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Greenwood Investors LLC: investment adviser
Greenwood Investors LLC is an investment adviser registered with the SEC (file 801-113075, CRD 155088). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.
- Assets managed
- $179.8M
- Discretionary
- 98%
- Accounts
- 43
- Employees
- 4
- In advisory roles
- 2
- Disclosures
- 0
Company page · SEC adviser record · Full Form ADV (PDF)
The firm reports no custody of client cash or securities.
Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.
Clients and fees
Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.
| Client type | Clients | Assets | Share |
|---|---|---|---|
| Individuals | 23 | $2.3M | 1.3% |
| High net worth individuals | 7 | $5.3M | 2.9% |
| Private funds and other pooled vehicles | 5 | $168.1M | 93.5% |
How it is paid
- A percentage of assets under your management
- Performance-based fees
- Other: Board directorship fees
Services
- Portfolio management for individuals and/or small businesses
- Portfolio management for pooled investment vehicles (other than investment companies)
- Portfolio management for businesses (other than small businesses) or institutional clients (other than registered investment companies and other pooled investment vehicles)
Who owns it
Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.
Direct owners (Schedule A)
| Owner | Type | Role | Stake | Since | Control | Public company |
|---|---|---|---|---|---|---|
| Steven Duncan Wood | Person | Managing member | E 75% or more | Sep 2010 | Yes | |
| Grace Carucci | Person | Silent member | A 5% to 10% | Jan 2014 | ||
| Joseph Edward Carucci | Person | Silent member | A 5% to 10% | Jan 2014 |
Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.
Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.
Disciplinary history
The firm answered No to every disciplinary question on Form ADV (Item 11).
The brochure
Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.
Form ADV Part 2A, filed Jul 14, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18
Item 4. Advisory business
A. Description of the Advisory Firm This firm was formed under the laws of the state of Delaware on November 8, 2010. The principal owner is Steven D. Wood. We're a bottoms-up, collaborative, concentrated global investment manager focused on areas of pessimism, structural inefficiencies and low competition. We particularly look to add value to the investments we make and collaborate with management teams or boards of directors. Our framework maximizes the risk-adjusted return profile of our portfolio while optimizing the qualitative and behavioral success factors on a continuum to ensure a wide variety of actionable opportunities that we can own for long periods of time.
Read the rest of Item 4 (754 more words)
This framework results in a concentrated portfolio of great managers guiding underappreciated companies through transformational moments in their history. After joining the board of directors of our largest investment in 2019, we have expanded our constructive engagement with portfolio companies with the aim of improving the fundamental trajectories of our investment portfolio.
B. Types of Advisory Services GreenWood Investors LLC (hereinafter “GWI”) offers the following services to advisory clients:
Investment Supervisory Services GWI manages funds and accounts according to its principles and process which results in a concentrated portfolio of the best ideas we can find around the world. We do deep and thorough research, which we make available to all our investors. We concentrate our efforts on a small portfolio of opportunities, which are selected in part based on our ranking framework, which is continuously evolving and, we hope, improving. GWI advises clients to size their asset allocation to their GWI account based on the individual goals, objectives, time horizon, and risk tolerance of each client. GWI creates an Investment Policy Statement for each client with a separate account, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in properly matching the portfolio sizing to each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: •
Investment strategy
•
Asset allocation
•
Asset selection
•
Risk tolerance
•
Regular portfolio monitoring
GWI manages its funds and accounts according to model portfolios but does make certain exceptions for unique situations among certain clients with respect to their work place considerations, risk tolerance levels and time horizon. GWI requests discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. However, we make exceptions in the case of certain sophisticated investors whose employers or investment mandates require pre-trade approval. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Performance based fees will be offered to qualified clients that subscribe to the GreenWood Global Micro Fund, LP, the GreenWood Global Fund, the GreenWood Builders Fund I, LP, the GreenWood Offshore Builders Fund I, the GreenWood Builders Fund II, LP, the GreenWood Offshore Builders Fund II, the GreenWood Builders Fund IV LP, the GreenWood Offshore Builders Fund IV, the GreenWood Builders Fund V LP, and the GreenWood Offshore Builders Fund V which are managed by GreenWood Investors LLC. Since the first quarter of 2019, we are only offering subscriptions to our investment funds to qualified investors and welcome non-qualified investors to open separate accounts.
