Strategic Advocates, LLC (hereinafter “Strategic Advocates”) is a registered investment advisor based in Logan,
Utah. We are a limited liability company organized under the laws of the State of Utah. We have been providing
investment advisory services since 2022. Bradley R. Harsch, James P. Jenkins and John R. Mickelson are the
principal owners of Strategic Advocates.
You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to
anyone from our firm who is an officer, an employee, and all individuals providing investment advice on behalf of
our firm. Where required, such persons are properly registered as investment adviser representatives.
Currently, we offer the following investment advisory services, personalized for each individual client:
Financial Planning Services
Portfolio Management Services
Retirement Plan Consulting Services
Financial Planning Services
Strategic Advocates offers various financial planning related services, which assist clients in the management of
their financial resources. Financial planning services are based upon an analysis of the client’s individual needs
beginning with one or more information gathering consultations. Once the firm has collected and analysed all
documentation gathered during these consultations, Strategic Advocates provides a written financial plan
designed to achieve the client’s financial goals and objectives. Strategic Advocates then assists clients in
developing a strategy for the successful management of income, assets, and liabilities. In general, financial
planning services may include any one or all of the following:
Cash Flow Analysis – Assessment of present financial situation by collecting information regarding net
worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans,
employee benefit statements, etc. The firm advises on ways to reduce risk; and, to coordinate and
organize records and estate information.
Retirement Analysis – Identification of long-term financial and personal goals and objectives including
advice for accumulating wealth for retirement income or appropriate distribution of assets following
retirement. Tax consequences and implications are identified and evaluated.
Insurance Analysis – Includes risk management associated with advisory recommendations based on a
combination of insurance types to meet your needs, e.g., life, health, disability, and long-term care
insurance. This will necessitate an analysis of cash needs of the client’s family at death, income needs of
surviving dependents, and potential disability income needs.
Portfolio Analysis/Investment Planning – Presentation of investment alternatives, including asset
allocation and its effect on the client’s portfolio; evaluation of economic and tax characteristics of
existing investments as well as their suitability for the client; and, identification and evaluation of tax
consequences and their implications.
Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding
of college or other post-secondary education.
Estate Analysis – Advising clients with respect to property ownership, distribution strategies, estate tax
reduction, and tax payment techniques.
Tax Analysis and Planning – The goal of tax planning is to arrange your financial affairs so as to minimize
your taxes. There are three basic ways to reduce your taxes, and each basic method might have several
variations. You can reduce your income, increase your deductions, and take advantage of tax credits.
The recommendations and solutions are designed to achieve the client’s desired goals, subject to periodic
evaluation of the financial plan, which may require revisions to meet changing circumstances. Financial plans are
based on your financial situation based on the information provided to the firm. We should be notified promptly
of any change to your financial situation, goals, objectives, or needs.
Clients can also request financial planning services that cover a specific area, such as retirement or estate
planning, asset allocation analysis, manager due diligence, and 401(k) platform due diligence. Clients may choose
to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so by
engaging us for investment advisory services or by using any investment adviser, broker dealer, or insurance
provider you choose.
Portfolio Management Services
Strategic Advocates provides discretionary, and in limited cases, non-discretionary portfolio management services
to our clients. Discretionary portfolio management means we will make investment decisions and place buy or
sell orders in your account without contacting you. We would also rebalance the portfolio whenever necessary,
as changes occur in market conditions and/or your financial circumstances. These decisions would be made based
upon your stated investment objectives. If you wish, you may limit our discretionary authority by, for example,
setting a limit on the type of securities that can be purchased for your account. Simply provide us with your
restrictions or guidelines in writing. If you have engaged us for non-discretionary portfolio management services,
Strategic Advocates will obtain your approval prior to executing any transactions in your account(s).
Portfolio management clients may also receive ongoing ad-hoc financial advice regarding routine financial
matters and questions regarding topics such as budgeting/cash flow management or insurance coverage. This
portion of our portfolio management services is entirely non-discretionary in nature – you will make all final
investment decisions and be responsible for implementation and monitoring of all investments held outside of
the account(s) we directly manage on your behalf at the custodian. Our ad-hoc financial advice is not intended to
replace broad-based financial planning and we will not provide you with a written financial plan or report as part
of our portfolio management services. Clients wishing to receive broad-based financial planning services or a
written financial plan may only do so by entering a separate and distinct written financial planning agreement
with our firm.
