Effective January 2, 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
January 2, 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 an other than annual amendment. The following changes were made to this Brochure since the last other than annual amendment filing, dated November 22, 2024.
- Legal Name Change - Evergreen Money Advisors has been legally changed to Evergreen Wealth Advisors.
- Item 4 - Advisory Business - Evergreen provides Clients with a new holistic Wealth Management Advisory Service. High Yield Checking and High Yield Savings bank accounts are being offered through Evergreen’s unaffiliated bank sponsor, Coastal Community Bank as part of an advisory cash management service. Additionally, Investment Accounts are available for Clients which includes access to Evergreen’s optimized portfolio allocation solution that utilizes tax optimization strategies to help Evergreen Clients reduce their overall tax liability. Charitable Giving Programs will also be available through Evergreen’s unaffiliated partnership with DAFFY to assist Clients with their philanthropic goals while considering tax implications. Lastly, Evergreen is no longer offering the cash management advisory product entitled “Liquid Treasuries” to new Clients but Evergreen will still service the existing Liquid Treasuries relationships.
- Item 5 - Fees and Compensation – Updated to reflect new tiered fee structure based on type of accounts held by Client and corresponding asset level.
- Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss - Detail provided around Evergreen’s updated advisory offering and how advice is formulated to effectively manage Cash Management and Personal Portfolios. Corresponding risks also included in this section.
- Item 17 - Voting Client Securities - Section updated to reflect Proxy Voting practices utilizing an independent vendor, Broadridge, to issue proxy voting guidance, manage the voting process in accordance with that guidance, and maintain proxy records. Proxy votes are cast in a manner consistent with Broadridge’s Shareholder Value Policy Rules. 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. In some situations where there is not sufficient material information to determine which vote direction would maximize shareholder value, Evergreen may determine to abstain or not to vote for a particular proxy.
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
Item 4 – Advisory Business
A. Description of the Advisory Firm
Effective November 8, 2024, Evergreen Wealth Advisors Corporation legally changed its name from Evergreen Money Advisors. 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 meet the minimum deposit amount (as noted in Item 7) and enter into an Evergreen Client Agreement (“Investment Advisory Agreement”) will have access to Bank Accounts offered through Evergreen’s bank sponsor. Once a Client has established Bank Accounts, meets the required minimum investment and wishes to open an Investment Account, they will complete the online enrollment to open an Investment Account that includes Evergreen’s proprietary portfolio management solution. 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
Upon completion of initial enrollment, Evergreen Clients will be required to open “High Yield Checking” (“HYC”) and “High Yield Savings” (“HYS”) Accounts (collectively, “Bank Accounts”) offered by Evergreen Wealth Corporation through its unaffiliated bank sponsor, Coastal Community Bank (“Coastal”). Clients will be required to deposit a minimum deposit amount of $25,000 but are not required to open an Investment Account at the onset of the relationship. In some cases, Evergreen may waive the minimum deposit amounts within the Bank Accounts.
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. Based on an initial assessment of Client liquidity needs, Evergreen will provide ongoing and continuous cash management advisory services over the accounts as outlined in the Investment Advisory Agreement to ensure cash balances align with the Client’s overall financial and investment strategy.
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, suitability questionnaires, risk tolerance, and cash management requirements to determine if it makes fiscal sense 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. Personal Portfolios and brokerage are made available through DriveWealth, LLC (“DriveWealth”).
Personal Portfolios require a minimum initial investment of $250,000. Once a Client has established Bank Accounts and wishes to open an Investment Account with $250,000, the Client will begin the Investment Account enrollment. Client’s initial goals and investment objectives are established during enrollment through Evergreen’s risk tolerance and suitability questionnaire where the Client's initial personal investment policy is created. Evergreen constructs a portfolio based on that policy and will provide continuous and regular supervisory or management services of all assets held in Client 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 appropriate investment allocation.
