Effective March 31, 2025
ADV Part 2A & 2B
Part 2A of Form ADV Brochure for:
Evergreen Wealth Advisors Corporation
Office Addresses:
305 Church at North Hills St, Suite 1250
Raleigh, NC 27609
Telephone: +1 (888) 884-0557
7700 Windrose Ave.,
Office Number 02-127
Plano, TX 75024
Telephone:
+1 (888) 884-0557
Mailing Address:
5540 Centerview Dr., Ste 204 PMB #48153
Raleigh, NC 27606
March 31, 2025
This Brochure provides information about the qualifications and business practices of Evergreen Wealth Advisors Corporation (“Evergreen Wealth Advisors” or “Evergreen” or the “Advisor”). If you have any questions about the contents of this Brochure, please contact the Advisor at the telephone number or addresses listed above. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
Evergreen is a registered investment adviser with the SEC. Registration of an investment adviser does not imply any certain level of skill or training.
Additional information about Evergreen is also available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Material Changes
This Brochure provides Clients with a summary of Evergreen’s advisory services and fees, certain business practices and policies, professionals, as well as actual or potential conflicts of interest, among other things. This Item is used to provide the Clients (as defined below) with a summary of new and/or updated information; the Advisor will inform Clients of the revision(s) based on the nature of the information as follows.
- Annual Update: The Advisor is required to update certain information at least annually, within 90 days of the Advisor’s fiscal year end (“FYE”) of December 31. The Advisor will provide Clients with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of the Advisor’s FYE or the Advisor will provide each Client with a revised Brochure with a summary of those changes in this Item.
- Material Changes: Should a material change in the Advisor’s operations occur, depending on its nature the Advisor will promptly communicate this change to Clients (and it will be summarized in this Item).
This Brochure is being updated as part of the annual amendment. The following changes were made to this Brochure since the last other than annual amendment filing, dated January 2, 2025.
- Item 4 - Advisory Business - Description of Evergreen’s Wealth Management Advisory Services have been clarified to align with current product offerings as of this filing. Overview provided for Financial Planning services available to Clients.
- Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss - Detail provided around Evergreen’s updated advisory offering and how advice is formulated under the Investment Advisory Agreement. Corresponding risks are also updated in this section.
- Item 14 - Client Referrals - details on client referral arrangements with Promoters have been provided. Evergreen will pay a flat fee to each Promoter to receive client referrals in the form of an initial introduction to interested consumers. The fees paid by Evergreen to the Promoters are paid irrespective of whether such a consumer becomes a Client. Clients will not pay any increased fee to us as a result of the arrangement.
Item 3 – Table of Contents
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 14 – Client Referrals and Other Compensation
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Part 2B of Form ADV Brochure Supplement
Part 2B of Form ADV Brochure Supplement - Appendix 1
Item 4 – Advisory Business
A. Description of the Advisory Firm
Evergreen Wealth Advisors (“Evergreen” or the “Advisor”) is a Delaware corporation and is a wholly owned subsidiary of Evergreen Wealth Corporation. The Advisor was originally formed in 2023. The controlling ownership of the Advisor resides with Bill Harris, Chief Executive Officer.
Evergreen is an investment adviser registered with the SEC. Evergreen was formed to provide holistic digital wealth advisory services encompassing cash management, investment advisory, and portfolio management services to individuals, high-net-worth individuals, and corporations.
Advisory services are offered under an Investment Advisory Agreement and are outlined below.
B. Types of Advisory Services
Evergreen Wealth Advisors provides ongoing holistic advisory services to Clients (each a “Client” and collectively the “Clients”) on a fully discretionary basis. Clients who enter into an Evergreen Client Agreement (“investment Advisory Agreement”) will have access to Bank Accounts offered through Evergreen’s bank sponsor and Investment Accounts that include Evergreen’s portfolio management solution as defined below, as well as Financial Planning assistance. The Bank Accounts and Investment Accounts have minimum deposit amounts (as noted in Item 7). Evergreen also offers access to charitable giving programs through unaffiliated third parties.
Evergreen Wealth Corporation, parent company of Evergreen Wealth Advisors, provides certain technologies and administrative actions to assist with the management of Evergreen Clients. Evergreen Wealth Corporation is a financial technology company, not a bank.
Cash Management - Checking and Savings
High Yield Checking (“HYC”) and High Yield Savings (“HYS”) Accounts (collectively, “Bank Accounts”) are offered as a Cash Management solution through our unaffiliated bank sponsor, Coastal Community Bank (“Coastal”). The cash balance in Client’s cash management accounts earns a variable rate of interest and is eligible for Federal Deposit Insurance Corporation (“FDIC”) insurance through pass-through FDIC insurance provided by Coastal Community Bank, Member FDIC. Evergreen will provide ongoing and continuous cash management advisory services over the accounts as outlined in the Investment Advisory Agreement.
Although Clients do not pay a fee for cash management accounts, Evergreen is incentivized to direct Clients to open a brokerage account and allocate available cash to an Investment Account that charges an asset based fee. This creates a potential conflict of interest however, it is Evergreen’s fiduciary responsibility to individually assess all Client factors such as investment objectives and Client instructions to determine if it is in a Client’s best interest to open an Investment Account.
