Description of Services and Fees
Bedminster L.L.C., dba The Bedminster Group (hereinafter “TBG”) is a registered investment adviser based in
Bluffton, South Carolina. We are a limited liability company, formed under the laws of the State of South Carolina.
We have been providing investment advisory services since 1997. Gene Balerna, CIMA®, is the Principal Owner of
TBG.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of
our firm, including Mr. Balerna. Such persons are properly registered as investment adviser representatives in
applicable jurisdictions where required.
Portfolio Management Services
Our firm offers discretionary portfolio management services to our clients. Discretionary portfolio management
means we will make investment decisions and place buy or sell orders in your account without first obtaining your
consent. These decisions would be made based upon your stated investment objectives. If you wish, you may
limit our discretionary authority by, for example, setting a limit on the type of securities that can be purchased
for your account. Simply provide us with your restrictions or guidelines in writing.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and help you decide how much risk you should take in your investments. The information we gather will help us
implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for
you or simply providing you with advice.
TBG does not recommend one particular type of security over other types of securities, but we do provide advice
on various types of securities, such as exchange listed equities, over the counter equities, foreign issues, American
depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities,
investment company securities (including mutual funds and exchange traded funds), US Government securities,
options contracts on securities and/or commodities, private equity instruments, return enhanced notes, and
interests in partnership investing in real estate. Additionally, will provide advice on existing investments you may
hold at the inception of the advisory relationship or on other types of investments for which you ask advice.
If you engage us for portfolio management services, we will monitor your portfolio’s performance on a continuous
basis, and rebalance the portfolio whenever necessary, as changes occur in market conditions and/or your
financial circumstances. You will also be eligible to receive the below General Consulting services as part of the
engagement, to the extent specifically requested.
General Consulting Services
TBG provides general consulting services that focus on the specific needs and concerns of the client. Advisory
consulting services may include giving advice on investment and investment related matters. These services
include the identification of financial goals and objectives, collection and assessment of all relevant data,
identification of financial problems and formulation of solutions, and the preparation of a financial plan in the
form of specific written recommendations. The services we provide will typically focus on one or more of the
following areas:
Retirement Planning: Retirement Planning is a process of determining retirement income goals and the actions
and decisions necessary to achieve those goals. Retirement planning includes identifying sources of income,
estimating expenses, implementing a savings program and managing assets. Future cash flows are estimated to
determine if the retirement income goal will be achieved.
Tax Planning: The goal of tax planning is to arrange your financial affairs so as to minimize your taxes. There are
three basic ways to reduce your taxes, and each basic method might have several variations. You can reduce your
income, increase your deductions, and take advantage of tax credits.
Investment Planning: The goal of investment planning is to determine the investment mix and policy, matching
investments to objectives, asset allocation for individuals and institutions, and balancing risk against performance.
The process realizes strengths, weaknesses, opportunities and risks in the choice of debt vs. equity, domestic vs.
international, growth vs. safety, and many other tradeoffs encountered in the attempt to maximize return at a
given risk.
Our advice is based on your financial situation and the financial information you provide to our firm. If your
financial situation, goals, objectives, or needs change, you must notify us promptly.
For standalone General Consulting clients, the engagement ends at the time the requested services are
completed. The client is exclusively responsible for implementing any accepted recommendations. Clients should
note that TBG does not monitor the client’s account once the recommendation has been provided.
Retirement Plan Consulting Services
Trustee Directed Plans. TBG may be engaged to provide discretionary investment advisory services to retirement
plans, whereby TBG shall manage the plan assets consistent with the investment objective designated by the plan
trustee(s). In such engagements with qualified plans, TBG will serve as an investment fiduciary and an investment
manager, as those terms are defined under The Employee Retirement Income Security Act of 1974 (“ERISA”)
Sections 3(21) and 3(38), respectively. TBG will generally provide services on an “assets under management” fee
basis per the terms and conditions of an Investment Advisory Agreement between the plan and TBG.
Participant Directed Retirement
Plans. TBG may also provide investment advisory and consulting services to
participant-directed retirement plans per the terms and conditions of a Retirement Plan Services Agreement
between TBG and the plan. To the extent requested by the client, TBG can assist the plan sponsor with the
selection of an investment platform from which plan participants shall make their respective investment choices
(which may include investment strategies devised and managed by TBG), and, to the extent engaged to do so,
may also provide corresponding education to assist the participants with their decision-making process.
Client Retirement Plan Assets. TBG may also be engaged provide investment advisory services relative to 401(k)
plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer.
In such event, TBG shall allocate (or recommend that the client allocate) the retirement account assets among
the investment options available on the 401(k) platform. TBG’s ability shall be limited to the allocation of the
assets among the investment alternatives available through the plan. TBG will not receive any communications
from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify TBG of any
changes in investment alternatives, restrictions, etc. pertaining to the retirement account.
Wrap Fee Programs
We do not sponsor, manage, or participate in any wrap fee programs.
IRA Rollover Considerations
As part of our investment advisory services to you, we may recommend that you withdraw the assets from your
employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will
manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, we will charge
you an asset-based fee as set forth in the agreement you executed with our firm. This practice presents a conflict
of interest because persons providing investment advice on our behalf have an incentive to recommend a rollover
to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are
under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the
rollover, you are under no obligation to have the assets in an IRA managed by our firm.
Many employers permit former employees to keep their retirement assets in their company plan. Also, current
employees can sometimes move assets out of their company plan before they retire or change jobs. In
determining whether to complete the rollover to an IRA, and to the extent the following options are available,
you should consider the costs and benefits of:
An employee will typically have four options:
• Leaving the funds in your employer's (former employer's) plan.
• Moving the funds to a new employer’s retirement plan.
• Cashing out and taking a taxable distribution from the plan.
• Rolling the funds into an IRA rollover account.
Each of these options has advantages and disadvantages and before making a change we encourage you to speak
with your CPA and/or tax attorney.
If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to
consider before you do so:
1. Determine whether the investment options in your employer's retirement plan address your needs or
whether you might want to consider other types of investments.
a. Employer retirement plans generally have a more limited investment menu than IRAs.
b. Employer retirement plans may have unique investment options not available to the public such
as employer securities, or previously closed funds.
2. Your current plan may have lower fees than our fees.
a. If you are interested in investing only in mutual funds, you should understand the cost structure
of the share classes available in your employer's retirement plan and how the costs of those
share classes compare with those available in an IRA.
b. You should understand the various products and services you might take advantage of at an IRA
provider and the potential costs of those products and services.
3. Our strategy may have higher risk than the option(s) provided to you in your plan.
4. Your current plan may also offer financial advice.
5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required
minimum distribution beyond age 70.5.
6. Your 401k may offer more liability protection than a rollover IRA; each state may vary.
a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets
have been generally protected from creditors in bankruptcies. However, there can be some
exceptions to the general rules so you should consult with an attorney if you are concerned
about protecting your retirement plan assets from creditors.
7. You may be able to take out a loan on your 401k, but not from an IRA.
8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may
also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability,
higher education expenses or the purchase of a home.
9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains
tax rate.
10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name.
It is important that you understand the differences between these types of accounts and to decide whether a
rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative,
or call our main number as listed on the cover page of this brochure.
Assets Under Management
As of December 31, 2023, we had approximately $164,268,600 in discretionary assets under management and $0
in non-discretionary assets under management.