Our investment advice is tailored to meet our clients’ needs and investment objectives. If you decide to hire our
firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals,
and help you decide how much risk you should take in your investments. The information we gather will help us
implement a tailored portfolio strategy that will be specific to your goals. We should be notified promptly of any
change to your situation, goals, objectives, or needs.
Strategic Advocates does not specialize in specific types of securities. We can advise clients on all types of
securities, such as exchange listed equities, over the counter equities, foreign issues, American depository
receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment
company securities (including mutual funds and exchange traded funds), US Government securities, options
contracts on securities and/or commodities, structured products, private placements, private equity instruments,
and interests in partnership investing in real estate. Additionally, will provide advice on existing investments you
may hold at the inception of the advisory relationship or on other types of investments for which you ask advice.
Our asset allocation models are diversified among investment styles and/or asset classes and are developed and
managed by us based on research conducted by our firm. Once the client portfolio is constructed, Strategic
Advocates provides periodic supervision of the portfolio as changes in the market conditions and client
circumstances may require. Investments and allocations are determined based upon the clients’ predefined
objectives, risk tolerance, time horizons, financial horizons, financial information, and other various suitability
factors. Further restrictions and guidelines imposed by clients may affect the composition and performance of a
client’s portfolio. As such, different clients of our firm may have significant differences in their asset allocation.
For these reasons, performance of one client’s portfolio might not be identical with another client’s even if both
clients have similar risk parameters. We review the clients’ financial circumstances and investment objectives on
a quarterly to annual basis and make adjustments to clients’ portfolios or allocation models as may be necessary
in an effort to achieve the desired results. At all times, our firm requires each Associated Person to uphold their
fiduciary duty by providing advice that in our judgement is in the client’s best interest.
Our professionals employ a range of investment strategies to implement the advice we give to clients including:
long-term purchases, short-term purchases, trading, short sales, margin transactions, option strategies including
writing covered options, uncovered options and spread strategies, and taking advantage of price differentials
between two or more securities (arbitrage). Quantitative analytics are also utilized in some of our investment
activities, to assist in the selection of securities or the management of investment risk.
Margin Borrowings–The use of short-term margin borrowings may result in certain additional risks to a Client.
For example, if securities pledged to brokers to secure a Client's margin accounts
decline in value, the Client
could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or
be the subject to a mandatory liquidation of the pledged securities to compensate for the decline in value.
Retirement Plan Consulting Services
Strategic Advocates provides several retirement plan consulting related services. While the primary clients for
these services will be pension, profit sharing and 401(k) plans, Strategic Advocates will also offer these services,
where appropriate, to individuals and trusts, estates and charitable organizations. Retirement plan consulting
services are comprised of the following components. Clients may choose to use any or all of the following services:
Assistance with the development and/or review and revision of an Investment Policy Statement (“IPS”)
as requested.
Provision of recommendations on appropriate investments that have a level of risk commensurate with
the anticipated return, seeing to it that risk is minimized through diversification, and ensuring that the
Plan has sufficient liquidity to meet its cash flow requirements.
Assistance with the selection of a qualified default investment alternative (“QDIA”) and determination
of the continuing suitability of a QDIA.
Assistance with on-going monitoring and make recommendations regarding the replacement of the
Plan’s investments and investment providers.
Assistance with the monitoring of investment options by preparing quarterly reports that document
investment performance, consistency of fund management, and conformance to any guidelines set forth
in the IPS and will notify you with any recommendations.
Analysis of the fees and expenses associated with the investments and the service providers and
recommend changes when warranted.
Ongoing and continuous discretionary investment management with respect to the asset classes and
investments for the Plan in accordance with the Plan’s investment policies and objectives. This service is
described in more detail in the Portfolio Management Services section above.
Monitor investments by preparing periodic investment reports that document investment performance,
consistency of fund management and conformance to the guidelines set forth in the IPS and determine
whether to maintain or remove and replace investment options.
Meetings with clients on a periodic basis to discuss the reports and investment decisions.
These services are designed to assist plan sponsors in meeting their management and fiduciary obligations to
Participants under ERISA. Pursuant to adopted regulations of the U.S. Department of Labor, we are required to
provide the Plan's responsible plan fiduciary (the person who has the authority to engage us as an investment
adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive
for providing those services, and our status (which is described below).