Investment Accounts - Evergreen Personal Portfolios
Evergreen provides investment management to its Clients on a fully discretionary basis through Evergreen Personal Portfolios (“Personal Portfolio”). As such, Personal Portfolios are professionally managed accounts in which all expenses and administrative costs are “wrapped” into a single management fee. Per the Investment Advisory Agreement, Evergreen has discretionary authority to select brokers or dealers for executing purchase and sales of securities transactions for Personal Portfolios.
Client’s investment objectives are established through Evergreen’s risk tolerance and suitability questionnaire, additional information obtained about the Client, and additional communications with the Client. Evergreen Client portfolios are managed based on the investment objectives of the Client and the investment principles of Evergreen. Clients will receive continuous and regular supervisory or management services of all assets held in their accounts on Evergreen’s platform.
Certain factors such as age, financial circumstances, investment objectives, risk tolerance, investing experience, tax filing status, household income, investable assets, net worth, state of residence, and other pertinent data may assist Evergreen to determine a Client’s diversified investment allocation consisting primarily of individual securities (including publicly traded stocks, bonds, exchange traded funds, money market mutual funds, and government securities).
Once the optimal allocation is determined by Client driven factors, Evergreen has the discretionary authority to implement the allocation in the Client’s portfolio. Portfolio rebalancing is conducted at Evergreen Wealth's discretion to balance drift from target allocations with potential tax savings as a result of changing market conditions or Client circumstances. Portfolios may also be rebalanced when a large deposit or withdrawal requires the purchase or sale of a significant dollar amount of securities in the Client’s accounts. Overall, portfolio rebalances occur in an effort to align with Client’s investment objectives while optimizing returns for the intended level of risk and focusing on tax savings.
Although Clients will pay the advisory fee as prescribed below for Investment Accounts, Evergreen is incentivized to direct Clients to allocate available cash to an investment portfolio. This creates a potential conflict of interest; however, it is Evergreen’s fiduciary responsibility to individually assess all Client factors such as investment objectives, Client instructions, and cash management requirements to determine if it is in Client’s best interest to allocate funds to Investment Accounts.
Donor Advised Funding - Personal Foundation
Evergreen facilitates access to donor-advised fund (“DAF”) accounts aimed to assist Clients with their philanthropic goals while considering tax implications. The DAF account program allows Clients to contribute cash or eligible securities to a charitable account, potentially realizing tax benefits in the year the contribution is made. Once a contribution is accepted, it is irrevocable and non-refundable, and becomes the legal property of the DAF sponsor.
Evergreen receives no compensation or benefits related to this arrangement. If a Client were to terminate their relationship with Evergreen while an allocation to a DAF was in place, Evergreen would prorate the final month of the Client fee and the Client would be responsible for the DAF fee going forward.
Evergreen does not provide tax, legal or accounting advice. Before engaging in any charitable giving program, Clients should review carefully the terms and conditions of the DAF sponsor and consult with their tax, legal, and accounting advisors regarding their individual situation.
Financial Information and Planning
Evergreen may offer financial information and planning on multiple investing, tax and financial planning topics at the Client’s request. This information and planning (i) may be delivered by our financial advisors or directly to our Clients via website, app, blog, email, SMS, social post and other channels, (ii) may be general in nature or personalized to the Client, (iii) may be developed by Evergreen, third-party sources, our financial advisors, or AI tools, and (iv) may be delivered in text, audio, video or generative AI formats.
Evergreen provides tax-aware investment management services but does not provide tax, legal or estate planning advice. Clients are encouraged to review any tax or estate related decisions with their tax preparer, accountant or attorney.
C. Client Tailored Services and Client Imposed Restrictions
Advisory services are tailored to achieve the Clients’ investment objectives which are established through Evergreen’s risk tolerance and suitability questionnaire, additional information obtained about the Client, and additional communications with the Client.
Clients have the ability to impose reasonable restrictions on Evergreen’s management. If an investment restriction is fundamentally inconsistent with Evergreen’s recommended allocation, Evergreen reserves the right to reject a new Client account or terminate an existing Client.
D. Wrap Fee Programs
Evergreen’s entire advisory business sponsors a single Wrap Fee Program (“the Program”). Access to the Program is available and required for all Clients of Evergreen. Clients participating in the Program will pay a “Wrap Fee,” meaning that Clients will pay a single management fee to the Advisor which will encompass the investment management services provided by the Advisor as well as the brokerage and transaction costs associated with the purchase and sale of securities in the Accounts. The Wrap Fee will be calculated as a percentage of the Assets Under Management (or “AUM”) in the Client’s Investment Accounts and exclude balances from High Yield Checking and High Yield Savings Accounts. The fee percentage may differ based upon the type of assets, the size of the Client’s relationship, and/or any promotional or negotiated reductions. Brokerage services of the Program are facilitated by Evergreen’s Clearing Brokers.
The associated fees of the wrap fee program are detailed below in Item 5.
E. Assets Under Management
As of December 31, 2024, Evergreen has approximately $107,622,368 of assets under management on a discretionary basis and $0 of Client assets on a non-discretionary basis.
Item 5 – Fees and Compensation
Our Investment Advisory Agreement establishes the specific manner in which the Advisor charges fees. Fees are calculated as a percentage of the assets under management held in Investment Accounts.
A. Advisory Fees and Compensation
Evergreen provides fully discretionary investment management services as part of the Evergreen Wrap Fee Program. Under the Program and Evergreen’s advisory agreement, participants receive advisory cash management and discretionary investment management services for a specified annual management fee which is billed based on assets held in Client Investment Accounts and excludes balances held in High Yield Checking and High Yield Savings Accounts. Evergreen will pay for applicable securities transaction fees, custodial costs, SEC exchange process fees, administrative fees, and other fees and expenses related to the management of Client accounts.
