Allegheny Financial Group, LTD (“Allegheny”) is a registered investment adviser which offers asset management
services based on the individual needs of the client. This Brochure provides a description of the advisory services
offered under the Allegheny Financial Group Wrap Fee Program.
For more information about Allegheny’s other investment advisory services, please contact your advisor for a copy
of a similar brochure that describes such services or go to www.adviserinfo.sec.gov.
Services
Investment Management and Financial Planning
Allegheny provides comprehensive portfolio management and financial planning services. Clients selecting this
service are charged a portfolio management fee, described in Item 5 below. Allegheny provides continuous advice
to a client regarding the investment of client funds based on the individual needs of the client. Through personal
discussions in which goals and objectives based on a client's particular circumstances are established, we develop
a client's personal investment strategy and create and manage a portfolio based on that strategy. During our data
gathering process, we determine the client’s individual objectives, time horizons, risk tolerance and liquidity
needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition
and background. Clients will receive reports reflecting the value and status of their uniquely designed portfolio.
Selecting fund managers is a large part of our service as an advisory firm. Allegheny uses original and proprietary
investment research conducted by the firm’s research department and investment committee. We manage
advisory accounts on a discretionary or non-discretionary basis. Clients may impose reasonable restrictions on
investing in certain securities, types of securities, or industry sectors. Account supervision is guided by the client's
stated goals, objectives, risk tolerance, as well as tax considerations.
In cases where the Client has selected non-discretionary management, the implementation of any or all
recommendations is solely at the discretion of the Client. Allegheny will work with the client to create a client
profile based on the client’s investment objectives and situation. Recommendations in mutual funds, stocks, bonds
or other assets of any kind will be consistent with the client’s investment objectives and restrictions set forth in the
client profile and implementation of those recommendations will be on direction from the client. Additionally,
clients may place unsolicited trades in their account.
Clients receiving these services participate in Allegheny’s Wrap Fee Program for which Allegheny receives a fee.
See the Allegheny Wrap Fee Brochure for additional details.
Streamlined Account Management (“SAM”)
Allegheny offers Streamlined Account Management (“SAM”) as a solution for clients who have lower asset levels or
do not engage Allegheny for financial planning services. We manage SAM accounts on a discretionary basis.
Clients selecting this service are charged a percentage of the value of billable assets listed on the Investment
Management Agreement and will be billed quarterly or semi-annually.
The following services are included with the SAM program:
Investment Strategy - Develop and implement an investment strategy by selecting positions and
controlling risk through diversification of assets and perform ongoing monitoring of the strategy in
relation to the criteria provided by the Client.
Performance Reports - Prepare periodic reports reviewing the performance of the investment portfolio, as
well as comparing the performance thereof to benchmarks with Client. The information used to generate
the reports will be derived directly from information such as statements provided by Client, investment
providers, and/or third parties.
Other Services - other tasks and administrative services required in connection with opening, closing and
managing the Client’s accounts, assisting with distributions and other assistance as required.
Clients receiving these services participate in Allegheny’s Wrap Fee Program for which Allegheny receives a fee.
See the Allegheny Wrap Fee Brochure for additional details.
Effective in 2023 Allegheny will be opening new wrap fee program accounts and transitioning their existing
advisory clients in stages to the Fidelity Advisory platform.
Assets for new and transitioned accounts are held at Fidelity Brokerage Services (“Fidelity”) a FINRA registered
broker- dealer, member SIPC. Fidelity acts as custodian and executing broker-dealer for transactions placed in
program accounts and provides other administrative services as described throughout this Brochure. You
cannot request that your orders be executed through another broker-dealer as part of the wrap fee program.
Clients should understand that not all advisors require their clients to select a certain broker. By selecting
Fidelity as the broker, clients may be unable to achieve the most favorable execution of client transactions.
Therefore, this practice may cost clients more money. Clients will be subject to separate fees and expenses
charged by Fidelity. Allegheny receives support services and/or products from Fidelity, many of which assist
Allegheny to better monitor and service program accounts maintained at Fidelity however, some of the
services and products benefit Allegheny and not client accounts.
Assets for legacy accounts are held at National Financial Services (“NFS”), a FINRA registered broker- dealer,
member SIPC. NFS acts as custodian and executing broker-dealer for transactions placed in program accounts,
and provides other administrative services as described throughout this Brochure. You cannot request that
your orders be executed through another broker-dealer. Allegheny Investments LTD (“AI”), is a dually
registered investment adviser and licensed broker-dealer. Allegheny is under common control with AI and the
directors of Allegheny are also the directors of AI. AI is the introducing broker-dealer for legacy program
accounts. Effective August 1, 2023, Allegheny will no longer without prior authorization open new client
brokerage accounts through NFS utilizing Allegheny’s affiliated broker dealer as introducing broker. Since
associated persons of Allegheny are registered with AI, the affiliated broker-dealer, this presents a conflict of
interest. Clients should understand that not all advisors require their clients to select a certain broker. By
selecting AI/NFS as the broker, clients may be unable to achieve the most favorable execution of client
transactions. Therefore, this practice may cost clients more money. Clients will be subject to separate fees and
expenses charged by NFS. Allegheny receives support services and/or products from NFS, many of which assist
Allegheny to better monitor and service program accounts maintained at NFS; however, some of the services
and products benefit Allegheny and not client accounts.
