Wellspring Capital Advisors, LLC is a registered advisor providing investment consulting services to insurance companies. Wellspring was formed in 2003. Steven Wayne Guyer and Bradley F Herrick are the only principals. Wellspring provides insurance companies customized, objective and independent investment advice. Investment advice is tailored to the individual needs of Wellspring's insurance clients. Wellspring primarily gives advice on a Non-Discretionary basis, clients may often impose restrictions on the types of securities they choose to invest in. As of 12/31/18, Wellspring advises on $3,156,000,000 on a Non-Discretionary basis. This figure is based on manager, custodian and client reports as of 12/31/18. Wellspring has $209,000,000 of Discretionary assets based on manager, custodian and client reports as of 12/31/18. please register to get more info

Wellspring's fees are based on assets under advisement and under some circumstances a flat annual fee has been negotiated. Fees can vary depending on the level of investment services provided and are negotiable. Clients are billed quarterly. Clients may be billed for reasonable travel expenses. If a client chooses to legally terminate their contract before the end of a calendar quarter after the duration of the legal contract term and after given legal stated notice, Wellspring fees will be prorated only for the duration that assets were under advisement. Wellspring does not receive financial compensation for the sale of securities or other investment products. please register to get more info

Wellspring does not currently accept performance-based fees. please register to get more info

Wellspring provides investment advice exclusively to Insurance Companies. While there is no minimum account size there are minimum fees.

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Wellspring uses Fundamental, Technical and Cyclical analysis to provide investment advice. Advice may be given on long and short-term purchases. Investing in securities involves risk of loss and clients should be prepared to bear this risk. Investors may lose some or all their investment. Wellspring gives advice on Equity Securities, Warrants, a variety of Fixed Income Securities including Corporate Debt Securities, Mortgage Backed Securities, Asset Backed Securities, Commercial Mortgage Backed Securities, Municipal Securities, Commercial Paper, Certificates of Deposit, , Mutual Fund Shares, United States Government Securities, Options Contracts on Securities and Commodities, Futures Contracts on Tangibles and Intangibles and Interests in Partnerships investing in Real Estate, Oil, Gas and other types of investments. Wellspring does not recommend one security type exclusively. please register to get more info

No owner or employee of Wellspring has been convicted of or plead guilty or nolo contendere ("no contest") to any felony, misdemeanor that involved investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or a conspiracy to commit any of these offenses. No owner or employee of Wellspring is named subject of a pending criminal proceeding that involves an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, or extortion; or a conspiracy to commit any of these offenses.

No owner or employee of Wellspring has been found to have been involved in a violation of an investment-related statute or regulation.

No owner or employee of Wellspring has been the subject of any order, judgment, or decree permanently or temporarily enjoining, or otherwise limiting Wellspring from engaging in any investment-related activity, or from violating any investment-related stature, rule, or order.

No owner or employee of Wellspring has been found to have caused an investment-related business to lose its authorization to do business by an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority.

No owner or employee of Wellspring has been found to have been involved in a violation of an investment-related statute or regulation and subject of an order by the agency or authority denying, suspending, or revoking the authorization of Wellspring by an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. This includes denying, suspending, or revoking the authorization of Wellspring or a management person to act in an investment-related business; barring or suspending Wellspring or a management person's association with an investment- related business; Otherwise significantly limiting Wellspring or a management person's investment-related activities; Or imposing a civil money penalty of more than $2,500 on your firm or a management person. No owner or employee of Wellspring has been found to have caused an investment-related business to lose its authorization to do business by a self-regulatory organization (SRO) proceeding. No owner or employee of Wellspring was found to have been involved in a violation of the SRO's rules and was barred or suspended from membership or from association with other members, or was expelled from membership, or otherwise significantly limited from investment-related activities, or fined more than $2,500 from a self-regulatory organization proceeding. please register to get more info

No owner or employee of Wellspring are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. No owner or employee of Wellspring are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.

Wellspring has no relationship or arrangement that is material to its business or clients with broker-dealer, municipal securities dealer, or government securities dealer or broker, investment company or other pooled investment vehicle (including mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund), futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift institution, account or accounting firm, lawyer or law firm, pension consultant, real estate broker or dealer, or sponsor or syndicator of limited partnerships.