The Wrap Fees charged by Evergreen may be more or less expensive than if the Client were to enter an arrangement to pay a management fee and brokerage fees separately at other financial institutions based on the total assets under management and the volume of trading conducted in the account. Depending on the frequency and volume of trades in a Client account, Evergreen may receive all, a portion, or none of the Wrap Fee charged as compensation for its investment advisory services.
The Wrap Fee is inclusive of all investment management fees charged by the Advisor, and all brokerage and transaction fees associated with the investing of Accounts.
The range of compensation paid by Clients is generally as follows based on the account type and average daily balance of the assets under management held in each Investment Account at the end of each calendar month.
| Management Fee Based on Account Type(s) Held by Client | |||
| Account Type | Value of Assets |
Monthly AUM Fee |
Annual AUM Fee |
| Investment Accounts |
First $500,000 |
.08% | .96% |
|
Next $500,000 (over $500K up to $1M) |
.07% | .84% | |
|
Next $4,000,000 |
.06% | .72% | |
|
Next $5,000,000 |
.05% | .60% | |
|
Assets over $10,000,000 |
Relationship pricing upon request | ||
|
*Excludes balances from High Yield Checking and High Yield Savings Accounts |
|||
Evergreen, from time to time and in its sole discretion, can reduce or waive the monthly fee for individual Clients or segments of Clients. Evergreen reserves the right to reduce or negotiate fees with individual Clients and may offer incentives or discounts to Clients based on specific factors including but not limited to the size of the account, the length of the relationship, affiliation to the Advisor, or the Client’s engagement with the Advisor’s affiliates or participation in a promotional or application testing program.
B. Payment of Fees
Based on the account types held by the Client and as well as established in the Investment Advisory Agreement with Evergreen, the Fee will be collected monthly by direct debit from Client accounts in arrears based on the average daily balance and the number of days the account was open during the month. Evergreen reserves the right to collect Fees from any account held by the Client at Evergreen Wealth and in some instances, noncash assets may also be required to be sold to enable the Fee to be deducted from Client accounts.
Investment Management Fees charged as a percentage of assets under management are based on the average of daily account balances provided by the Clearing Broker. Evergreen calculates the appropriate Fee based on the type of accounts, average daily balance of the assets under management, and sends the Fee invoices directly to the respective Clearing Broker to debit the Fee from the appropriate Client account.
For Clients maintaining a Personal Portfolio balance, Evergreen will sell securities in an amount that will generate cash proceeds to satisfy a Client’s Fee obligation by the fifteenth of each month. Evergreen will automatically debit the prorated amounts of the Fees from the assets in a Client’s account on a monthly basis in arrears.
Accounts are billed at the corresponding Fee schedule indicated above as well as noted on the Investment Advisory Agreement. The Clearing Broker does not check the Fee calculation, percentage or amount to be deducted, so the Client is responsible for reviewing Fee deductions shown on account statements and informing Evergreen of any suspected errors.
C. Additional Fees and Expenses
Client accounts invested into ETFs and money market funds will pay additional Fees and expenses charged by those investment vehicles, in addition to the Wrap Fee assessed by the Advisor. The Advisor will take into consideration the Fees and expenses charged by an investment vehicle when considering the appropriateness for the Client.
D. Prorated and Prepayment of Fees
Under no circumstances does Evergreen require or solicit payment of Fees in advance of services rendered.
The Investment Advisory Agreement between Evergreen and Clients may be terminated by either party pursuant to the terms and conditions of the Investment Advisory Agreement. There will be no Fees for termination of a Client, but Clients may be charged Fees by the Clearing Brokers to liquidate and transfer assets in accordance with the corresponding written account agreements.
Accounts initiated or terminated during a billing period will be charged a prorated Fee based on the number of days the account was open during the month. Upon termination or full liquidation of any account, any prepaid, unearned Fees will be promptly refunded, and any earned, unpaid Fees will be due and payable.
E. Additional Compensation and Conflicts of Interest
For Cash Management Accounts, the variable rate of interest is determined and paid to Clients by Evergreen. Coastal receives a nominal percentage of the variable rate of interest set by Evergreen of Client deposits which is ultimately determined by the Federal Funds Rate.
Additionally, as HYC Accounts include a Visa Debit Card for payment transactions, Visa’s Digital Payment Solutions (DPS) typically charges vendors a Fee for each transaction processed through its network. Although the transaction Fee is typically borne by the vendor, the cost of goods can indirectly affect customers.
Item 6 – Performance-Based Fees and Side-By-Side Management
Evergreen does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a Client). The Advisor manages multiple Client accounts, including accounts with different fee arrangements. The management of multiple Client accounts creates a conflict of interest because the Advisor may have an incentive to favor one Client account over another.
Item 7 – Types of Clients
Evergreen provides investment advisory services to high net worth individuals, individuals, and business entities. A Client may establish a Bank Account or Personal Portfolio prior to funding the accounts, however, Evergreen requires a minimum of $25,000 on the Evergreen platform for the Client to utilize a Bank Account and a minimum of $250,000 on the Evergreen platform for the Client to utilize a Personal Portfolio. At our discretion, Evergreen may waive the minimum account size or deposit amounts. Evergreen reserves the right to terminate the relationship in accordance with the provisions of the account agreement.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Evergreen Wealth provides fully managed investment portfolios tailored to each Client's specific financial situation and investment objectives. Our investment approach begins with a Client assessment to ensure all portfolios are suitable to the Client’s investment objectives. Except in special circumstances, portfolios are broadly diversified across hundreds of securities, including equities, fixed income instruments, and cash equivalents. While the specific allocation varies by Client, our investment strategy typically emphasizes equity holdings to pursue long-term growth objectives and tax optimization opportunities.