Fees
In the Allegheny Financial Group Wrap Fee Program, clients pay Allegheny a single advisory fee for advisory
services and execution of transactions. Clients do not pay brokerage commissions, markups or transaction
charges for execution of transactions in addition to the advisory fee. The advisory fee is negotiable between
the client and Allegheny and is set out in the advisory agreement. The advisory fee is a percentage based on
the value of all assets in the account, including cash holdings. The maximum advisory fee for newly executed
advisory agreements is 1.00%. The advisory fee may be higher than the fee charged by other investment
advisors for similar services. The advisory fee is paid to Allegheny. Allegheny does not accept performance-
based fees for program accounts.
The advisory fee is deducted from the account by NFS for legacy accounts and by Fidelity for new and
transitioned accounts and paid to Allegheny based on a written authorization from the client. Allegheny
calculates the advisory fee in advance and provides the debit instruction to the custodian based on the billing
frequency stated in the advisory agreement; typically, semi- annually or annually. In limited circumstances,
clients are invoiced for their fees. If the advisory agreement is terminated before the end of the period, client is
entitled to a pro-rated refund of any pre-paid advisory fee based on the number of days remaining in the billing
period after the termination date.
Portfolio Management (PMA)
Portfolio management fees are calculated as a percentage of assets under management and generally billed at
least semi-annually. Fees are billed in advance or arrears, in accordance with the terms of the portfolio
management agreement. Instructions will be provided to the client’s qualified custodian to have the advisory fees
deducted from your account. In limited circumstances, Allegheny invoices clients for their fees as described in the
client’s portfolio management agreement. The following are the portfolio management fees payable by the client
to Allegheny:
1.00% on the first $2,500,000 of assets under management
0.65% on the amount from $2,500,000 to $5,000,000
0.50% on the amount from $5,000,000 to $10,000,000
0.45% on the amount from $10,000,000 to $25,000,000
0.40% on the amount from $25,000,000 to $50,000,000
0.35% on the amount of assets over $50,000,000
Allegheny, in its sole discretion, has the right to deviate from this schedule. A client’s total fee may exceed the
schedule above when flat or hourly fees apply. Allegheny permits existing clients to continue to be billed according
to previously published ADV schedules for cases where the relationship was established under the then published
ADV terms. Previously established fee schedules will be calculated differently than the schedule stated
above, in
accordance with that client’s management agreement. Allegheny retains the right to negotiate fees on a client-by-
client basis. Each client’s facts, circumstances and needs are considered in determining the client fee. Allegheny
considers the complexity of the client, amount and types of assets managed, related accounts and other factors.
For the purpose of asset management fee calculations Allegheny reserves the right to combine the advisory
accounts of immediate family members or other related accounts. Allegheny, in its sole discretion, permits an
Allegheny Advisor to include additional accounts.
Streamlined Account Management Fees (“SAM”)
The Allegheny fee for the Streamlined Account Management (“Advisory Fee”) is a percentage of the value of
billable assets listed on the Investment Management Agreement and will be billed quarterly or semi-annually in
advance. Instructions will be provided to the client’s account custodian to have the advisory fees deducted from
their account as outlined in the Investment Management Agreement. The Advisory Fee for SAM accounts is .75%.
Wrap Fee Program Transaction Charges Disclosure
In the Allegheny Financial Group Wrap Fee Program, the transaction costs are borne by Allegheny. Allegheny has
agreed to pay an asset-based fee to NFS for legacy accounts and a transaction-based fee for new or transitioning
accounts. Both types of fees cover clearing and execution services.
In legacy accounts, the asset-based fee covers the cost of all transactions during the first 60 days after
an account is opened. The asset-based fee has an annual limit of 45 transactions. Transactions placed for an
account that exceed the annual limit will be paid by Allegheny. Allegheny has an incentive to limit trades to 45 per
year.
In new or transitioned accounts, the transaction-based fees are borne by Allegheny and do not include the above
first 60 days or 45 transaction parameters. Allegheny still has an incentive to limit trades as they will cover all
transaction fees incurred by the client as part of the wrap fee program.
When the transaction costs borne by Allegheny are transaction based, Allegheny has a conflict of interest because
they have a financial incentive to trade less frequently. In addition, because transactions charges vary by security
type, there is a conflict of interest for Allegheny because they have an incentive to select securities for your
Account that cost the Advisor less than other types of securities. Clients should discuss with their advisor these
conflicts. The transaction charges vary depending on the type of security being purchased or sold. In the case of
mutual funds, the transaction charges vary. Funds identified in the NFS or Fidelity published directory as being
subject to mutual fund transaction surcharges will be assessed a $10 mutual fund transaction surcharge on buys,
sells, exchanges-round trip and share class conversions. The list of fund families and/or CUSIPs that are subject to
the surcharge is subject to change by NFS or Fidelity without notice. Allegheny is responsible for paying these
transaction surcharges. Therefore, Allegheny has an incentive to use funds that are not assessed the extra
transaction fee.