Services Limited to Specific Types of Investments GWI limits its investments to equities, bonds, fixed income, debt securities, ETFs, REITs, options, futures, and private placements. GWI may use other securities as well to help diversify a portfolio when applicable.
C. Client Tailored Services and Client Imposed Restrictions GWI offers the same suite of services to all of its clients. Because we are highly focused on maintaining a concentrated portfolio of our highest conviction ideas, and continuously reallocate capital to the timeliest investments, we do not offer formal time horizon planning for investors. The Investment Policy Statement, which outlines each client’s current situation (income, tax levels, and risk tolerance levels), is used to size the client’s investment to the client’s restrictions, needs, and targets. We would prefer to have the investment sized in line with each investors’ own needs rather than change a portfolio for the investors’ needs. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs, and through separate accounts, we have an ability to exclude certain investments. However, if the restrictions prevent GWI from properly servicing the client account, or if the restrictions would require GWI to deviate from its standard suite of services, GWI reserves the right to end the relationship.
D. Wrap Fee Programs GWI does not participate in any wrap fee programs.
E. Amounts Under Management GWI has the following assets under management: Non-Discretionary/ Advisory*
Total as of 05/31/2026
Strategy
Discretionary
Builders Fund I
$61,087,475
$61,087,475
Builders Fund II
$20,208,274
$20,208,274
Builders Fund IV
$47,018,652
Builders V
$15,001,609
$15,001,609
Global Micro Fund
$10,108,279
$10,108,279
Traditional Accounts
$6,899,577
$1,556,071
$8,455,648
Total
$160,323,866
$3,375,551
$163,699,417
$1,819,480
$48,838,132
*In the case where we need pre-trade approval from a trustee or employer, although we have discretionary arrangements with many of these clients, we deem these accounts to be nondiscretionary given the trading restrictions in place.
Item 5. Fees and compensation
A. Fee Schedule Investment Supervisory Services Fees Total Assets Under Management
All Separate Accounts
Annual Management Fee
Performance Fee
1.5%
None
0.0%
15.0%
GreenWood Global Micro Fund, LP Founders Class (Closed)
Total Assets Under Management
Annual Management Fee
Performance Fee
1.0%
15.0% after a 5% hurdle
1.0%
10.0% after 12% compounded hurdle
Series A
1.0%
10.0% after a 5% annual hurdle
Series B
1.0%
10.0% after a 5% annual hurdle
Class A
1.0%
10.0% after a 5% annual hurdle
Class B
1.5%
15.0% after a 5% annual hurdle
Affiliated LP
1.0%
10.0% after a 5% annual hurdle
New LP
1.5%
15.0% after a 5% annual hurdle
Builders Class (Open) GreenWood Builders Fund I, LP GreenWood Builders Fund II, LP
GreenWood Builders Fund IV, LP
GreenWood Builders Fund V, LP
Read the rest of Item 5 (1,341 more words)
These fees are not negotiable, and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract for Separate Accounts and in the Subscription Documents for each fund. If we amend a fee agreement in the future for one investor, we intend to give the same option to all existing investors, or in the case the fees are lower, we will proactively apply it to all existing investors at the time, subject to possible incentives based on length of investment with the firm. Fees are paid quarterly in arrears, and separate account clients may terminate their contracts with same day, written notice. Fund investors may redeem their interests monthly, with no lockups, except as clearly stated in the Partnership Agreement or any other document between the fund and the client. The Limited Partners of GreenWood Builders Fund V LP are subject to a three (3) year lock-up period that begins on the effective date of the formation of GreenWood Builders Fund V LP. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization.
Performance-based Fees
New Qualified clients that subscribe to the GreenWood Global Micro Fund, LP, which is managed by GreenWood Investors LLC, pay an annual management fee of 1%. If the portfolio rises in value, then the client will pay 15% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Qualified clients that subscribe to the GreenWood Builders Fund I, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1%. If the portfolio rises in value, then the client will pay 10% on that increase in value, subject to a 12% annuallycompounded hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 12.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund II, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1%. If the portfolio rises in value, then the client will pay 10% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund IV, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1% or 1.5% based on the class the client subscribes to. The partnership offers two classes of capital accounts Class A and Class B. Class A is available to a limited partner that has an existing investment with a member of the General Partner of GreenWood Builders Fund IV, LP. All new clients without an existing investment with the general partner are offered to subscribe to Class B. Class A clients pay an annual management fee of 1% and Class B clients pay an annual management fee of 1.5%. If the portfolio rises in value, then the Class A client will pay 10% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Class B client will pay 15% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund V, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1% or 1.5% of the balance of each Limited Partner’s capital account, without regard to the profitability of the fund.