Following the completion of the investment suitability questionnaire and selection of an investment profile through use of our digital app and/or discussion with our Advisors, all factors will be assessed to build a recommended balanced and diversified portfolio consisting primarily of individual securities (including publicly traded stocks, bonds, exchange traded funds, and government securities).
Clients will have the opportunity to accept the recommended allocation or if Clients wish to adjust their allocation preferences to certain sectors and security types, they will have the ability to adjust prior to finalizing their investment objectives, subject to Evergreen recommended boundaries. If the custom sector or security type allocation determined by the Client is outside of the recommended boundaries, Clients will be required to discuss their investment objectives with an Evergreen Wealth Advisor to assess if they are aligned with their overall financial goals.
Once the optimal allocation is determined by Client driven factors and funds are transferred to Investment Accounts, Evergreen’s proprietary portfolio optimizer will determine the optimal allocation based on Evergreen determined constraints and then send trade orders to Drivewealth to execute the trades.
Evergreen periodically monitors Clients’ portfolios and will rebalance Personal Portfolio assets within the first 90 days of account funding and initial asset allocation followed by a monthly rebalance. 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.
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, suitability questionnaires, risk tolerance, 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 program is offered through Daffy, which is an independent nonprofit organization that is unaffiliated with Evergreen. The DAF account program allows Clients to contribute cash or securities to a charitable account to realize potential tax benefits the year of the contribution to the donor-advised fund, while supporting their selected charities upon donation.
If a Client wishes to open a DAF and it is aligned with their philanthropic goals, Evergreen will guide Clients through the opening of a DAF account in accordance with Daffy Investment Policy Guidelines. Evergreen will pay for the Client fee to maintain a DAF account. Evergreen receives no other compensation or benefits from Daffy 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.
Following regulations regarding charitable contributions set forth in the Internal Revenue Code of 1986, as amended, Daffy requires that contributions become the sole property of Daffy. Thus, all contributions accepted by Daffy are both irrevocable and unconditional. Once contributions are accepted, they are not refundable and become assets owned and held by Daffy. Moreover, they are subject to the exclusive legal authority and control of Daffy as to their use and distribution.
Please Note: 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 Daffy program that is accessible from Daffy and consult with their tax, legal, and accounting advisors regarding their individual situation.
Cash Management - Liquid Treasuries
As of the date of this brochure, Evergreen is no longer offering the cash management advisory product entitled “Liquid Treasuries” to new Clients but Evergreen will still service the existing Liquid Treasury relationships. Liquid Treasuries Accounts include a checking account (“Evergreen Bank Account”) offered by Evergreen Wealth Corporation through its unaffiliated bank sponsor, Coastal Community Bank (“Coastal”), where the Advisor will direct the purchase and sale of U.S. treasury securities as a cash management program for Clients. The broker and custodian for Liquid Treasuries Accounts is Jiko Securities, Inc. (“Jiko”) and in order to facilitate the purchase and sale of Treasuries, a Liquid Treasury Bank Account will also be maintained at Jiko in the Clients name.
Cash deposited into an Evergreen Bank Account will be swept to a Liquid Treasury Bank Accounts held at Jiko and then U.S. Treasury bonds will be purchased in the Liquid Treasury Investment Account. Initial interest is earned in the Bank Accounts but following the purchase of Treasury Bonds, the Client will then begin to earn the specified yield on the Treasury.
All cash balances in an Evergreen Bank Account as well as a Liquid Treasury Bank Account earn a variable rate of interest and are eligible for Federal Deposit Insurance Corporation (“FDIC”) insurance while such cash balance awaits the sweep into a Liquid Treasury or Investment Account. FDIC insurance is not provided, and interest is not earned, until the funds arrive at the Evergreen Bank Accounts held at Coastal or Jiko.
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 determined by the Federal Funds Rate.
C. Client Tailored Services and Client Imposed Restrictions
Advisory services are tailored to achieve the Clients’ investment objectives. During enrollment, the Client will complete a suitability questionnaire which creates a recommendation for the corresponding investment allocation.