Our tax optimization strategies are customized to each Client's unique tax situation and may include tax loss harvesting to offset capital gains, tax-advantaged accounts, strategic asset location across taxable and tax-advantaged accounts, systematic gain deferral techniques to minimize current-year tax liabilities, and incorporation of tax-exempt securities such as municipal bonds for Clients in higher tax brackets. These strategies are customized according to individual Client needs to enhance after-tax returns while maintaining alignment with overall investment objectives.
Portfolio rebalancing is conducted at Evergreen Wealth's discretion to balance drift from target allocations with potential tax savings as a result of changing market conditions or Client circumstances.
B. Investment Strategies
Evergreen's investment methodology is rooted in Modern Portfolio Theory (“MPT”), a Nobel Prize-winning framework that provides the foundation for our portfolio construction and management approach. MPT establishes that an optimal portfolio can be constructed by maximizing expected returns for a given level of risk through strategic diversification using a large number of securities across multiple asset classes. We combine MPT with tax reduction strategies to attempt to deliver portfolios which simultaneously align with the Client’s investment objectives and aim to reduce current and future income taxes on the Client’s portfolio.
Key strategies for Personal Portfolios include:
Custom Portfolio Construction: Evergreen builds custom portfolios based on securities from a diversified index and are tailored to individual Client preferences. This allows us to maintain exposure to a diversified set of securities while customizing for a variety of factors.
Diversification: Diversification is a cornerstone of our investment approach. The Advisor allocates assets across various sectors, styles and asset classes to reduce risk. By spreading investments across a broad set of securities, we seek to mitigate volatility and enhance risk-adjusted returns.
Tax Loss Harvesting: Evergreen attempts to offset capital gains by selling tax lots that have declined in value, which can reduce Client’s overall tax liability. Tax loss harvesting is an ongoing process that is employed across the portfolio to minimize taxable gains while limiting drift from the target asset allocation.
Gain Deferral: To minimize the impact of capital gains taxes, Evergreen generally avoids selling tax lots with unrealized capital gains (i) for at least twelve months from the date of purchase to avoid short-term capital gains treatment and (ii) indefinitely unless a sale is required to raise funds or reduce the drift from the target asset allocation.
Asset Location: Evergreen attempts to place securities into taxable and tax-advantaged accounts in a manner that optimizes after-tax returns. This typically involves placing capital-gain-assets preferentially in taxable accounts and ordinary-income-assets preferentially in tax deferred accounts.
Tax Advantaged Accounts: Evergreen assists Clients in the use of tax-advantaged vehicles such as IRAs and Roth accounts when appropriate. These accounts offer various tax benefits including tax-deferred growth, tax-free growth, or immediate tax deductions.
Tax Exempt Securities: For Clients in higher tax brackets, Evergreen may recommend tax-exempt Treasury or municipal bonds as a part of their diversified portfolio. This approach helps to minimize taxable income while providing necessary portfolio diversification.
Charitable Giving: For Clients who wish to incorporate philanthropy into their financial plans, the Advisor offers strategies for donating appreciated securities to qualified charitable organizations. This allows Clients to avoid capital gains taxes on the donated assets while receiving a charitable deduction, creating a tax-efficient way to give.
C. Risks of Investments and Strategies Utilized
Evergreen’s strategies are subject to investment and system risks; therefore, Clients may lose money. There can be no assurance that any of the strategies will be successful in meeting the Client’s investment objective as investing in securities involves risk of loss that Clients should be prepared to bear. The following list of risk factors does not purport to be a complete enumeration or explanation of every risk involved in an investment with Evergreen. Clients should read the entire Brochure, investment agreement and other materials that may be provided by Evergreen. Generally, Evergreen’s strategies will be subject to the following risks:
Market Risk. All investments involve the risk of loss, and securities held in Client portfolios are subject to various market risks that may cause their value to fluctuate. The prices of equity securities, including common and preferred stocks, warrants, exchange-traded funds (ETFs), mutual funds, and other securities, may rise or fall based on company performance, industry trends, general market conditions, and investor sentiment. ETFs are also subject to risks related to liquidity, tracking error, and management fees that may affect their performance relative to the underlying index or assets they seek to track.
Markets can experience periods of significant volatility due to changing interest rates, inflation, geopolitical events, fiscal and monetary policy decisions, and broader economic developments.
Investing in foreign and emerging markets introduces additional considerations, including political and economic instability, currency fluctuations, limited regulatory oversight, and differences in financial reporting and disclosure standards. Emerging markets, in particular, may be more susceptible to abrupt and severe price declines, limited liquidity, and government intervention. These factors can contribute to increased volatility and potential losses in Client accounts.
Factor Risk. Factor risk is the possibility that securities with similar attributes (such as industry, size, style, geography, volatility, maturity or asset class) may decline in price due to factor-specific market or economic developments. If a portfolio invests more heavily in a particular factor, the value of its shares may be sensitive to factors and economic risks that specifically affect that factor.