Limited Partners that maintain another investment with one or more members of the General Partner, will pay an annual management fee of 1%. All new clients without an existing investment with the general partner are subject to an annual management fee of 1.5%. If the portfolio rises in value, each limited partner pays a performance fee equal to 10% or 15% of each limited partner’s proportionate share of the net profits for the year. Ther rate of 15% of the net profits is for each investor that is not already an existing investor with one or more members of the General Partner and the rate of 10% of the net profits is for each investor that maintains another investment with one or more members of the General Partner. For all investors, the payment of performance allocation is subject to a hurdle that is calculated at a rate of 5% per annum on the invested capital in the shares. If the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Clients of our five international feeder funds, the GreenWood Global Fund, the GreenWood Offshore Builders Fund I, the GreenWood Offshore Builders Fund II, the GreenWood Offshore Builders Fund IV, and the GreenWood Offshore Builders Fund V pay the same fees as a result of their subscription to our domestic fund. In order to ensure all clients pay the same fees in their particular class or asset, and to simplify regulatory reporting, our Global Micro Fund and Global Fund have invested in the Builders Fund I, Builders Fund II, Builders Fund IV, and Builders Fund V. The fees incurred on these investments are waived by the Global Micro Fund and the Global Fund, to ensure no duplication of fees and to give these investors a more favorable fee structure on the Builders Fund investments.
B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid quarterly in arrears.
Payment of Performance-based Fees Performance-based fees are withdrawn directly from the client’s accounts with client’s written authorization or may be invoiced and billed directly to the client and clients may select the method in which they are billed. Fees are paid quarterly for the Global Micro Fund and only upon a return of capital or client redemption for the Builders Fund I, the Builders Fund II, Builders Fund IV and the Builders Fund V.
C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by GWI. Please see Item 12 of this brochure regarding broker/custodian.
D. Prepayment of Fees GWI collects its fees in arrears. It does not collect fees in advance.
E. Other Compensation Some of the firm’s supervised persons receive renumeration for serving on the executive board.
Item 6. Performance-based fees and side-by-side management
GWI manages funds that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) as well as accounts that are NOT billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because GWI or its supervised persons may have an incentive to favor accounts for which GWI and its supervised persons receive a performance-based fee. GWI addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance based fees.
Read the rest of Item 6 (897 more words)
GWI executes trades for both funds and accounts simultaneously through its trading system, and all clients receive the same share of an execution based on the net liquidation value of the account or fund. GWI seeks best execution and upholds its fiduciary duty for all clients. New qualified clients that subscribe to the GreenWood Global Micro Fund, LP, which is managed by GreenWood Investors LLC, will pay an annual fee of 1%. If the portfolio rises in value, then the client will pay 15% on that increase in value, after being subjected to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark”.
Qualified clients that subscribe to the GreenWood Builders Fund I, LP, which is managed by GreenWood Investors LLC, will pay an annual fee of 1.0%. If the portfolio rises in value beyond a 12% annually compounded hurdle rate, then the client will pay 10% on that increase in value after the hurdle. If the portfolio drops in value, then the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund II, LP, which is also managed by GreenWood Investors LLC, pay an annual fee of 1%. If the portfolio rises in value, then the client will pay 10% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund IV, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1% or 1.5% based on the class the client subscribes to. The partnership offers two classes of capital accounts Class A and Class B. Class A is available to a limited partner that has an existing investment with a member of the General Partner of GreenWood Builders Fund IV, LP. All new clients without an existing investment with the general partner are offered to subscribe to Class B. Class A clients pay an annual management fee of 1% and Class B clients pay an annual management fee of 1.5%. If the portfolio rises in value, then the Class A client will pay 10% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Class B client will pay 15% on that increase in value, subject to a 5% annual hurdle, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Qualified clients that subscribe to the GreenWood Builders Fund V, LP, which is also managed by GreenWood Investors LLC, pay an annual management fee of 1% or 1.5% of the balance of each Limited Partner’s capital account, without regard to the profitability of the fund. Limited Partners that maintain another investment with one or more members of the General Partner, will pay an annual management fee of 1%. All new clients without an existing investment with the general partner are subject to an annual management fee of 1.5%. If the portfolio rises in value, each limited partner pays a performance fee equal to 10% or 15% of each limited partner’s proportionate share of the net profits for the year. Ther rate of 15% of the net profits is for each investor that is not already an existing investor with one or more members of the General Partner and the rate of 10% of the net profits is for each investor
that maintains another investment with one or more members of the General Partner. For all investors, the payment of performance allocation is subject to a hurdle that is calculated at a rate of 5% per annum on the invested capital in the shares. If the portfolio drops in value, then the client will not incur a new performance fee until the portfolio surpasses the last highest value in addition to the 5.0% hurdle rate, adjusted for withdrawals and deposits, which is generally known as a “high water mark”. Performance fees are paid only upon a return of capital to investors. Clients that are paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes.
