A. Firm Information
Efficient Advisors, LLC (“Efficient”) is an investment adviser registered with the Securities and
Exchange Commission. Efficient was founded in 2009 and is owned by Efficient Advisors Parent,
Inc. Efficient Advisors Parent, Inc. is owned by Fiduciary Services Group, LLC as of March 2024.
This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by Efficient.
B. Advisory Services Offered
Turn-Key Asset Management Services
Efficient offers an asset allocation service designed to build long-term wealth while maintaining
risk tolerance and loss threshold levels based on your distinct financial needs and goals. We
offer model portfolios designed to allocate your assets among exchange-traded funds (“ETFs”),
no-load mutual funds, managed futures mutual funds, and/or variable annuity sub accounts
(referred to as “Fund” or “Funds”). Our service includes monitoring your account and rebalancing
and/or reallocating your assets on a discretionary basis in order to maintain your model allocation
selection. Other financial services firms and professionals, such as independent financial
planners, investment advisers, CPAs, and brokerage firms and their representatives refer their
clients to Efficient. We refer to these professionals in this brochure as your Advisor or RIA Firm
(or “RIA Firms” if referring to more than one).
Initially, your Advisor will assist you in understanding our Investment Management Agreement,
defining your investment goals and risk tolerance (“Investor Profile”), and selecting an allocation
model based upon your Investor Profile. Please remember that your Investor Profile is only a
guide to selecting an appropriate portfolio. Your Advisor may suggest a portfolio with a higher or
lower risk level than the Investor Profile indicates. If that happens, please make sure that you
understand his/her rationale for doing so before signing the Investment Management Agreement.
We require your Advisor to maintain an ongoing relationship with you and meet with you on a
periodic basis to discuss changes in your personal or financial situation, suitability requirements,
and any new or revised reasonable restrictions you would like to impose on your account(s).
Because your Investor Profile helps to determine your allocation strategy, you are responsible for
promptly communicating all changes in your financial circumstances and investment objectives.
We review your account(s) in the context of your stated investment objectives and your Investor
Profile dictates any adjustments we make. For this reason, prompt notification by you results in
maintaining your assets in alignment with your individual needs.
We can explore other investment options at your request, but when Efficient begins its
management of your account, in all likelihood your existing assets will be sold to fund your model
portfolio purchases. You may be able to place reasonable restrictions on the individual
investments held within your account. These restrictions must be in writing and accompany the
Investment Management Agreement. Restrictions must be accepted by Efficient, and acceptance
is at the sole discretion of Efficient.
Allocations for Small Accounts
Efficient has developed alternatives for handling individual accounts with a current market value
of less than $50,000. We refer to these alternative allocations as “Small Account Allocations.”
Small Account Allocations mirror the standard Efficient Portfolio that you have chosen as closely
as possible given the constraints of account size and the specific portfolio selected. They may
also include fewer underlying Funds. The purpose of Small Account Allocations is to manage
smaller balances more effectively and reduce your transaction costs. Be advised that this may
also reduce your portfolio’s diversification.
Accounts valued between $10,000 and $50,000 may be invested in a model with approximately
five (5) to seven (7) underlying Funds. For accounts valued between $1,000 and $10,000, we
may invest your assets in a single asset allocation Fund without an allocation to managed futures,
even if requested. An account with less than $1,000 in market value may not be invested until it
becomes at least $1,000. Once your account’s market value exceeds a certain threshold (as
determined by Efficient at our sole discretion), your account may be transitioned out of the Small
Account Allocation and into the standard allocation for your selected Efficient Portfolio. Efficient
will consider transaction costs and tax impact before initiating such transition and if a transition is
initiated it may result in transaction charges by your Custodian and you may experience a taxable
gain or loss if applicable to such account. Efficient also reserves the right to transition your
portfolio into a Small Account Allocation if the market value is reduced to an amount below the
thresholds listed earlier in this section. As with a transition to a standard portfolio, this transition
to a Small Account Allocation may result in transaction charges by your Custodian and you may
experience a taxable gain or loss if applicable to such Account.