Cybersecurity Risk. The Advisor and its key service providers (including custodians, broker-dealers, and banks) rely on technology systems that may be vulnerable to cybersecurity threats. These include hacking, data breaches, system failures, and other disruptions that could compromise Client data, delay transactions, or disrupt operations. Such incidents may result in financial loss, regulatory consequences, or reputational damage. Similar risks apply to companies in which Clients invest, potentially affecting investment performance. While the Advisor has implemented controls to manage these risks, no system is fully immune to cyber threats.
Risk of Health Crises and Other Disruptive Events. Events such as pandemics, natural disasters, terrorism, and geopolitical conflict can disrupt global markets and the operations of the Advisor and its service providers. These disruptions may impair trading, valuation, and other investment-related activities, and may negatively impact the performance of Client portfolios. Broader economic effects from such events may also reduce the value of investments or increase volatility.
Software Risk. Evergreen delivers many of its investment advisory services through software. Consequently, Evergreen rigorously designs, develops and tests its software extensively before putting such software into production with actual Client Accounts and assets and periodically monitors the behaviors of such software after its deployment. Notwithstanding this rigorous design, development, testing and monitoring, it is possible that such software may not always perform exactly as intended or as disclosed on the Site, mobile app, blogs or other Evergreen disclosure documents, especially in certain combinations of unusual circumstances. Evergreen continuously strives to monitor, detect and correct any software that does not perform as expected or as disclosed.
Artificial Intelligence Risk. Evergreen may use artificial intelligence (“AI”) tools to support investment research, portfolio management, wealth management advice, and business operations. While AI has the potential to enhance efficiency and insight, it may also generate inaccurate, incomplete, or biased outputs. Reliance on flawed AI-generated content could lead to errors in investment decisions, negatively affecting Client portfolios. In addition, rapid changes in AI technology or its adoption by competitors may impact the Advisor’s ability to adapt or remain competitive. Mismanagement or misuse of AI could also result in legal, operational, or reputational risks.
Tax Optimization Risk. Clients should consult their personal tax advisor to understand the tax implications of investing with the Advisor and using tax optimization strategies, as outcomes depend on individual circumstances. Taxes should not be the sole driver of investment decisions. Clients and their tax advisors are responsible for how transactions are reported to the IRS or other tax authorities. Tax outcomes are not guaranteed and may be challenged by the IRS. The Advisor does not provide tax advice and assumes no responsibility for tax consequences, including capital gains or wash sales resulting from tax-loss harvesting.
As a result of tax optimization, the Client’s actual allocations and securities may differ from the target allocations and securities, which may result in pre-tax performance that is better or worse than the target allocations and securities would have generated. Evergreen’s tax optimization is generally limited to the securities within the Client’s Personal Portfolio; therefore, it may not take into account any securities held elsewhere or any tax considerations outside of the Client’s Personal Portfolio.
Item 9 – Disciplinary Information
The Advisor and its management persons have not been a party to any legal or disciplinary events that would be material to a Client’s or prospective Client’s evaluation of its investment advisory business or the integrity of its management.
Item 10 – Other Financial Industry Activities and Affiliations
A. Registration as a Broker-Dealer or Broker-Dealer Representative
Neither the Advisor nor its management persons are registered as a broker-dealer or broker- dealer representative.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Adviser
Neither the Advisor nor its management persons are registered as futures commission merchant, commodity pool operator, or a commodity trading adviser.
C. Relationships Material to this Advisory Business and Possible Conflicts of Interest
As mentioned previously, Evergreen Wealth Corporation is the parent company of the Advisor and provides banking services to Clients. Only those Clients participating in the Evergreen Wealth Corporation banking services are eligible to participate in the Advisor’s investment advisory services, unless otherwise agreed upon by the Client and the Advisor.
D. Selection of Other Advisors or Managers
The Advisor does not utilize nor select other advisors or third-party managers. All assets are managed by the Advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Evergreen has adopted a code of ethics pursuant to Rule 204A-1 under the Advisers Act (the “Code of Ethics” or “the Code”) that governs a number of conflicts of interest that can arise when providing advisory services to Clients. The Code is designed to ensure the Advisor meets its fiduciary obligation to Clients, (or prospective Clients), to detect and prevent violations of securities laws, and to drive home a culture of compliance within Evergreen.
This Code is distributed to each employee at the time of hire and when there are any material changes. On an annual basis, employees are required to attest that they have read, understood, and have observed the Code. The Code is reinforced in annual training and on-going monitoring of employee activity.
Evergreen’s Code includes the following:
- Requirements related to the confidentiality of Client personal information;
- Prohibitions on:
- Insider trading (if the Advisor is in possession of material, non-public information);
- Providing or accepting gifts and entertainment that exceed the Advisor’s policy standards;
- Outside business activities that are inconsistent with the Advisor’s policy standards;
- Pre-clearance of employee securities transactions;
- Pre-clearance of political contributions.
- Reporting of investment holdings on an annual basis;
- Quarterly (and annual) reporting all personal securities transactions (“covered securities” as mandated by regulation); and
- Quarterly (and annual) reporting of all personal brokerage accounts.
Evergreen employees may buy or sell securities for their personal accounts identical to or different from those recommended to Clients. A conflict of interest arises when an employee buys or sells a security in the same, or close proximity to the date of a purchase or sale of the same security on a Client’s behalf. There could be an incentive for an employee to take advantage of the market effect of a Client’s trade, or the market effect of an employee’s trade can negatively affect a subsequent purchase or sale price obtained for a Client.