Item 7. Types of clients
GWI generally provides management supervisory services to the following Types of Clients: ❖ Endowments ❖ ❖ ❖ ❖
Institutional Investors Family Offices Individuals High-Net-Worth Individuals
Minimum Account Size There is an investment minimum, $10,000 for separate accounts and $100,000 for our funds, which may be waived by the investment advisor, based on the needs of the client and the complexity of the situation. The minimum investment in the GreenWood Global Micro Fund, LP is $100,000 and the same minimum applies for the GreenWood Builders Fund I, LP, the GreenWood Builders Fund II, LP, the GreenWood Builders Fund IV, LP, and the GreenWood Builders Fund V, LP.
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The Builders Fund I, the Builders Fund II, the Builders Fund IV, and the Builders Fund V serve as a single-name co-investments to affect constructive changes to our targeted companies. They are a limited life vehicles. From time to time, when GreenWood seeks to augment its share of company ownership via its institutional relationships, it will continue to launch coinvestment funds. It serves as a way for investors to increase their exposure to our highest conviction ideas.
Item 8. Methods of analysis, investment strategies and risk of loss
Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Our framework directs our intensive investigative efforts on a wide array of opportunities, which get published and closely disseminated in order to solicit feedback and continuously improve the fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Our collaborative network of partners, comprised of sophisticated investors, entrepreneurs and business owners, help us both find and diligence this steady stream of global opportunities. We are particularly attracted to business builders and engage our investments to improve the business trajectory and make decisions for long-term stakeholder success.
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Investment Strategies GWI participates in long term trading, short term trading, and short sales. Our annual portfolio turnover has ranged from 25-40%, which correlates to a holding period of 2.5-4.0 years on average. The time we hold is determined by the relative opportunity set we have, and opportunities for capital reallocation to better candidates. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.
Investment Strategies Accounts will include any of the following: equities, distressed bonds, options, and exchangetraded funds, all of which can go down in value. At times, these losses can become material, such as in 2008 when the equity markets were down more than 50% from their 2007 high.
GWI seeks to earn a total return on our investments, rather than aim to outperform a particular index or class of securities. Thus, while GWI will seek to manage the risks to the downside, the hedges GWI employs will not perfectly protect from such extreme market movements. GWI asks all clients to only allocate a portion of their total assets with which they can take risks with over a period of multiple years. Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short term trading and short sales generally hold greater risk and clients should be aware that there is a chance of material risk of loss using any of those strategies. Hedge exposure is primarily obtained through short sales, ETFs, bond shorts and purchasing put options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
C. Risks of Specific Securities Utilized GWI generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, it will at times utilize short sales. Short sales generally hold greater risk of capital loss and clients should be aware that there is a chance of material risk of loss using any of those strategies. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear.
Item 9. Disciplinary information
There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. However, as of December 31, 2025, GreenWood Builders Fund IV, LP, a fund managed by GreenWood Investors LLC, is involved in legal proceedings initiated by the Fund seeking annulment and declaration of nullity of the decision of the general meeting of The Swatch Group SA held on May 21, 2025, in which the Fund requests that the decision refusing the election of Mr. Steven Wood be annulled and that he be declared an elected member of the Board of Directors.
