BLUESTEM FINANCIAL ADVISORS, LLC

The portfolio is highly diversified, consisting of 30 individual holdings. The investment strategy is explicitly passive and index-oriented, relying heavily on Exchange Traded Funds (ETFs) to achieve broad market exposure. The portfolio is heavily concentrated in ETFs, which comprise 97.7% of the total value ($252.85M), with individual equities making up a negligible fraction. The structure suggests a core-satellite approach where the "core" is composed of broad market index funds, though in this specific filing, the entire portfolio appears to be constructed as a single strategic asset allocation model.

2. Key Holdings

The portfolio is dominated by a few massive "core" positions that establish the foundational asset allocation. The top two holdings, BND (Vanguard Total Bond Market ETF) and IVV (iShares Core S&P 500 ETF), have nearly identical weightings, representing 21.32% ($55.19M) and 21.13% ($54.69M) of the portfolio, respectively. This creates an almost perfectly balanced split between domestic fixed income and domestic large-cap equity as the primary anchors.