Efficient reserves the right to change, alter, or terminate the Small Account Allocations at any time
at our sole discretion.
d.b.a Evidence Based Advisors
Evidence Based Advisors [“EBA”] offers an asset allocation service designed to build long-term
wealth while maintaining risk tolerance and loss threshold levels based on your distinct financial
needs and goals. EBA offers model portfolios designed to allocate your assets among exchange-
traded funds (“ETFs”), no-load mutual funds, and/or variable annuity sub accounts (referred to as
“Fund” or “Funds”). Our service includes monitoring your account and rebalancing and/or
reallocating your assets on a discretionary basis in order to maintain your model allocation
selection. Other financial services firms and professionals, such as independent financial
planners, investment advisers, CPAs, and brokerage firms and their representatives refer their
clients to EBA. We refer to these professionals in this brochure as your Advisor or RIA Firm (or
“RIA Firms” if referring to more than one).
Initially, your Advisor will assist you in understanding our Investment Management Agreement,
defining your time horizon and risk tolerance (“Investor Profile”), and selecting an allocation model
based upon your Investor Profile. Please remember that your Investor Profile is only a guide to
selecting an appropriate portfolio. Your Advisor may suggest a portfolio with a higher or lower
risk level than the Investor Profile indicates. If that happens, please make sure that you
understand his/her rationale for doing so before signing the Investment Management Agreement.
We require your Advisor to maintain an ongoing relationship with you and meet with you on a
periodic basis to discuss changes in your personal or financial situation, suitability requirements,
and any new or revised reasonable restrictions you would like to impose on your account(s).
Because your Investor Profile helps to determine your allocation strategy, you are responsible for
promptly communicating all changes in your financial circumstances and investment objectives.
We review your account(s) in the context of your stated investment objectives and your Investor
Profile dictates any adjustments we make. For this reason, prompt notification by you results in
maintaining your assets in alignment with your individual needs.
We can explore other investment options at your request, but when EBA
begins its management
of your account, in all likelihood your existing assets will be sold to fund your model portfolio
purchases. You may be able to place reasonable restrictions on the individual investments held
within your account. These restrictions must be in writing and accompany the Investment
Management Agreement. Restrictions must be accepted by EBA, and acceptance is at the sole
discretion of EBA.
Retirement Plans
If your account is a retirement plan subject to Employee Retirement Income Security Act of 1974
(“ERISA”), you will appoint Efficient as “Investment Manager” under Section 3(38) and/or
“investment adviser” under Section 3(21) of ERISA. You will furnish copies of all documents
governing the plan that give you authority to retain Efficient and that govern Efficient’s services to
the plan. In addition, you will send to Efficient any amendments to your ERISA plan that affect
Efficient’s rights or obligations. The amendment will be binding on Efficient only when we have
sent you written notice of our agreement to the amendment. Efficient will not have any
responsibility for assets held outside of the custodial or trust account over which it has discretion.
You will be required to name Efficient as a fiduciary in the plan's ERISA fidelity bond covering the
account.
Unmanaged Assets
From time to time, you may decide to hold certain securities or other property for which Efficient
does not provide investment advisory services ("Unmanaged Assets") in your custody or
brokerage account(s). Requests to hold an Unmanaged Asset must be made in writing and
requires the approval of Efficient. Efficient will have no duty, responsibility or liability with respect
to these assets, and therefore, Efficient will not charge an investment advisory fee. However, if
you have an account that solely contains Unmanaged Assets, Efficient reserves the right to
charge an account maintenance fee of $5 per month.
Sub-Advisory Services
Efficient provides other financial services firms and professionals with outsourced investment
management services as a sub-advisor. In our capacity as a sub-advisor, Efficient provides
discretionary investment management services, including asset allocation, portfolio construction,
investment management and supervision services. These sub-advisory services are generally
part of a broker-dealer’s managed account program whereby the Client will then enter into a
program and investment advisory agreement with the program sponsor and then elect Efficient
as their money manager. The Advisor will assist and advise the Client in establishing investment
objectives for the account, the selection of Efficient, and defining any restrictions on the account.
