href="mailto:compliance@strategasrp.com"> for
assistance in identifying the current information for
each Platform.
Model Delivery Services
SAM offers licenses to use Model Portfolios to
certain Platforms, to receive and use the Model
Portfolios, including regular updates to the portfolio
composition and recommended rebalancing
thereto. The Model Portfolios are not tailored in any
way to the client or underlying clients of such
clients. However, as noted previously, if requested
by a client, SAM considers providing stock picks to
supplement the Model Portfolio that the client or
the client’s client may use to meet its needs or
preferences. Under Model Delivery Services, SAM
does not exercise any investment discretion (i.e.,
it does not have the responsibility of trading based
on the Model Portfolio), and does not vote proxies.
Clients that receive a Model Portfolio are
responsible for assessing initially and on an
ongoing basis the viability and suitability of any
investment portfolio decision they or their designee
makes for themselves, their underlying clients or
third parties, including decisions made based on
the Model Portfolio. Underlying clients of a client
are not considered clients of SAM when SAM
provides Model Delivery Services.
Portfolio Management Services
SAM also offers Portfolio Management Services as
an adviser or sub-adviser to client accounts. These
accounts may include individuals, trusts, family
offices, companies, non-profits, corporations,
other investment advisers, investment companies,
and other institutional accounts. The client selects
a Model Portfolio(s) based on the client’s
objectives, and then agrees to have the client’s
account managed in accordance with the selected
Model Portfolio and (if applicable) SAM’s
supplemental stock picks and client-imposed
investment restrictions. In providing Portfolio
Management Services to client accounts, SAM
manages the accounts with discretion. SAM’s
advice is limited to these services.
A client obtaining Portfolio Management Services is
responsible for providing SAM information that
SAM reasonably requires in order to provide the
services selected by the client including, but not
limited to, any investment policy statement and
anticipated liquidity needs. SAM will rely on this
information when providing its advisory services. A
client is also responsible for informing SAM in
writing of any material change in circumstances
that might materially affect the manner in which
the client’s assets should be invested.
Important Note for Platform and Wrap Fee
Program Clients
SAM does not sponsor a wrap fee program, i.e., a
single fee charged to the client for bundled services
such as investment advice and brokerage services.
However, some Platforms offer SAM’s Model
Portfolios as part of a wrap fee program sponsored
by the Platform (the “Program Sponsors”). SAM
manages wrap fee accounts similar to other non-
wrap fee separately managed accounts pursuant to
the Model Portfolio selected. For accounts that are
in a wrap fee program, SAM receives a portion of
the wrap fee for SAM’s services. A list of Program
Sponsors is included on Schedule D to SAM’s Form
ADV Part 1A, which is available at the SEC’s
website at
www.adviserinfo.sec.gov.
Platform clients who select SAM to manage their
assets through a Platform, including through wrap
fee programs, typically do so under either a “single
contract” or “dual contract” arrangement.
Under a single contract arrangement, a client
enters into an agreement with the Program
Sponsor and the Program Sponsor, in turn, enters
into a subadvisory or similar agreement with SAM
on the client’s behalf. This type of arrangement is
frequently referred to as a single contract
arrangement because there is only one contract
between the client and the Platform; the client
does not have an agreement directly with SAM.
Clients with single contract arrangements typically
are subject to a wrap fee arrangement with the
Platform and pay an asset-based wrap fee to the
Program Sponsor and, out of that wrap fee, the
Program Sponsor pays an advisory fee to SAM.
Under a dual contract arrangement, the client has
two contracts; one contract with the Platform and
another contract with SAM. Clients with a dual
contract arrangement pay to SAM an advisory fee
in addition to the fee they pay to the Platform.
Program Sponsors generally assist a Platform client
with the selection of SAM (or may have the
discretion to select SAM) to manage the assets in
the client’s account maintained at the Program
Sponsor. They generally also provide trade
execution services and custodial services for the
client’s account as part of the wrap fee paid by the
client.
SAM participates in programs offered by Platforms
in one of two ways. First, SAM may manage client
portfolios with full investment discretion (i.e.,
Portfolio Management Services described above).
Alternatively, SAM may provide the Program
Sponsor with Model Portfolios, or other advice or
consulting services regarding the asset allocation
strategies, that the Program Sponsor provides to
clients (i.e., Model Delivery Services described
above). Platform clients are not considered clients
of SAM when SAM provides Model Delivery
Services.
If SAM is selected to manage the assets in a client
account maintained by the Program Sponsor, SAM
will manage the client’s account with full
investment discretion. Unless the client or Program
Sponsor directs SAM to do otherwise, SAM will
select the broker-dealers that will execute client
trades.
If SAM provides the Program Sponsor with model
portfolios, advice or consulting services, SAM will
not manage the client’s account or select broker-
dealers to execute client trades.
If a client is participating in a program sponsored
by a Platform, the client should review the client’s
agreement with the Platform and the Platform’s
Form ADV Part 2A Brochure for a full description of
the services provided and fees charged by the
Platform. A client should also review the sections
entitled “Fees and Compensation” and “Investment
Discretion” below for more information.
SEC-Registered Investment Companies
SAM makes its advisory Portfolio Management
Services available to SEC-registered investment
companies (such as mutual funds or exchange
traded funds (“ETFs”)) that seek an investment
strategy consistent with the relevant Model
Portfolio. Strategas acts as investment advisor to
the Strategas Global Policy Opportunities ETF
(SAGP) and Strategas Macro Thematic
Opportunities ETF (SAMT). Further, on January 18,
2024, a filing under Rule 485(a) of the Securities
Act of 1933 was made with the SEC relating to a
preliminary prospectus and statement of additional
information (“SAI”) of the Strategas Macro
Momentum ETF (SAMM) for which SAM is intended
to act as investment advisor. As of the date of this
Brochure, SAMM’s inception date is expected to
occur on or around April 4, 2024. SAM may modify
its Model Portfolios in connection with any sub-
advisory services to a mutual fund or other SEC-
registered investment company in order to comply
with applicable investment restrictions under the
Investment Company Act of 1940, as amended, or
as set forth in the fund prospectus or SAI.
Information concerning a mutual fund, including a
description of the services to be provided by and
the advisory fees payable to SAM, is contained in
the fund’s prospectus or other offering documents.
Investment advice is provided on a discretionary
basis in SAM’s capacity as advisor or sub-adviser,
meaning that the fund authorizes SAM to make all
investment decisions, subject to applicable
restrictions and the supervision of the fund’s
primary adviser and the fund’s board of trustees.
Assets Managed
As of December 31, 2023, SAM had approximately
$446,469,469 in regulatory assets under
management, which was managed on a
discretionary basis, and $152,986,733 in non-
discretionary assets under advisement.