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 sponsors a Wrap Fee Program (“the Program”). 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 will 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 DriveWealth.
The associated fees of the wrap fee program is detailed below in Item 5.
E. Assets Under Management
As of November 8, 2024, Evergreen has approximately $110,501,832 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 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 |
|||
For clients with a Liquid Treasuries Cash Management Account, the fee will be .03% per month and .36% per year.
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 custodian. 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 custodian to debit the Fee from the appropriate Client account.
For Clients maintaining a Personal Portfolio balance, Evergreen instructs Drivewealth to 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 account custodian 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.
Liquid Treasuries Account Fees are calculated by Jiko based on account balances at the end of a calendar month and Fees are deducted directly from the Jiko brokerage account.
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 custodians 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. The Advisor reviews investment decisions for the purpose of ensuring that all Accounts with substantially similar investment objectives are treated equitably. The performance of similar Accounts is also regularly compared to determine whether there are any unexplained significant discrepancies.
Item 7 – Types of Clients
Evergreen provides investment advisory services to high net worth individuals, individuals, and business entities. Evergreen requires a minimum of $25,000 to establish a Bank Account relationship on the platform. In the event that a Client fails to meet the minimum relationship balance requirement, Evergreen reserves the right to terminate the relationship in accordance with the provisions of the account agreement.
To open an Evergreen Personal Portfolio, Evergreen requires a minimum of $250,000 to open an advisory account. At our discretion, the Advisor may waive this minimum account size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Evergreen provides Clients with personalized investment strategies for each Client. Our investment platform offers Taxable Brokerage Accounts and utilizes a diversified pool of approximately 1,500 individual securities to build custom portfolios based on each Client’s risk tolerance, tax rate, sector weighting preferences, and other factors.
The pool of approximately 1,500 securities consists of equities, fixed income, and cash equivalents. For the equity portion of the portfolio there are U.S. stocks and American Depositary Receipts (“ADRs”) for international exposure, spanning eight sectors: technology, financials, real estate, healthcare, consumer, industry, energy, and media. In addition to equities, the pool includes Exchange-Traded Funds (“ETFs”) for fixed income exposure, covering several sectors including government bonds, municipal bonds, corporate bonds, international bonds, and high yield bonds. For cash equivalents, the Advisor offers money market funds, which may be selected based on the Client’s state of residence and the optimal tax-equivalent yield.
In order to define the asset allocation for each Client’s portfolio from the pool of securities above, the Advisor first must identify the Client’s risk tolerance. The Advisor will recommend a risk tolerance for the Client based on their net worth, income, age, and other factors but will allow the Client to make limited changes to their risk tolerance. If the Client wants to make a change to their risk tolerance that is outside of those limits they will need to speak to an Evergreen Advisor. There are 25 different options for risk tolerance selection with 5 major categories and 5 options per category. The 5 categories are conservative, moderate, balanced, growth, and aggressive. The more conservative the portfolio, the higher the allocation to fixed income and cash equivalents and the lower the allocation to stocks. The more aggressive the portfolio, the higher the allocation to stocks, and the lower the allocation to fixed income and cash equivalents.
Upon account funding and initial allocation, portfolios are initially rebalanced within the first three months and reviewed monthly thereafter. Rebalancing occurs (1) monthly if the portfolio drifts significantly from the Client’s established asset allocation or sector weightings, or (2) upon large deposit or withdrawal. Clients are not responsible for individual security selection; Evergreen manages all purchase and sale decisions within the portfolio.
Clients may update their preferences through our platform or with assistance from an Evergreen advisor.
The Advisor also provides access to a Donor Advised Fund (“DAF”) offering in which the Client can contribute securities or cash to the DAF. Upon contribution the Client will receive the tax benefit.