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In addition, GreenWood Investors LLC, as investment manager to the Fund, is engaged in a proxy contest with The Swatch Group SA on behalf of the Fund concerning seven governance proposals submitted for inclusion in the company’s Ordinary General Meeting scheduled for May 12, 2026. Legal costs related to these matters have been expensed as incurred. Based on advice from external legal counsel, GreenWood’s management believes that the likelihood
of an unfavorable outcome in the litigation is remote and that any potential loss is unlikely. The outcome of the proxy contest cannot be determined at this time; accordingly, no provision has been recorded for any future expenses related thereto. GreenWood’s management continues to monitor these matters, which have not had a material impact on the Fund’s financial position, results of operations, or liquidity. Clients or perspective clients can always view the CRD records for advisers at www.adviserinfo.sec.gov. The firm’s CRD # is 155088.
Item 10. Other financial industry activities and affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative Steven D. Wood nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer.
B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GWI nor its representatives are registered as a FCM, CPO, or CTA.
C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Steven Wood is currently the Managing Member of GreenWood Performance Investors, LLC, the general partner of GreenWood Global Micro Fund, LP, a fund launched in February 2014, GreenWood Builders Fund I, LP, a fund launched in January 2018, and GreenWood Builders Fund II, LP, a fund launched in July 2021.
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Steven Wood is also the Managing Member of GreenWood Partners IV LLC, the general partner of GreenWood Builders Fund IV, LP, a fund launched in July 2024 and GreenWood Partners V LLC, the general partner of GreenWood Builders Fund V LP, a fund launched in January 2025. GreenWood Investors, LLC serves as the investment advisor to GreenWood Global Micro Fund, LP, GreenWood Global Fund, GreenWood Builders Fund I, LP, GreenWood Offshore Builders Fund I, GreenWood Builders Fund II, LP, GreenWood Offshore Builders Fund II, GreenWood Builders Fund IV, LP, GreenWood Offshore Builders Fund IV, GreenWood Builders Fund V LP, and GreenWood Offshore Builders Fund V and manages the accounts alongside other clients whose accounts follow traditional strategy. Steven Wood appointed Christopher Torino to act as the portfolio manager of GreenWood Builders Fund II LP. GWI always acts in the best interest of the client.
Steven Wood is also currently Director of The Builders Institute Inc., which aims to bring the same principle of long-term value creation to a much broader audience. As GreenWood Investors has increasingly looked to support the value-builders managing our investments, The Builders Institute will expand this support beyond our portfolio. Steven Wood also serves as an Independent Director on the Board of Directors of Avio S.p.A, and Cortland Associates. He receives compensation for his services in relation to these roles.
D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections GWI does not utilize nor select other advisors or third party managers. All assets are managed by Steven Wood and Chris Torino at GreenWood Investors LLC.
Item 11. Code of ethics, participation in client transactions and personal trading
Transactions and Personal Trading A. Code of Ethics Our firm has adopted Code of Ethics pursuant to Rule 204A-1 of the Investment Advisers Act of 1940 which covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Record-keeping, Annual Review, and Sanctions. Any existing or prospective clients may request a copy of our Code of Ethics from management.
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B. Recommendations Involving Material Financial Interests GWI does not recommend that clients buy or sell any security in which a related person to GWI has a material financial interest other than the obvious investments our employees have in our funds. GWI employee investments in our funds carry the same terms and fees that we give to all other investors.
C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GWI may buy or sell securities for themselves that they also recommend to clients. GWI will always document any transactions that could be
construed as conflicts of interest and will always transact client business before their own when similar securities are being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GWI may buy or sell securities for themselves at or around the same time as clients. GWI will not trade non-mutual fund or non-ETF securities 5 days prior to or 5 days after trading the same security for clients.
Item 12. Brokerage practices
A. Factors Used to Select Custodians and/or Broker/Dealers The Custodian, Interactive Brokers LLC, was chosen based on their relatively low transaction fees, access to international markets, bond markets and ETFs. GWI will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian.
1. Research and Other Soft-Dollar Benefits GWI receives no research, product, or service other than execution from a broker-dealer or third-party in connection with client securities transactions (“soft dollar benefits”).
2. Brokerage for Client Referrals GWI receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party.
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3. Clients Directing Which Broker/Dealer/Custodian to Use GWI will not allow clients to direct GWI to use a specific broker-dealer to execute transactions. Clients must use GWI recommended custodian (broker-dealer). Not all investment advisers require their clients to direct brokerage. By requiring clients to use our specific custodian, GWI may be unable to achieve most favorable execution of client transactions, and this may cost clients’ money over using a lower-cost custodian. We review custodians annually to ensure the competitiveness of our Custodian.
