and customary target parameters.
If the client elects to use Adviser’s portfolio management services, Adviser will generally review
accounts for rebalancing on a quarterly or annual basis to the allocation target in each
asset-class agreed upon by the client. Adviser or the Client may elect not to rebalance because
the funds involved are economically insufficient, additional fees and expenses are anticipated, or
there may be other pending events that would impact the decision. Through the Platform
Provider, Adviser will also provide a mechanism for collection of investment advisory fees from
clients payable to Adviser.
All client accounts are managed and/or administered on a non-discretionary basis pursuant to
instructions received from the client pursuant to a limited power of attorney.
For clients receiving Investment Management Services, Adviser generates a personalized
investment policy statement based on information provided by the client. That information
includes suitability information (income, age, investment net worth, risk tolerance, investment
objectives, etc.) and other variables. Adviser also retains the ability to present multiple historic
simulations to help the client determine the investment allocation that Adviser believes is most
appropriate for the client’s stated goals. On an ongoing basis, Adviser monitors client transactions
and utilizes the Platform Provider’s research and practice management resources, as well as
educational resources intended for Adviser or Clients.
ERISA Plan Services
Adviser additionally provides retirement plan services to defined contribution and benefit plans
subject to the Employee Retirement Income Security Act of 1974 (“ERISA”) consisting of
investment advisory and administrative services provided in conjunction with the Platform
Provider. Fiduciary and non-fiduciary services are provided in conjunction with independent
recordkeepers, third-party administrators, custodians, and other unaffiliated service providers.
Plan assets are maintained in accounts held by certain independent and unaffiliated
broker-dealer custodians and have the ability to hold assets not managed by Adviser on an
accommodation-only basis. Subject to the paragraph below and the agreement that plans sign
with Adviser, Adviser serves as a fiduciary to such plans pursuant to Sections 3(21)(A)(i) of
ERISA when providing the specifically-enumerated fiduciary services.
Adviser, at times through affiliated or unaffiliated service providers, offers recommended asset
allocations to plans and/or plan participants utilizing model portfolios or a lineup of
approved
mutual funds. Funds or securities not approved or recommended by Adviser are permitted to be
held with a plan or plan participant’s account; however, Adviser does not act as a fiduciary to a
plan pursuant to Section 3(21)(A)(i) of ERISA for plan assets not invested in a model portfolio or
approved mutual fund or money market fund.
Advisory Consulting Services
Adviser additionally provides separate Advisory Consulting Services in addition to or apart from
investment management services. Advisory Consulting Services are typically provided on a
negotiated basis based upon a defined series of goals and objectives, and are either delivered as
part of a one-time consultation, report or analysis or as part of an ongoing series of consultations,
reports, and analyses. After assessing a client’s current financial situation and goals, and if
agreed-to between Adviser a client, Adviser will deliver a written financial plan that includes an
assessment of the client’s financial life and various action items for the client to implement or fulfill
ongoing consultative services and deliverables as agreed to between the client and Adviser.
Topics addressed as part of Advisory Consulting Services can include, but not necessarily be
limited to the following:
●Lifestyle goals
●Retirement goals
●Gap Analysis including investment analysis and areas of opportunity
●Savings goals (short term, medium and long term goals)
●Retirement Benefits optimization review
●Asset protection planning and insurance analysis
●Lifetime Income Analysis
●Tax planning tips
●Social Security analysis
●Asset location strategy
●Asset and Liability review
●Net worth statement
●Online account access and data aggregation
●Coordinated meetings with your other professional advisors (i.e. CPAs, attorneys, etc.)
Clients are ultimately responsible for implementing any recommended action items as part of
Advisory Consulting Services unless the client separately retains Adviser to perform investment
management services.
Adviser tailors its advisory services to the individual needs of its clients by taking the time to
understand clients’ current financial condition, goals, risk tolerance, income, liquidity
requirements, investment time horizon, and other information that is relevant to the management
of clients’ account(s). This information will then be used to make investment recommendations
that reflect clients’ individual needs and objectives on an initial and ongoing basis. Adviser’s
recommendations will allocate portions of clients’ account(s) to various asset classes classified
according to historical and projected risks and rates of return. Adviser will review all such
recommendations with clients, and clients will have the opportunity to accept or reject any
recommendations. Clients are under no obligation to accept or implement any recommendation
made by Adviser. Clients may impose restrictions on investing in certain securities or types of
securities so long as such restrictions may reasonably be implemented by Adviser.
B. 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 ERISA and/or the Internal
Revenue Code (the “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:
a. Meet a professional standard of care when making investment recommendations (give
prudent advice);
b. Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
c. Avoid misleading statements about conflicts of interest, fees, and investments;
d. Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
e. Charge no more than is reasonable for our services; and
f.Give you basic information about conflicts of interest.
C. Adviser does not participate in any wrap fee programs.
D. As of December 31, 2022, Adviser manages $138,220,831 in client assets on a non-discretionary
basis and $0 on a discretionary basis.