Accordingly, Evergreen’s Code of Ethics subjects all of the Advisor’s employees to various procedures and restrictions relating to their personal securities transactions. These procedures include, among other things, the filing of annual reports of their investment holdings, the filing of quarterly reports of their transactions, review and pre-approval of trades in covered securities from the Chief Compliance Officer or a designee, and review and pre-approval of political contributions from the Chief Compliance Officer or a designee.
The provisions of the Code of Ethics are intended to avoid or mitigate material conflicts of interest that can arise between employees’ personal conduct and the fiduciary duty to Evergreen Clients. Evergreen reserves the right to refine and modify the Code of Ethics and its other policies and procedures over time. Clients may obtain a copy of Evergreen’s Code of Ethics by providing an email request to Clientservice@evergreenwealth.com.
Item 12 – Brokerage Practices
A. Factors Used to Select or Recommending Broker-Dealers
Evergreen’s investment advisory services consist solely of providing, and recommending, a selection of portfolios for investment to the Client. The Advisor has engaged the Clearing Brokers to provide brokerage services to the program.
The Clearing Brokers will route orders to various exchanges or market centers for execution and will regularly review the quality of execution to ensure that it is seeking to obtain the best execution of the Advisor’s Client transactions. While the Clearing Brokers will, as described above, seek to obtain best execution of the Advisor’s Client transactions, Clients should be aware that, by the Advisor exclusively engaging with the Clearing Brokers for all of its trading and rebalancing activities with respect to the portfolios, the Clearing Brokers may not provide lowest possible transactions cost. However, as described below, the Advisor believes the selection of the Clearing Brokers is in the best interest of the Advisor’s Clients, given the expanded suite of services that the Clearing Brokers will provide in connection with the Client accounts.
The Clearing Brokers will be responsible for managing all of the account activities, including receipt and delivery of securities; receipt and payment of funds owed by or to the Advisor’s Clients, and providing custody for securities and funds held by the Advisor’s Clients in the program the Advisor will be responsible for monitoring all transactions in its Client accounts and for notifying the Clearing Brokers if it believes that an error has been made in the trading.
If the Advisor identifies a trading error, it will work with the Clearing Brokers to ascertain the facts and resolve the error. To the extent appropriate given the facts and circumstances surrounding the error, the Advisor will work with the Clearing Broker to ensure that the error’s impact on the Customer is minimized. If there is a realized gain to the Client as a result of a trading error, the Client will keep the gain. If the error is the Advisor’s responsibility, any Client transaction will be corrected and the Advisor will be responsible for any loss resulting from the error.
B. Research and Other Soft Dollar Benefits
The Advisor does not engage in the use of “soft dollars” or commission sharing agreements.
C. Brokerage for Client Referrals
The Advisor does not consider, in selecting or recommending broker-dealers, Client referrals from a broker-dealer. The Advisor may receive referrals in the future and if it does it will appropriately amend this Brochure.
D. Directed Brokerage
The Advisor does not accept directed brokerage arrangements. Securities transactions are executed by brokers selected by the Advisor in its discretion and without the consent of the Clients. The Advisor may enter into directed brokerage arrangements only at its discretion.
E. Aggregating Trading for Multiple Clients
Evergreen does not aggregate orders. This means that Clients may not be able to take advantage of the cost savings and other benefits of order aggregation or block trading. Due to the wide universe of securities selected and bespoke allocation particular for each Client, Evergreen will likely be unable to trade blocks of securities in groups to achieve a benefit for Clients. Overall, Evergreen does not feel that Clients are at a disadvantage by trading each custom portfolio systematically.
Item 13 – Review of Accounts
A. Frequency and Nature of Periodic Review and Who Makes Those Reviews
Client accounts are reviewed on at least a monthly basis to ensure consistency with the Client’s strategy and investment objectives. Asset allocation, cash management, market conditions and changes to a Client’s financial condition are considered. The formal reviews are conducted by Advisors at least annually.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts
Reviews may take place more frequently in the event of major unanticipated changes in economic, market, or political conditions that may impact Client holdings. Portfolios may also be rebalanced when a large deposit or withdrawal impacts Client preferences.
C. Content and Frequency of Regular Reports
Each Client’s Clearing Brokers provides monthly statements to Clients showing the assets in each Client account, the market value, and each account’s performance for the quarter.
Item 14 – Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties
The Advisor does not receive any economic benefit, directly or indirectly from any third party for advice rendered to the Client.
B. Compensation to Non-Advisory Personnel for Client Referrals
Evergreen has entered into client referral agreements with unaffiliated third-party promoters where the promoters refer prospective clients whose investment goals and objectives are compatible with Evergreen’s investment approach. Evergreen compensates the promoter through direct compensation in accordance with the requirements of Rule 206(4)-1 of the Investment Advisers Act of 1940, and any corresponding state securities law requirements.
Prospective clients will be provided with disclosures at the time of the solicitation that state whether the promoter is a current Client of the firm; whether the promoter will receive any cash or non-cash compensation for the referral; and that the receipt of compensation for a referral creates a conflict of interest. In addition, each prospective client will be provided with a copy of a written disclosure statement disclosing the terms and conditions of the arrangement between Evergreen and the promoter, including the compensation the promoter will receive from Evergreen and any material conflicts of interest on the part of the promoter as a result of the referral arrangement.