The only relationship Wellspring has is with Wellspring's insurance company clients who receive investment related advice from Wellspring.

Wellspring has one relationship with another investment adviser, Roble Belko & Company. Wellspring earned referral fees by referring three individuals to Roble Belko & Company. Roble Belko & Company is an investment advisory firm located in Sewickley, PA offering wealth and risk management services for high net worth individuals, families and small institutions. Steven Guyer has most of his personal investments managed by this firm as well as his in-laws. Steven Guyer and relatives pay management fees that are identical to the fee paid by individuals referred to Roble Belko & Company. The referral fee paid to Wellspring represented approximately 2% of total Wellspring revenue. Wellspring's referral arrangement with Roble Belko & Company in no way creates a material conflict of interest for Wellspring's clients. Wellspring does not recommend or select other investment advisers for its insurance clients that would create any conflict. please register to get more info

Wellspring's Code of Ethics addresses the monitoring of the proprietary trading activities of its owner and employees. A copy is available upon request. Wellspring's owner and employees do not recommend to clients, or buy and sell for client accounts, securities in which Wellspring has a material financial interest. Wellspring's owner and employees may own similar broad market ETFs that are also in client's portfolios. Wellspring's owner and employees will not recommend securities to clients or buy and sell for client accounts at or about the same time that Wellspring's owner and employees buy or sell the same securities for their own accounts.

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For Non-Discretionary clients, Wellspring may recommend brokers to execute various ETF trades on behalf of those clients. Wellspring does not have discretion to select brokers or negotiate brokerage commissions on behalf of those clients. Clients need to give authorization by email to brokers to execute specific trades. Various broker dealers whom our clients may execute ETF trades through provide Wellspring with market insight, investment and manager research and in certain instances access to managers. In addition, our clients have custody relationships at various custodial banks and may choose not to set up another custody relationship to pay lower commissions. Recommending brokers does not create conflicts of interest for Wellspring and Wellspring's clients. Due to the Non-discretionary nature of the relationship, clients are free to use any broker they choose.

For Non-Discretionary clients, Wellspring does not request or require clients to execute transactions through a specified broker-dealer. Wellspring may recommend a broker-dealer. Although Wellspring may believe that a recommended broker-dealer's commissions and execution are competitive, clients are encouraged to shop for the best execution and commissions and free to direct trades through any broker-dealer they choose. For Non-Discretionary clients, Wellspring does not have the authority or ability to aggregate trades for various client accounts under any circumstances. For Discretionary clients, Wellspring uses several different brokers to achieve best execution. Wellspring does not receive compensation from the brokers. Wellspring’s brokerage practices do not create conflicts of interest for its clients. Wellspring does not receive client referrals from broker-dealers or third parties. please register to get more info

Client accounts are reviewed quarterly, monthly and sometimes times daily as necessary. Steven Guyer CFA® and Bradley Herrick CFA®, are responsible for reviews and are assisted by Aaron McLeod. Many factors trigger other than periodic client account reviews including but not limited to market volatility, rebalancing and enterprise risk management reviews.

Clients receive written reports on a quarterly basis and often more frequently depending on each specific client's needs.

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Wellspring receives compensation only from its clients for providing investment advice to its clients.

Wellspring does not compensate anyone outside of Wellspring for client referrals.

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Wellspring does not take custody of client's assets.

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Wellspring does not have or accept discretionary authority to manage securities accounts on behalf of its Non-Discretionary accounts. Wellspring does accept discretion for its Discretionary accounts as outlined in the investment management agreement signed by both parties.

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Wellspring does not and will not accept authority to vote client securities for Non-Discretionary accounts but will vote client securities for its Discretionary accounts. please register to get more info

Wellspring does not require or solicit any prepayment of fees. Wellspring does not have discretionary authority or custody of client funds or securities and does not require or solicit any prepayment of fees. Wellspring has not been the subject of a bankruptcy petition at any time during the past ten years. Supplemental Brochure Wellspring Capital Advisors, LLC One East Wacker Drive - Suite 2805 Chicago, IL 60601 Phone: 312-346-6882 Fax: 312-896-1476 www.wellspringcap.com This brochure supplement provides information about Steven Wayne Guyer, Bradley Franklin Herrick and Aaron Frank McLeod which supplements the Wellspring Capital Advisors, LLC brochure. You should have received a copy of that brochure. Please contact Steven Wayne Guyer if you did not receive Wellspring Capital Advisors’ brochure or if you have any questions about the contents of this supplement. Steven Wayne Guyer Year of Birth 1962 Educational Background and Business Experience B.A. Economics, Northwestern University Business Positions Held in the past Five Years:

