A. Description of the Advisory Firm
Established in 2001, Huntleigh Advisors, Inc. (“HAI”) is an advisory firm registered with the SEC
pursuant to Section 203 of the Investment Advisors Act of 1940, as amended (the “Act”). Our principal
place of business is located in St. Louis, Missouri with satellite offices in several other states. Our
primary owners are Robert L. Chambers and Michael B. Rowan.
As used in this Brochure, the words “we”, “our” and “us” “Advisor”, or “HAI” refer to Huntleigh
Advisors, Inc. The words “you”, “your”, and “Client” refer to you as either a Client or prospective client
of Huntleigh Advisors, Inc.
HAI is affiliated with the other companies comprising the Huntleigh Group. Those entities are:
• Huntleigh Securities Corporation (“HSC”) an SEC registered broker/dealer and FINRA Member
• K.W. Chambers & Co.(“KWC”) an SEC registered broker/dealer and FINRA member
HAI also does business under the fictitious name, “The Huntleigh Group,” which it shares with its
affiliates, HSC and KWC. This corporate structure creates a conflict of interest in that they all share
common ownership, and the same office space in St. Louis, MO and other satellite offices. Further,
one or more individual officers and directors are officers and directors of one or more of the above
entities. The conflict exists in that these individuals benefit from any cross-business among these
entities. In addition, there is a risk that such officers and directors will make a decision that benefits
one or more of these other entities to the detriment of HAI. Further, pursuant to our Privacy Policy
we share Client information with one or more of these affiliated entities.
B. Types of Advisory Services
ASSET MANAGEMENT
HAI offers asset management services to advisory Clients. HAI will offer Clients ongoing asset
management services through determining individual investment goals, time horizons, objectives,
and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring
and the overall investment program will be based on the above factors.
When the Client elects to use HAI on a discretionary basis, the Client will sign a limited trading
authorization or equivalent allowing HAI to determine the securities to be bought or sold and the
amount of the securities to be bought or sold. HAI will have the authority to execute transactions in
the account without seeking Client approval on each transaction.
Traditional Model Program
Traditional Model programs are professionally managed investment accounts that are
reviewed for rebalancing no less than quarterly by our Portfolio Manager. HAI provides
portfolio management services to Clients using model asset allocation portfolios. Each model
portfolio is designed to meet a particular investment goal.
Our investment recommendations are not limited to any specific product or service offered
by a broker/dealer or insurance company and will include advice regarding the following
securities, among others:
• Exchange-listed securities
• Securities traded over-the-counter
• Warrants
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• United States governmental securities
• Options contracts on securities
• Variable annuities
• Non-traded securities
MindShare Program
For the MindShare Program, HAI manages investment advisory accounts using its HAI
MindShare Small Companies Advisory Service investment strategy.
This program’s goal is to seek long-term capital appreciation. HAI will seek to achieve this
goal by investing in the equity securities of micro-, small- and mid-capitalization companies
that, HAI believes has growth potential. Our analysis is based on (a) investor sentiment, which
we measure by reviewing stock price trends and charting those trends, both positive and
negative, and (b) fundamental research to determine which common stocks to purchase. HAI
tries not to emphasize investment in any particular investment sector or industry. However,
due to the growth characteristics of particular sectors, such as technology or health care,
investments in these sectors from time-to-time will represent a significant portion of our
Clients' portfolios.
For the MindShare Program, HAI typically manages Client accounts using two investment
styles or strategies: SmallCap Growth, and MicroCap Select Growth.
• SmallCap Growth seeks to identify the most rapidly growing small cap companies
exhibiting accelerating operating fundamentals accompanied by improving investor
sentiment. Advisor typically purchases stocks of companies with market
capitalizations corresponding to those of the Russell Small Cap Growth Index®.
• MicroCap Select Growth seeks to identify micro-cap companies using the same
philosophy/process that we currently use in our SmallCap Growth strategy, but in the
micro market cap range (market caps corresponding to those of the Russell Microcap
Growth Index®).
The MindShare Program also manages a higher-risk strategy: the Focused Strategy.
• Focused Strategy invests in a smaller number of companies, and/or in a more limited
number of sectors than our other strategies. The strategy typically invests in stocks
of between 8-12 companies at one time. The strategy is flexibly managed so that it
can invest in equity securities in a variety of industries and in any market
capitalization range. This flexibility will enable HAI to take advantage of
opportunities as they arise. However, a consequence of this investment strategy is
that the strategy will often result in a high rate of portfolio turnover, account value
fluctuations, and fewer sector allocations, making this strategy riskier than the other
two.
Individual Management Program
As opposed to using the programs discussed above, HAI may also manage accounts outside
of the model portfolio(s) and use customized strategies.
Third Party Management
When deemed appropriate for the Client, HAI may recommend that Clients utilize the services of a
Third Party Manager (TPM) to manage a portion of, or the Client’s entire portfolio. All TPMs that HAI
recommends must be a Registered Investment Advisors with the SEC or with the appropriate state
authority(ies).