Evergreen has entered into referral arrangements collectively known as “Promoters” and are unaffiliated Registered Investment Advisers under the SEC and solely provide referral services. Evergreen pays a flat fee to receive client referrals in the form of an initial introduction to interested consumers. The fees paid by Evergreen to the Promoters are paid irrespective of whether such a consumer becomes a client. Clients will not pay any increased fee to us as a result of the arrangement.
Item 15 – Custody
All Client funds and securities will be held in custody by qualified custodians (the “Clearing Brokers”). Evergreen, and at its sole discretion, may determine which Clearing Broker to use for each Client account. Clients wishing to engage the Advisor to provide investment advisory services will be required to establish an Evergreen Bank Account with Evergreen Wealth Corporation’s unaffiliated banking service provider, Coastal Community Bank, via separate agreement (“Banking Agreement”). The Banking Agreement provides Evergreen Wealth Corporation with the ability to direct funds for investments into custodial accounts at the Bank and Evergreen’s Clearing Brokers as necessary to provide the services elected by the Client, including daily investment of cash balances. As Evergreen Wealth Corporation and the Advisor are under common control, the Advisor will be deemed to have custody over its Clients’ accounts. As such, the Advisor will be subject to the provisions of Rule 206(4)-2 of the Investment Advisers Act (“the Custody Rule”) and will ensure a surprise audit of Client accounts by a PCAOB registered auditor will be undertaken on an annual basis.
All Clients will have access to real time reporting on the transactions in their accounts via the online platform and will receive at least monthly statements from the Clearing Brokers and bank sponsor, and a summarization of those statements from the Advisor. All Clients should carefully review and compare each such statement to ensure that the information contained in such statements is accurate and does not contain any discrepancies.
Item 16 – Investment Discretion
The Advisor provides investment advisory services on a discretionary basis to Clients. Please see Item 4 for a description of any limitations Clients may place on the Advisor’s discretionary authority. Clients must complete an investment objectives questionnaire at the beginning of the relationship giving the Advisor discretionary authority to determine, without obtaining the consent of the Client: (i) which securities are bought or sold, (ii) the total amount of the securities bought or sold, and (iii) the financial institution used to buy and sell securities, and (iv) the rates paid for the advisory relationship.
Item 17 – Voting Client Securities
Evergreen, as a matter of policy and as a fiduciary to Clients, has responsibility for voting proxies for portfolio securities consistent with the best interests of Clients. Evergreen maintains policies and procedures as to the handling, research, voting, and reporting of proxy voting and makes appropriate disclosures about the Advisor’s proxy policies and practices. Clients grant Evergreen the authority to vote proxies as established by the Investment Advisory Agreement and do not have the ability to direct a vote in any solicitation.
Evergreen utilizes the proxy voting and due diligence services provided by Broadridge Financial Solutions, Inc. (“Broadridge”), or its successors or assigns. The costs and expenses associated with this service are paid by Evergreen. Under this arrangement, proxy votes are cast in a manner consistent with the Shareholder Value Policy Rules developed and maintained by Broadridge, with Evergreen retaining discretion to override Broadridge’s proxy voting recommendations, consistent with Evergreen’s fiduciary obligations. This vote override ability should not be interpreted as an obligation by Evergreen to review each proxy voting decision considered or made by the third-party proxy service provider.
If Broadridge’s guidelines do not specify a recommended vote, there might not be sufficient material information to determine which vote direction would maximize shareholder value and as such, Evergreen may determine to abstain or not to vote a particular proxy.
Evergreen’s policy and practice includes the responsibility to monitor corporate actions, receive and vote Client proxies and disclose any potential conflicts of interest as well as making information available to Clients about the voting of proxies for their portfolio securities and maintaining relevant and required records.
Evergreen shall maintain records pertaining to proxy voting as required pursuant to Rule 204-2(c)(2) under the Advisers Act. The records are maintained through the Broadridge ProxyEdge System. Clients may request information regarding how Evergreen voted a Client’s proxies, and Clients may request a copy of the Advisor's proxy policies and procedures by emailing clientservice@evergreenwealth.com.
Item 18 – Financial Information
The Advisor has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of a bankruptcy petition.
Part 2B of Form ADV Brochure Supplement
for:
Evergreen Wealth Advisors Corporation
Office Addresses:
305 Church at North Hills St, Suite 1250
Raleigh, NC 27609
Telephone: +1 (888) 884-0557
7700 Windrose Ave.,
Office Number 02-127
Plano, TX 75024
Telephone:
+1 (888) 884-0557
Mailing Address:
5540 Centerview Dr., Ste 204 PMB #48153
Raleigh, NC 27606
March 31, 2025
This Brochure Supplement provides information about certain Evergreen Wealth Advisors Corporation (“Evergreen” or “Evergreen Wealth Advisors”) employees listed below that supplements the Evergreen Wealth Advisors Brochure. Please contact Evergreen at +1 (888) 884-0557 or clientservice@evergreenwealth.com if you did not receive Evergreen Wealth Advisors’ Brochure or if you have any questions about the contents of this Brochure Supplement.