The services we provide to your Plan are described above, and in the service agreement that you have previously
signed. Our compensation for these services is described below, in Item 5, and also in the retirement plan
Consulting Agreement. We do not reasonably expect to receive any other compensation, direct or indirect, for
the services we provide to the Plan or Participants, unless the plan sponsor directs us to deduct our fee from the
plan or directs the plan record-keeper to issue payment for our fee out of the plan. If we receive any other
compensation for such services, we will (i) offset the compensation against our stated fees, and (ii) we will
promptly disclose the amount of such compensation, the services rendered for such compensation and the payer
of such compensation to you.
Other retirement plan consulting services are available on request. All of our retirement plan consulting services,
whether general or customized, will be outlined in an Agreement that shows the services that will be provided
and the fees that will be charged for those services.
Strategic Advocates is registered as an investment advisor and represents that it is not subject to any
disqualification as set forth in Section 411 under the Employee Retirement Income Security Act (“ERISA”). To the
extent Strategic Advocates performs Fiduciary Services, Strategic Advocates is acting as a fiduciary of the Plan as
defined in Section 3(21) or Section 3(38) under ERISA.
Strategic Advocates may also perform the following non-Fiduciary services:
Assistance with the education of the participants in the Plan about general investment principles. Client
understands that Strategic Advocates’ assistance in participant investment education shall be consistent
with and within the scope of the definition of investment education of Department of Labor Interpretive
Bulletin 96-1. As such, Strategic Advocates is not providing fiduciary advice (as defined in ERISA) to the
participants. Strategic Advocates will not provide individualized investment advice concerning the
prudence of any investment or combination of investment for a particular participant or beneficiary
under the Plan.
Assistance with group enrollment meetings designed to increase retirement plan participation among
employees and investment and financial understanding by the employees.
Strategic Advocates may provide these services or, alternatively, may arrange for the Plan’s other providers to
offer these services, as agreed upon between Strategic Advocates and client.
Rollover Services Disclosure
In conjunction with the advisory services offered, we may provide education or recommendations related to the
rollover of an employer sponsored retirement plan. A plan participant leaving employment has several options.
Each choice offers advantages and disadvantages, depending on desired investment options and services, fees
and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique
financial needs and retirement plans. The complexity of these choices may lead an investor to seek assistance
from us.
When our firm or our Associated Person(s) recommend an investor roll over plan assets into an Individual
Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset-based fee as a result. However,
no compensation is received if assets are retained in the plan. Thus, we have an economic incentive to encourage
an investor to roll plan assets into an IRA. In most cases, your fees and expenses will increase because fees will
apply to assets rolled over to an IRA and ongoing services will be extended to these assets.
Further, you may incur other levels of fees and expenses, including, but not limited to, investment-related
expenses imposed by other service providers and mutual fund managers not affiliated with us, as well as other
fees and expenses charged by the custodian, third-party administrator, and/or record-keeper. We make no
representations or warranties relating to any costs or expenses associated with the services provided by any third
parties, and you understand that these fees are in addition to the fee paid to us for the rollover advice.
In cases where we provide you with rollover advice as defined by the Department of Labor, which may also include
setting up and/or completing the rollover transaction, we do not serve as a custodian, and we do not provide
legal or tax advice to you. In addition, we do not have any responsibilities or potential liabilities in connection
with assets not related to the rollover and investments that are not managed by us.
When we provide investment advice to you regarding your retirement plan account or individual retirement
account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or
the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests. In accordance with various rules and regulations, we must act
in your best interest and we must not put our interests ahead of your interests. Additionally, we must: meet a
professional standard of care when making investment recommendations (give prudent advice); never put our
financial interests ahead of yours when making recommendations (give loyal advice); avoid misleading statements
about conflicts of interest, fees, and investments; follow polices, and procedures designed to ensure that we give
advice that is in your best interest; charge no more than is reasonable for our services; and give you basic
information about any conflicts of interest.
We rely on all information you provide to us, whether financial or otherwise, without independent verification.
We request that you promptly notify us in writing of any material change in the financial and other information
provided to us, and to promptly provide any such additional information as may be reasonably requested by us.
Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future performance,
any specific level of performance, or the success of any recommendations or strategies that we may take or
recommend for you, or the success of our overall recommendations. Investment recommendations are subject
to various market, currency, economic, political, and business risks, and that investment decisions will not always
be profitable.
Wrap Fee Programs
We do not sponsor, manage, or participate in any wrap fee programs.
Assets Under Management
As of October 31, 2023, our firm manages approximately $363,541,2998 of client assets, with
$335.066,293 being managed on a discretionary basis.