After gathering information about your financial situation and objectives, an investment advisor
representative of our firm will make recommendations regarding the suitability of a TPM or
investment style based on, but not limited to, your financial needs, investment goals, tolerance for
risk, and investment objectives. Upon selection of a TPM(s), we will monitor the performance of the
TPM(s) to ensure their performance and investment style remains aligned with your investment
goals and objectives.
In such circumstances, HAI receives solicitor fees from the TPM. We act as the liaison between the
Client and the TPM in return for an ongoing portion of the advisory fees charged by the TPM. We help
the Client complete the necessary paperwork of the TPM, and provide ongoing services to the Client.
Ongoing services include but are not limited to:
1. Meet with the Client to discuss any changes in status, objectives, time horizon or suitability;
2. Recommend investment managers that align with Clients’ objectives
3. Ongoing monitoring of the Clients’ accounts ; and
4. Assist Client in changing investment managers and/or allocations when appropriate
When appropriate, HAI will provide the TPM with any changes in Client status as provided to us by
the Client and review the quarterly statements provided by the TPM. HAI will deliver the Form ADV
Part 2, Privacy Notice and Solicitors Disclosure Statement of the TPM. Clients placed with TPM will
be billed in accordance with the TPM’s Fee Schedule which will be disclosed to the Client prior to
signing an agreement.
Because some types of investments involve certain additional degrees of risk, any and all elected
programs will only be implemented/recommended when consistent with the Client's stated
investment objectives, tolerance for risk, liquidity, and suitability.
SUBADVISORY SERVICES
HAI may act as a Sub-Advisor to other investment advisors who hire HAI to manage a portion or all
of their Client’s portfolio. The investment advisors must have discretionary authority over the
account and the ability to delegate that discretionary authority to HAI. HAI will manage the assets
according to agreed upon strategies between the investment advisor and HAI.
ERISA PLAN SERVICES
HAI offers service to qualified and non-qualified retirement plans including 401(k) plans,
403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation
plans. HAI may act as a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. HAI acts as a limited scope ERISA 3(21) fiduciary that
can advise, help and assist plan sponsors with their investment decisions. As an investment
advisor HAI has a fiduciary duty to act in the best interest of the Client. The plan sponsor is
still ultimately responsible for the decisions made in their plan, though using HAI can help
the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
• Provide investment advice to the Client about asset classes and investment alternatives
available for the Plan in accordance with the Plan’s investment policies and objectives.
Clients will make the final decision regarding the initial selection, retention, removal and
addition of investment options. HAI acknowledges that it is a fiduciary as defined in ERISA
section 3 (21) (A) (ii).
• Assist the Client in the development of an investment policy statement (“IPS”). The IPS
establishes the investment policies and objectives for the Plan. Client shall have the
ultimate responsibility and authority to establish such policies and objectives and to
adopt and amend the IPS.
• Provide investment advice to the Plan Sponsor with respect to the selection of a
qualified default investment alternative for participants who are automatically enrolled
in the Plan or who have otherwise failed to make investment elections. The Client retains
the sole responsibility to provide all notices to the Plan participants required under
ERISA Section 404(c) (5) and 404(a)-5.
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with the Client on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services are:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. Client understands HAI’s
assistance in education of the Plan participants shall be consistent with and within the
scope of the Department of Labor’s definition of investment education (Department of
Labor Interpretive Bulletin 96-1). As such, HAI is not providing fiduciary advice as
defined by ERISA 3(21)(A)(ii) to the Plan participants. HAI will not provide investment
advice concerning the prudence of any investment option or combination of investment
options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
HAI may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between HAI and Client.
3. HAI has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
• Other hard-to-value or illiquid securities or property.
Excluded Assets will not be included in calculation of Fees paid to HAI on the ERISA
Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
3(38) Investment Manager. For some accounts, HAI acts as an ERISA 3(38) Investment
Manager in which it has discretionary management and control of a given retirement plan’s
assets. HAI would then become solely responsible and liable for the selection, monitoring and
replacement of the plan’s investment options.
1. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the initial
selection, retention, removal and addition of investment options in accordance with the
Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The IPS
establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Plan Sponsor retains the sole responsibility to provide all notices to the
Plan participants required under ERISA Section 404(c) (5).
• Assist in monitoring investment options by preparing periodic investment reports that
document investment performance, consistency of fund management and conformance
to the guidelines set forth in the IPS and make recommendations to maintain, remove or
replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment
recommendations.
2. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information and
the investment alternatives available to them under the Plan. The Advisor’s assistance in
education of the Plan participants shall be consistent with and within the scope of the
Department of Labor’s definition of investment education (Department of Labor
Interpretive Bulletin 96-1). As such, the Advisor is not providing fiduciary advice as
defined by ERISA to the Plan participants. Advisor will not provide investment advice
concerning the prudence of any investment option or combination of investment options
for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by the
employees.
HAI may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between Advisor and Plan Sponsor.
3. HAI has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
C. Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment strategies are
created that reflect the stated goals and objectives. Clients may impose restrictions on investing in
certain securities or types of securities. These restrictions may, however, prohibit engagement with
HAI.
D. Wrap Fee Programs
HAI does not participate in a Wrap Program.
E. Amounts Under Management
As of December 31, 2023, HAI provides management services for:
Discretionary Assets: Non-Discretionary Assets:
$444,258,607 $1,164,020