NFS and Fidelity currently have arranged for all funds in the No Transaction Fee Program (referenced with a fee
status of “NTF”) in the published directory to be free of clearing charges for wrap fee program accounts. NFS and
Fidelity receive compensation from the fund families based on the average daily net assets in the funds that are
identified as NTF. Funds that are identified as NTF generally pay all available 12b-1 fee revenue to NFS or Fidelity
as part of such compensation. Any 12b-1 fees associated with the funds identified as NTF that are received by NFS
for legacy wrap fee accounts will be credit directly to the client account, or paid to Allegheny then applied as an
offset toward the client’s advisory fee. While NTF funds have no transaction charge they tend to have a higher
expense ratio, which is borne by the client. NFS and Fidelity do not charge a transaction charge for fixed income
securities (e.g., bonds or structured products); however, NFS and Fidelity acts as principals on fixed income
security transactions and receives a mark-up/down on the transaction or applies a flat transaction fee. . These
charges are subject to change.
Certain share classes of mutual funds that participate in the NTF Program can be purchased in non- wrap accounts
without a transaction charge. In order to participate in the NTF Program, mutual funds pay NFS and Fidelity
recordkeeping and/or revenue sharing fees in the form of asset-based or transaction-based fees. A complete list of
mutual fund sponsors participating in the NTF Program can be found by visiting
https://fundresearch.fidelity.com/mutual-funds/fund-families-no-transaction-fee. Clients should understand that
the cost to Allegheny of transaction charges is a factor they consider when deciding which mutual funds to select
and whether or not to place transactions in the account. Advisor has a financial incentive to select certain funds in
order to reduce or eliminate the transaction charges, including but not limited to funds participating in the NTF
Program.
Other Types of Fees and Charges
Program accounts will incur additional fees and charges from parties other than Allegheny as noted below. These
fees and charges are in addition to the advisory fee paid to Allegheny. Allegheny does not share in any portion of
these third-party fees.
NFS and Fidelity, as the custodian and broker-dealer providing brokerage and execution services on program
accounts, will impose certain fees and charges that are not part of the bundled platform fee. NFS notifies clients of
these charges at account opening. NFS and Fidelity will deduct these fees and charges, as applicable, directly from
the client’s program account.
There are other fees and charges that are imposed by other third parties that apply to investments in program
accounts. Some of these fees and charges are described below.
If a client’s assets are invested in mutual funds or other pooled investment products, clients should be
aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an
advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay
Allegheny the advisory fee with respect to those assets. Most of the mutual funds available in the
program may be purchased directly. Therefore, clients could generally avoid the second layer of fees by
not using the management services of Allegheny and by making their own investment decisions.
Certain mutual funds impose fees and charges such as contingent deferred sales charges, early
redemption fees and charges for frequent trading. These charges may apply if client transfers into or
purchases such a fund with the applicable charges in a program account.
Although Allegheny requires that no-load and load-waived mutual funds be purchased in a program
account when available, client should understand that some mutual funds pay asset-based sales charges
or service fees (e.g., 12b-1 fees) to the custodian with respect to account holdings.
If client holds a variable annuity as part of an account, there are mortality, expense and administrative
charges, fees for additional riders on the contract and charges for excessive transfers within a calendar
year imposed by the variable annuity sponsor.
Further information regarding fees assessed by a mutual fund, or variable annuity is available in the appropriate
prospectus, which is available upon request from Allegheny or from the product sponsor directly.
Other Important Considerations
The advisory fee is an ongoing wrap fee for investment advisory services, the execution of transactions
and other administrative and custodial services. The advisory fee may cost the client more than
purchasing the program services separately, for example, paying an advisory fee plus commissions for
each transaction in the account. Factors that bear upon the cost of the account in relation to the cost of
the same services purchased separately include the type and size of the account, historical and or
expected size or number of trades for the account, and number and range of supplementary advisory and
client-related services provided to the client.
The advisory fee also may cost the client more than if assets were held in a traditional brokerage account.
In a brokerage account, a client is charged a commission for each transaction, and the representative has
no duty to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold
strategy for the account or does not wish to purchase ongoing investment advice or management
services, the client should consider opening a brokerage account rather than a program account.
The Advisor recommending the program to the client receives compensation as a result of the client’s
participation in the program. This compensation includes the advisory fee and also may include other
compensation, such as bonuses, awards or other things of value offered by brokers to Allegheny or its
associated persons. The amount of this compensation may be more or less than what Allegheny would
receive if the client participated in other Allegheny programs, programs of other investment advisors or
paid separately for investment advice, brokerage and other client services. Therefore, Allegheny has a
financial incentive to recommend a the program over other programs and services.
The investment products available to be purchased in the program can be purchased by clients outside of
a program account, through broker-dealers or other investment firms not affiliated with Allegheny.