B. Aggregating (Block) Trading for Multiple Client Accounts GWI maintains the ability to block trade purchases across accounts. While block trading may benefit clients by purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of our custodian.
Item 13. Review of accounts
A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least quarterly by Steven D. Wood, Managing Member and Christopher Torino often much more regularly. Steven D. Wood is the chief advisor and is instructed to review clients’ accounts with regards to the model portfolio account, their investment policies and risk tolerance levels. All accounts at GWI are assigned to these reviewers.
B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events. Changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance) will trigger a review of the client’s size of its investments with GreenWood.
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C. Content and Frequency of Regular Reports Provided to Clients Each client receives monthly, quarterly or annually a written report detailing the client’s account which will come from the custodian or fund administrator. GWI also provides regular written communications to clients with commentary on its portfolio. We have written quarterly letters, and all investors have access, if they choose, to ongoing alerts, reports, and research notifications on each position we hold. We believe transparency of our holdings not only helps our own process but keeps investors and GWI aligned.
Item 14. Client referrals and other compensation
A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes)
GWI does not receive any economic benefit, directly or indirectly from any third party for advice rendered to GWI clients.
B. Compensation to Non –Advisory Personnel for Client Referrals GWI has an arrangement in place with an independent, unaffiliated third party (referred to as “the Promoter”) that markets our investment advisory services and refers prospective clients to us. In exchange for these introductions and in accordance with SEC Rule 206(4)-1, we pay the Promoter a Servicing Fee for as long as any Referred Investor has an investment with GreenWood.
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The Promoter will receive a percentage of the advisory fees that we collect from the client for a specified period and does not result in any increased costs, hidden expenses, or higher advisory fees for the referred client. This compensation arrangement creates a material conflict of interest, as the Promoter has a financial incentive to recommend our investment advisory services over alternative options that may have different fee structures or do not compensate them.
Other Compensation GreenWood personnel receive compensation for serving on executive boards and we may have certain restrictions on our ability to purchase proprietary products. We also have an incentive to advise you to invest in the GreenWood Global Micro Fund LP, the GreenWood Builders Fund I LP, the GreenWood Builders Fund II LP, the GreenWood Builders Fund IV LP, or the GreenWood Builders Fund V LP because these funds are also managed through GreenWood Investors LLC.
Item 15. Custody
GWI does not take custody of client accounts at any time. Custody of client’s accounts is held primarily at Interactive Brokers LLC. Clients will receive account statements from the custodian and should carefully review those statements. For investors in the GreenWood Global Micro Fund, LP, the GreenWood Builders Fund I, LP, the GreenWood Builders Fund II, LP, the GreenWood Builders Fund IV, LP, and the GreenWood Builders Fund V, LP we are deemed to have custody for the brief period of time when the investor subscribes or redeems from the fund. To remain compliant with SEC regulation, we delegated the distribution of confirmations and monthly statements to an independent third-party administrator. All financial statements that we distribute to investors are also prepared by an independent auditor.
Item 16. Investment discretion
For all client accounts where GWI provides ongoing supervision, GWI maintains limited power of authority over client accounts with respect to securities to be bought and sold and number of securities to be bought and sold. All buying and selling of securities is explained to clients in detail before an advisory relationship has commenced.
Item 17. Voting client securities
GWI will not ask for, nor accept voting authority for client securities in separately managed accounts. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. GreenWood Performance Investors LLC, the general partner to GreenWood Global Micro Fund LP, GreenWood Builders Fund I LP, GreenWood Builders Fund II LP, GreenWood Partners IV LLC, the general partner to GreenWood Builders Fund IV LP and GreenWood Partners V LLC, the general partner to GreenWood Builders Fund V LP, do accept voting authority for the funds managed by GWI. In addition, for all Builders funds, GreenWood utilizes Institutional Shareholder Services, Inc. (“ISS Stoxx”) for voting and/or ballot administration.
Item 18. Financial information
A. Balance Sheet GWI does not require nor solicit prepayment of fees in advance, take custody of client funds or securities, and therefore does not need to include a balance sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither GWI nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years GWI, as well as its principal, has not been the subject of a bankruptcy petition ever.
Other brochures on file
- Form ADV Part 2B - Steven Wood, Jul 14, 2026
- Form ADV Part 2B - Christopher Torino, Mar 31, 2026
Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.