Efficient will continue to provide oversight of the Client’s selected portfolio.
In consideration for such services, the Program Sponsor will charge a program fee that includes
the investment advisory fee of the money managers, the administration of the program and
trading, clearance and settlement costs. The Program Sponsor will add Efficient‘s Investment
Advisory Fee (described below in Item 5) and will deduct the overall fee from the Client account,
generally at the start of each calendar quarter. The asset-based program fee is generally tiered
and varies depending on the size of the account.
The client’s advisor also provides copies of Efficient’s Disclosure Brochure and gathers the
account opening documentation from the client. Efficient receives notice of the account opening
documentation from the Advisor. Efficient does not typically meet with clients of the Sub-Advisory
Services and relies on the client’s Advisor to provide updates with regard to changes in client risk
tolerance, goals and suitability. Clients are instructed to channel their communication and update
their suitability information directly with their Advisor who made the portfolio selection on their
behalf. If a client wishes to place restrictions on the portfolio management, those requests should
be processed through the client’s Advisor.
Financial Planning & Consulting
Efficient may provide a variety of financial planning and consulting services to your Advisor, on
your Advisor’s behalf, or to individuals and families. Services are offered in several areas of a
Client’s financial situation, depending on their goals, objectives and financial situation.
Financial planning and consulting recommendations may pose a potential conflict between the
interests of Efficient and the interests of the Client. Clients are not obligated to implement any
recommendations made by Efficient, or their Advisor. If the Client elects to act on any of the
recommendations made by Efficient, the Client is under no obligation to affect the transaction
through Efficient.
Third-Party Model Portfolio Program
Efficient provides access to third-party model portfolios made available by model providers on our
platform via our Third-Party Model Portfolio Program (“TPMP”). In this program, Your Advisor will
select one or more third-party model portfolios based on Your investment profile. Efficient’s role
in this program is to provide administrative support and trading execution based on the model
portfolio(s) You and Your Advisor select. For the services we provide, Efficient will charge a
maximum of 0.35% annually based on the value of your account(s) in this program. Specific
information regarding fees for this program will be disclosed in the TPMP Agreement You and
Your Advisor execute with Efficient.
FICA For Advisors Cash Management Program
Efficient makes available to clients the FICA For Advisors Cash Management Program (“FICA
Program”) offered by StoneCastle Network, LLC (“StoneCastle”), an affiliate of StoneCastle Cash
Management, LLC. The FICA Program allows customers the ability to protect their money by
placing it in deposit accounts at banks, savings institutions and credit unions (collectively, “Insured
Depositories”) in a manner that maintains full insurance of the funds by the Federal Deposit
Insurance Corporation (“FDIC”) or National Credit Union Administration (“NCUA”), whichever is
applicable. Funds will be deposited within StoneCastle’s network of Insured Depositories
(“Deposit Network”). StoneCastle requires a minimum deposit of $100,000 to open a FICA
Program account. Efficient will assist clients in signing up for this program and facilitating the
transfer of funds between the client’s like-named accounts. Efficient will earn a fee of 0.1% from
StoneCastle if clients participate in this program. This arrangement presents a conflict of interest
to the extent that Efficient is incentivized to make recommendations to the FICA Program based
on the fee being paid to Efficient by StoneCastle.
D. Wrap Fee Program
Efficient participates as an investment manager in a wrap fee program called ManagedPlan,
which is offered by Fiduciary Advisors, LLC. The portfolios and services offered by Efficient
through ManagedPlan are the same as those offered to clients that come directly to Efficient.
Those clients who are introduced to Efficient through the ManagedPlan program will receive
ManagedPlan’s Disclosure Brochure that describes the program, its services and related costs.
E. Assets Under Management
Efficient’s assets under management were $2,357,579,975 as of December 31, 2023 across all
programs described above. Of this amount, $75,132,843 were managed on a non-discretionary
basis.