B. Investment Strategies
Investment Accounts
Evergreen’s investment strategies are customized based on each Client’s individual circumstances, including their risk tolerance, tax rate, sector weighting preferences, age, net worth, and income. The Advisor employs a personalized approach to portfolio management that focuses on achieving long-term financial goals while optimizing for tax efficiency and risk management.
Key strategies for Personal Portfolios include:
Custom Portfolio Construction: Evergreen builds custom portfolios based on securities from a Global Diversified Index and are tailored to individual Client preferences. This allows us to maintain exposure to a diversified set of securities while customizing for factors such as tax efficiency and sector preferences.
Tax Optimization: Multiple tax reduction strategies may be used, including tax loss harvesting which attempts to offset capital gains by selling securities that have declined in value, allowing Clients to help reduce their overall tax liability. Tax loss harvesting is a continuous process that is employed across the portfolio to minimize taxable gains while maintaining the desired asset allocation.
Gain Deferral: To minimize the impact of capital gains taxes, the Advisor aims to hold investments for extended periods, deferring the realization of gains. This helps Clients take advantage of lower long-term capital gains tax rates.
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 through an unaffiliated third-party. This allows Clients to avoid capital gains taxes on the donated assets while receiving a charitable deduction, creating a tax-efficient way to give.
Diversification: Diversification is a cornerstone of our investment approach. The Advisor allocates assets across various sectors and asset classes to reduce risk. By spreading investments across a broad set of securities, the Advisor seeks to mitigate volatility and enhance returns while minimizing the risk of significant losses in any one area.
All portfolios are managed and monitored with a focus on tax efficiency to ensure they remain aligned with the Client’s objectives. All portfolios are continuously monitored and adjusted when needed to account for market changes, Client updates, and tax considerations, ensuring that portfolios remain optimized for both performance and tax minimization. Clients can update their preferences or work with an advisor to review their strategies as their financial situation evolves.
Treasuries Accounts
Cash balances in the Client's Evergreen Checking Account will be invested into U.S. Treasury securities with an aim at generating income on the cash balances. The Treasury Account and corresponding Evergreen Bank Account are a requirement to be a Client of the Advisor. The Advisor maintains discretionary authority regarding the amount, timing, and direction of all trading in the Treasury Account.
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 its investment objective as investing in securities involves risk of loss that Clients should be prepared to bear. Generally, Evergreen’s strategies will be subject to the following risks:
Common Stocks and Equity-Related Securities. Prices of common stock react to the economic conditions of the company that issued the security, industry and market conditions, and other factors and may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly the value of other equity-related securities, including preferred stock, warrants and options may also vary widely.
Exchange Traded Funds. ETFs are a type of index fund bought and sold on a securities exchange. The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in it being more volatile and ETFs have management fees that increase their costs. ETFs are also subject to other risks, including: (i) the risk that their prices may not correlate perfectly with changes in the underlying index; and (ii) the risk of possible trading halts due to market conditions or other reasons that, in the view of the exchange upon which an ETF trades, would make trading in the ETF inadvisable.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price movements of forward and other derivative contracts are influenced by, among other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary and exchange control programs and policies of governments, and national and international political and economic events and policies. Clients are also subject to the risk of failure of any of the exchanges on which their positions trade or of its clearinghouses.
Foreign Securities Risk. Investing in securities issued by companies whose principal business activities are outside the United States may involve significant risks not present in domestic investments. For example, there is generally less publicly available information about foreign companies, particularly those not subject to the disclosure and reporting requirements of U.S. securities laws. Foreign issuers are generally not bound by uniform accounting, auditing, and financial reporting requirements and standards of practice comparable to those applicable to domestic issuers. Investments in foreign securities also involve the risk of possible adverse changes in investment or exchange control regulations or currency exchange rates, expropriation or confiscatory taxation, limitation on the removal of cash or other assets, political or financial instability, or diplomatic and other developments which could affect such investments. Further, economies of particular countries or areas of the world may differ favorably or unfavorably from the economy of the United States. Foreign securities often trade with less frequency and volume on their respective exchanges than domestic securities and therefore may exhibit greater price volatility than domestic investments. ADRs and ETFs investing in foreign securities are subject to risks similar to those associated with direct investments in foreign securities.
