DESCRIPTION OF BUSINESS, PRINCIPALS, AND TYPES OF SERVICES The Strategic Financial Alliance, Inc. (“SFA”) is a registered broker-dealer with the Financial Industry Regulatory Authority (“FINRA”) and is also an Investment Adviser registered with the Securities and Exchange Commission (“SEC”). SFA is an Atlanta-based, Georgia corporation, formed in 2003, and a wholly owned subsidiary of SFA Holdings, Inc. Clive Slovin is the President and CEO of SFA Holdings, Inc. SFA has worked to build a strong reputation within the Financial Services Industry through its independent model and commitment to service. Through its network of independent Advisory Representatives, SFA offers a range of advisory services as described below, including:
• Portfolio Management Programs
• Selection of and Referral to Third Party Asset Management Programs
• Financial Planning
• Financial Consulting
• Lectures and Seminars As of December 31, 2023, SFA managed assets valued at approximately $334,013,066 million, of which approximately $48,528,599 million were managed on a discretionary basis and $285,484,467 million were managed on a non-discretionary basis. Additionally, as of December 31, 2023 SFA had approximately $ $264,925,895 million in assets under advisement, which represents the assets referred by SFA to third-party asset managers as described on Page 3 under “Third Party Asset Managers.” PORTFOLIO MANAGEMENT PROGRAMS Through its two portfolio management programs, SFA offers a customized approach to implementing individualized investment strategies designed with the goal of meeting your investment objectives through asset allocation, portfolio design, portfolio monitoring, and consolidated reporting. In order to participate in the portfolio management programs, Advisory Representatives must be properly registered, have at least five years of experience in the financial services industry (or equivalent experience, as determined by SFA) and be approved by SFA to offer the programs. You may select an all-inclusive program (“wrap fee program”) in which the asset-based fee includes your advisory fee as well as transaction costs. Alternatively, you may choose a program in which you pay transaction fees in addition to your asset-based advisory fee. The amount of your advisory fee is negotiated between you and your Advisory Representative, and limited based on the program’s published maximum fee schedule. Disclosure Brochure (Rev.03/30/2024) Page 2 STRATEGIC CHOICE PROGRAM Your Advisory Representative is the portfolio manager for your Account(s). SFA will also serve as the introducing broker-dealer to introduce transactions for your Account. Pershing LLC will maintain physical custody of your assets and is responsible for trade execution, billing and reporting. Portfolios may include stocks, bonds, ETFs, mutual funds, and certain illiquid, alternative securities (for suitable investors). The Strategic Choice Program, including fees and expenses, is more fully described in ADV Part 2A Appendix 1 The Strategic Choice Program Brochure, which is available upon request. C-SHARE MUTUAL FUND MANAGEMENT PROGRAM When you own C-Share Class mutual funds, a 1% annual fee is deducted from your mutual fund account. In the C-Share Mutual Fund Management Program, your Advisory Representative will recommend the purchase, sale and/or reallocation of C-share class mutual funds, monitor your designated C-Share holdings based on your stated objectives and risk tolerance. Your Advisory Representative will, no less than annually, review your account with you. SFA, as a registered broker/dealer, will receive the 1% annual fee from the mutual fund company (or companies). SFA designates these fees as payment for the advisory services listed above. Other share class mutual funds are available that offer a breakpoint (discount) for large purchases which may result in a lower cost to you, as disclosed in the C-Share Program Agreement. However, if you purchase other share classes, those funds would not be included in this Program and would not receive the services of your Advisory Representative under this program. If you terminate the C-Share Program Agreement, SFA will continue to receive fees as “broker of record” until such time as you liquidate the funds or move the account to another firm. CO-ADVISORY PROGRAMS Through our co-advisory relationships with certain third-party managers, your Advisory Representative will assist you in choosing suitable strategists or model portfolios which will manage your account in a manner consistent with your stated financial objectives, risk tolerance and investment horizon. Your Advisory Representative will review your account and make recommendations for changes to the selected strategist(s) as warranted. Your Advisory Your Representative will monitor your account and its performance, meet with you periodically and may recommend changing managers based on your needs and objectives. Co-Advisory Programs include the following. (Additional programs may be made available from time to time.) ORION PORTFOLIO SOLUTIONS, LLC (formerly FTJ FundChoice) Wrap fee programs through Orion Portfolio Solutions, LLC offers model portfolios of mutual funds and ETFs. These may be offered on an all-inclusive wrap fee or non-wrap basis. Disclosure Brochure (Rev.03/30/2024) Page 3 This program is more fully described, including fees and expenses, in the Orion Portfolio Solutions, LLC Program Disclosure Brochure, which is available upon request, or may be accessed at www.sec.gov. BAM ADVISORY SERVICES LLC (formerly LORING WARD) Loring Ward offers portfolios of mutual funds and a retirement account platform. Loring Ward’s services, including fees and expenses, are described in its ADV Part 2A Disclosure, also available upon request and at www.sec.gov. You may select among various financial institutions (e.g., Schwab, Fidelity) to maintain physical custody of your account(s). MANAGER SELECTION PROGRAMS The manager selection programs are wrap (inclusive) and non-wrap (non-inclusive) programs sponsored by third party investment advisers. The program sponsor evaluates other independent investment advisers and selects investment advisers to participate as portfolio managers in the programs. Your Advisory Representative will serve in a co-advisory role, assisting you in reviewing the participating portfolio managers and selecting one or more to manage your account(s) in a manner consistent with your objectives. The selected portfolio manager or managers will, typically, exercise discretionary authority in the account. SFA and your Advisory Representative will not have discretionary authority over the assets in accounts participating in these programs. Your Advisory Representative will monitor your account and its performance, meet with you periodically and may recommend changing managers based on your needs and objectives. Manager selection programs include:
•

Lockwood Managed Account Advisor Program, and