Partner, Chief Compliance Officer Wellspring Capital Advisors, LLC One East Wacker Drive - Suite 2805 Chicago, IL 60601

Professional Designations Received: CFA® - Chartered Financial Analyst 1992, issued by CFA Institute

Disciplinary Information

There is no disciplinary history to disclose.
Other Business Activities

There are no other business activities to disclose.

Additional Compensation

There are no additional compensation arrangements to disclose.

Supervision

Steven Guyer, like all Wellspring employees, is subject to the firm's compliance in the performance of his job duties. He must comply with the firm's policies and procedures. The advice Mr. Guyer provides is in accordance with the firm's written compliance procedures. Mr. Herrick conducts periodic reviews of Steven Guyer’s personal trading activities and obtains written representations from Mr. Guyer regarding his understanding of the firm's policies and procedures. Finally, the firm's Code of Ethics sets high standards for ethical business conduct and contains significant safeguards to mitigate conflicts and otherwise protect clients from abuses. For additional detail regarding the firm's Code of Ethics see "Code of Ethics, Participation or Interest in Client Transactions and Personal Trading" in Wellspring’s brochure. Mr. Herrick can be reached at 312-768-7462. Bradley Franklin Herrick Year of Birth 1977 Educational Background and Business Experience B.A. Liberal Arts, Wabash College Business Positions Held in the past Five Years:

Partner Wellspring Capital Advisors, LLC One East Wacker Drive - Suite 2805 Chicago, IL 60642

Professional Designations Received: CFA® - Chartered Financial Analyst 2006, issued by CFA Institute

Disciplinary Information

There is no disciplinary history to disclose.
Other Business Activities

There are no other business activities to disclose.

Additional Compensation

There are no additional compensation arrangements to disclose.

Supervision

Bradley Herrick, like all Wellspring employees, is subject to the firm's compliance in the performance of his job duties. He must comply with the firm's policies and procedures. The advice Mr. Herrick provides is in accordance with the firm's written compliance procedures. Mr. Guyer conducts periodic reviews of Bradley Herrick’s personal trading activities and obtains written representations from Mr. Herrick regarding his understanding of the firm's policies and procedures. Finally, the firm's Code of Ethics sets high standards for ethical business conduct and contains significant safeguards to mitigate conflicts and otherwise protect clients from abuses. For additional detail regarding the firm's Code of Ethics see "Code of Ethics, Participation or Interest in Client Transactions and Personal Trading" in Wellspring’s brochure. Mr. Guyer can be reached at 312-346-6882.
Aaron Frank McLeod
Year of Birth 1972 Educational Background and Business Experience B.A. Biology, University of St. Thomas Business Positions Held in the past Five Years:

Analyst Wellspring Capital Advisors, LLC One East Wacker Drive - Suite 2805 Chicago, IL 60601

Disciplinary Information

There is no disciplinary history to disclose.
Other Business Activities

There are no other business activities to disclose.

Additional Compensation

There are no additional compensation arrangements to disclose.

Supervision

Aaron Frank McLeod, like all Wellspring employees, is subject to the firm's compliance in the performance of his job duties. He must comply with the firm's policies and procedures. The advice Mr. McLeod provides is in accordance with the firm's written compliance procedures. Mr. Guyer conducts periodic reviews of Aaron McLeod’s personal trading activities and obtains written representations from Mr. McLeod regarding his understanding of the firm's policies and procedures. Finally, the firm's Code of Ethics sets high standards for ethical business conduct and contains significant safeguards to mitigate conflicts and otherwise protect clients from abuses. For additional detail regarding the firm's Code of Ethics see "Code of Ethics, Participation or Interest in Client Transactions and Personal Trading" in Wellspring’s brochure. Mr. Guyer can be reached at 312-346-6882. please register to get more info