Emerging Markets Risk. Investments in emerging markets, which include Africa, Asia, the Middle East and Central and South America, are subject to the risk of abrupt and severe price declines. The economic and political structures of developing countries, in most cases, do not compare favorably with the U.S. and other developed countries in terms of wealth and stability, and financial markets in developing countries are not as liquid as markets in developed countries. The economies in emerging market countries are less developed and can be overly reliant on particular industries and more vulnerable to the ebb and flow of international trade, trade barriers, and other protectionist measures. Certain countries may have legacies or periodic episodes of hyperinflation and currency devaluations or instability and upheaval that could cause their governments to act in a detrimental or hostile manner toward private enterprise or foreign investment. Significant risks of war and terrorism currently affect some emerging market countries.
Sector Risk. Sector risk is the possibility that securities within the same group of industries will decline in price due to sector-specific market or economic developments. If a portfolio invests more heavily in a particular sector, the value of its shares may be sensitive to factors and economic risks that specifically affect that sector. As a result, a portfolio’s share price may fluctuate more widely than the value of shares of a mutual fund that invests in a broader range of industries. Additionally, some sectors could be subject to greater government regulation than other sectors, which may impact the share price of companies in these sectors. The sectors in which any portfolio may invest in more heavily will vary.
Counterparty Risk. Transactions may be affected in “over-the-counter” or “interdealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange–based” markets. This exposes Clients to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the contract (whether or not bona fide) or because of a credit or liquidity problem, thus causing Clients to suffer a loss.
Cybersecurity Risk. The information and technology systems of the Advisor and of key service providers to the Advisor and its Clients, including banks, broker-dealers, custodians and their affiliates, may be vulnerable to potential damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by their respective professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes and earthquakes. For instance, cyber-attacks may interfere with the processing or execution of the Advisor’s transactions, cause the release of confidential information, including private information about Clients, subject the Advisor or its affiliates to regulatory fines or financial losses, or cause reputational damage. Additionally, cyberattacks or security breaches (e.g., hacking or the unlawful withdrawal or transfer of funds), affecting any of the Advisor’s key service providers, may cause significant harm to the Advisor, including the loss of capital. Similar types of cybersecurity risks are also present for issuers of securities in which the Advisor may invest. These risks could result in material adverse consequences for such issuers and may cause the Advisor’s investments in such issuers to lose value. Although the Advisor has implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, it may be necessary for the Advisor to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of the Advisor or its Client accounts and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including personal information, which may result in identity theft.
Effects of Health Crises and Other Catastrophic Events. Health crises, such as pandemic and epidemic diseases, as well as other catastrophes that interrupt the expected course of events, such as natural disasters, war or civil disturbance, acts of terrorism, power outages and other unforeseeable and external events, and the public response to or fear of such diseases or events, have and may in the future have an adverse effect on Clients' investments and the Advisor's operations. For example, any preventative or protective actions that governments may take in respect of such diseases or events may result in periods of business disruption, inability to obtain raw materials, supplies and component parts, and reduced or disrupted operations for Client portfolio companies. In addition, under such circumstances the operations, including functions such as trading and valuation, of the Advisor and other service providers could be reduced, delayed, suspended or otherwise disrupted. Further, the occurrence and pendency of such diseases or events could adversely affect the economies and financial markets either in specific countries or worldwide.
Software Risk. Evergreen delivers its investment advisory services entirely 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.