• AssetMark Investment Services programs (formerly, Genworth Financial). THIRD-PARTY ASSET MANAGERS – SOLICITOR ARRANGEMENTS SFA and certain of its Advisory Representatives act as solicitors for third-party asset managers (“TPAMs”). Your Advisory Representative will recommend a TPAM whose management style and strategies are consistent with your objectives and financial profile. You will enter into an advisory agreement with the TPAM. SFA nor your Advisory Representative will exercise discretion or make investment choices or recommendations in the account. These programs may include asset allocation models, model portfolios, market timing strategies, or other strategies for mutual funds and variable annuity sub-accounts. In a solicitor’s arrangement, SFA through your Advisory Representative typically gathers information about your financial situation, investment objectives, and reasonable restrictions you Disclosure Brochure (Rev.03/30/2024) Page 4 wish imposed upon the management of your account; periodically reviews reports provided to you; contacts you at least annually to update your financial information and review the account, its performance, and the services of the TPAM. Your Advisory Representative also communicates changes in your information to the TPAM as warranted. It is important to notify your Advisory Representative of any changes in your financial situation, investment objectives, or account restrictions. You will receive the TPAM’s Disclosure Brochure and a Solicitor’s Disclosure Statement, which will describe the relationship between TPAM and SFA, and the solicitor’s fee paid to SFA. FINANCIAL PLANNING AND FINANCIAL CONSULTING SERVICES Financial Planning Your Advisory Representative will work with you to prepare (1) a comprehensive, written financial plan designed to help you achieve your financial goals and investment objectives, or (2) a plan limited in scope to a particular area. Preparation of a plan requires that you provide your Advisory Representative with personal data such as family records, employment records, budgeting, assets, liabilities, estate information, and tax information. Financial planning is a process that may address any or all of the following topics as you may request:
• asset protection
• tax planning
• business succession
• cash flow
• education planning
• estate planning
• multi-generational planning
• insurance planning
• asset allocation
• risk management
• retirement planning
• wealth transfer
• charitable gifting
• long-term care and disability planning Should you choose to implement the recommendations promulgated in your financial plan, we encourage you to work closely with your attorney, accountant, insurance agent, and other professional advisors. Although you may choose to implement the recommendations made in your financial plan through your Advisory Representative in his or her capacity as a registered representative or licensed insurance agent, you are free to employ the services of any advisor, registered representative, or insurance agent of your choice, regardless of whether or not that person is associated with SFA. Financial Consulting SFA offers investment consulting services that are limited to the specific areas you identify. These services are not considered financial planning services because we will not perform a Disclosure Brochure (Rev.03/30/2024) Page 5 comprehensive analysis of your financial position and will not prepare a written report documenting our review. The consulting services our Advisory Representatives provide may include (but are not limited to):
• Assisting you in the preparation of an investment policy statement;
• Reviewing and recommending changes to an existing investment policy statement (or similar guidelines, policies, and/or investment allocation that you are employing);
• Reviewing existing contracts you have with service providers, such as managers and consultants, and making recommendations for changes;
• Assisting you in renegotiating the fees you pay to service providers and/or assisting you in conducting a search for new service providers;
• Analyzing the performance of your current investment manager;
• Advising you regarding the manner in which your investment account is being managed and, at your request, assisting you in searching for a new investment manager;
• Advising you on the purchase and sale of particular individual investments;
• Monitoring your transaction costs; and,
• Monitoring compliance by your investment managers with your investment policy statement. SFA does not offer legal or tax advice. An Advisory Representative may present the tax aspects of certain investments or strategies in general terms but does not provide specific tax advice. We recommend that all tax questions or strategies should be discussed with your tax professional. Regardless of the services you choose, we strongly encourage you to notify your Advisory Representative promptly if there are any changes in your personal circumstances, financial situation, investment objectives, or risk tolerances. LECTURES AND SEMINARS SFA sponsors lectures, seminars, or speeches of an educational and generic nature. A broad range of topics may be included in each seminar including, but not limited to, asset allocation, retirement planning, risk, tax planning, long-term care and estate planning. SUBSCRIPTION ADVISORY SERVICES The Subscription Advisory Services Program (Subscription Program) offers an array of financial planning and wealth management services selected by you for an annual flat fee, provided on an on-going basis to help you adhere to your plan and achieve stated goals and objectives. The Subscription Program services can include retirement, education, estate, and legacy planning; wealth management, advice related to accounts held away from the Firm, tax strategies, and asset allocation. With your authorization, your Advisory Representative will collaborate with your other advisors, including tax and legal advisors. The nature and frequency of reporting, meetings, written plans, and other specific services are described and agreed upon in the Subscription Disclosure Brochure (Rev.03/30/2024) Page 6 Program Agreement. Investment Management is not offered through the Subscription Program. CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS Your Advisory Representative develops and recommends a strategy based on the information you provide about your financial profile using his or her knowledge and experience. It is very important that you communicate changes in your information so your Advisory Representative can make recommendations and manage your account in a manner that is consistent with your objectives, risk tolerance and time horizon. You may impose reasonable restrictions on the manner in which your account is managed, such as limiting investments in certain types of securities or asset classes, in accordance with your values or beliefs. Disclosure Brochure (Rev.03/30/2024) Page 7