Samantha Muncy
Head of Advisory Services
Year of Birth: 1980
Education
Purdue University Daniels School of Business, Global Executive MBA, 2021
TIAS School for Business and Society at Tilburg University in The Netherlands, Global Executive MBA, 2021
Mary Baldwin University, BS, 2003
Business Background
Evergreen Wealth Advisors Corporation, Head of Advisory Services, 12/2023 - Present
Open to the Public Investing, Inc., Head of Customer Experience, 05/2021 - 12/2023
Public Holdings, Inc., Head of Customer Experience, 05/2021 - 12/2023
Edward Jones, General Partner- 10/2016 - 04/2021
Edward Jones, Regional Leader 10/2013 - 10/2015
Edward Jones, Financial Advisor, 06/2003 - 10/2015
Disciplinary Information
None
Other Business Activity
None
Supervision
Evergreen’s Chief Compliance Officer, Corey Gomes, supervises Ms. Muncy’s advisory activities. This supervision takes various forms, including communication and advertisement reviews, conducting regular meetings and various supervisory controls related to supervised persons.
Andrew Leneve
Director of Sales
Year of Birth: 1987
Education
University of Oregon, BS, 2009
Business Background
Evergreen Wealth Advisors Corporation, Director of Sales, 01/2025 - Present
Fisher Investments, Group Vice President, 02/2016 - 12/2024
Fisher Investments, Team Lead 08/2014 - 02/2016
Fisher Investments, Financial Advisor 12/2012 - 7/2014
Fisher Investments, Account Executive 10/2009 - 11/2012
Disciplinary Information
None
Other Business Activity
None
Supervision
Evergreen’s Chief Compliance Officer, Corey Gomes, supervises Mr. Leneve’s advisory activities. This supervision takes various forms, including communication and advertisement reviews, conducting regular meetings and various supervisory controls related to supervised persons.
Elliott McCown, CFP®
Lead Wealth Advisor
Year of Birth: 1989
Education
University of North Carolina at Charlotte, 2012
Nagoya University of Foreign Studies, 2012
Designation(s)/Certification(s):
Elliott McCown has earned the following certification and is in good standing with the granting authority:
- CFP®, Certified Financial Planner: (granted by the CFP Board of Standards), 2024.
Please refer to ADV Part 2B Appendix 1 for definitions of the above designation.
Business Background
Evergreen Wealth Advisors Corporation, Lead Wealth Advisor, 12/2024 - Present
Personal Capital Advisors Corporation, Financial Advisor, 02/2022 - 11/2024
Empower Advisory Group, LLC, Mass Transfer, 04/2023 - 11/2024
UBS Financial Services, Inc., Financial Advisor, 09/2017 - 04/2021
The Vanguard Group, Inc., Registered Person, 02/2016 - 08/2017
Image Wizards, Head of Business Development, 08/2014 - 02/2016
CBRE, Accounts Payable Clerk, 06/2013 - 01/2014
Disciplinary Information
None
Other Business Activity
None
Supervision
Elliott McCown reports to Samantha Muncy, Evergreen’s Head of Advisory (540-931-5901). Ms. Muncy and Evergreen’s Chief Compliance Officer, Corey Gomes, supervise Mr. McCown’s advisory activities. This supervision takes various forms, including communication and advertisement reviews, conducting regular meetings and various supervisory controls related to supervised persons.
Joel Anderson
Wealth Advisor
Year of Birth: 1991
Education
Golden Gate University Master of Science in Financial Planning (“MSFP”), 2023
Fox School of Business at Temple University, Master of Business Administration (“MBA"), Finance, 2019
University of Arizona, BA, 2016
Business Background
Evergreen Wealth Advisors Corporation, Wealth Advisor, 12/2024 - Present
Values Added Financial, LLC, Financial Advisor, 01/2022 - 10/2024
Ameriprise Financial Services, LLC, Vice President, 08/2020 - 12/2021
Wells Fargo Clearing Services, LLC, Financial Advisor, 07/2017 - 08/2020
United States Navy., Fleet Marine Force Corpsman, 08/2009 - 07/2017
Disciplinary Information
None
Other Business Activity
None
Supervision
Joel Anderson reports to Samantha Muncy, Evergreen’s Head of Advisory (540-931-5901). Ms. Muncy and Evergreen’s Chief Compliance Officer, Corey Gomes, supervise Mr. Anderson’s advisory activities. This supervision takes various forms, including communication and advertisement reviews, conducting regular meetings and various supervisory controls related to supervised persons.
Part 2B of Form ADV Brochure Supplement - Appendix 1
Professional Designation Definitions
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold the CFP® certification. You may find more information about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To become a CFP® professional, an individual must fulfill the following requirements:
- Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP Board-approved coursework at a college or university through a CFP Board Registered Program. The coursework covers the financial planning subject areas CFP Board has determined are necessary for the competent and professional delivery of financial planning services, as well as a comprehensive financial plan development capstone course. A candidate may satisfy some of the coursework requirements through other qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have earned a bachelor’s or higher degree or completed a financial planning development capstone course.
- Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the context of real-life financial planning situations.
-
Experience – Complete 6,000 hours of professional experience related to the personal financial planning process, or 4,000 hours of apprenticeship experience that meets additional requirements.
- Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to remain certified and maintain the right to continue to use the CFP Board Certification Marks:
-
Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at all times when providing financial advice and financial planning. CFP Board may sanction a CFP® professional who does not abide by this commitment, but CFP Board does not guarantee a CFP® professional's services. A client who seeks a similar commitment should obtain a written engagement that includes a fiduciary obligation to the client.
- Continuing Education – Complete 30 hours of continuing education every two years to maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments in financial planning. Two of the hours must address the Code and Standards.