Tax Optimization Risk. Personal Portfolios utilize tax reduction strategies including tax-loss harvesting strategies and are subject to the following risks:
- Clients should confer with their personal tax advisor regarding the tax consequences of investing with Evergreen and engaging in the tax optimization strategies, based on their particular circumstances. Clients and their personal tax advisors are responsible for how the transactions in the Client’s account are reported to the Internal Revenue Service (“IRS”) or any other taxing authority. Evergreen assumes no responsibility to Clients for the tax consequences of any transaction, including any capital gains and/or wash sales that may result from the tax-loss harvesting strategy.
- Tax optimization strategies utilized are not intended as tax advice, and Evergreen does not represent in any manner that the tax consequences described will be obtained or that Evergreen’s investment strategy will result in any particular tax consequence. The tax consequences of this strategy are complex and may be subject to challenge by the IRS. This strategy was not developed to be used by, and it cannot be used by, any investor to avoid penalties or interest.
- A Client must notify Evergreen of specific stocks in which the Client is prohibited from investing. If a Client instructs Evergreen not to purchase certain stocks, Evergreen will select an alternate stock to purchase on the Client’s behalf or if Evergreen deems no other stock as appropriate, not invest in an alternate stock. The Client shall notify Evergreen immediately if any investments recommended or made for the Client to violate such restrictions.
- The performance of the new securities purchased utilizing tax optimization may be better or worse than the performance of the securities that are sold for tax-loss harvesting purposes.
- The effectiveness of the tax optimization to reduce the tax liability of the Client will depend on the Client’s entire tax and investment profile, including purchases and dispositions in a Client’s (or Client’s spouse’s) accounts outside of Evergreen and type of investments (e.g., taxable or nontaxable) or holding period (e.g., short-term or long-term).
The foregoing list of risk factors does not purport to be a complete enumeration or explanation of every risk involved in an investment with the Advisor. Clients should read the entire Brochure, investment agreement and other materials that may be provided by the Advisor.
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.
To facilitate enrollment as a digital application developer, a single owner Limited Liability Corporation has been established under the name Evergreen Wealth Advisors. The entity is wholly owned by Evergreen Wealth Corporation.
In some exceptions, remote employees may work on behalf of the Advisor in states outside of the primary office locations of Evergreen. As such, Evergreen is determined to have nexus in those states and due to certain corporate and tax requirements, must register an entity in those states to taxes. As of this filing, a separate entity has been established in California under the name Evergreen Wealth Advisors California Corporation and is also wholly owned by Evergreen Wealth Corporation.
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 company meetings, as necessary, 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);
- Pre-clearance of employee securities transactions;
- 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
- Providing or accepting gifts and entertainment that exceed the Advisor’s policy standards;
- Outside business activities that exceed or are inconsistent with the Advisor’s policy standards;
- Political contributions;
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, and review and pre-approval of trades in covered securities 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. 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 custodians to provide brokerage services to the program.
The custodians 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 custodians 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 custodians for all of its trading and rebalancing activities with respect to the portfolios, the custodians may not provide lowest possible transactions cost. However, as described below, the Advisor believes the selection of the custodians is in the best interest of the Advisor’s Clients, given the expanded suite of services that the custodians will provide in connection with the Client accounts.
The custodians 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 custodians if it believes that an error has been made in the trading.
If the Advisor identifies a trading error, it will work with the custodians 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 custodian 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 investment personnel 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 custodian 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
Currently, neither the Advisor nor its related persons directly or indirectly compensate any person who is not advisory personnel for Client referrals. If in the future the Advisor enters such arrangements, this Brochure will be appropriately amended.
Item 15 – Custody
All Client funds and securities will be held in custody by qualified custodians. 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 investment into custodial accounts at the Bank, DriveWealth, and Jiko 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 Custodians, Evergreen Wealth Corporation’s partner bank, 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
January 2, 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, Austen Caraker, 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.
Elliott McCown
Lead Wealth Advisor
Year of Birth: 1989
Education
University of North Carolina at Charlotte, 2012
Nagoya University of Foreign Studies, 2012
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, Austen Caraker, 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, 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, Austen Caraker, 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.