A. Firm Information
Alterity Financial Group, LLC (“Alterity” or the “Advisor”) is a registered investment advisor with the U.S. Securities
and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the
State of Maine. Alterity was founded in March 2010 and is owned and operated by CGC, LLC; CGC, LLC is owned
by Sierra Chapman. This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by Alterity.
B. Advisory Services Offered
Alterity offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Alterity's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
Alterity provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment management
and related advisory services. Alterity works closely with each Client to identify their investment goals and
objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Alterity will then
construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds
(“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize individual stocks, bonds or options
contracts to meet the needs of its Clients. The Advisor may retain certain types of investments based on a Client’s
legacy investments based on portfolio fit and/or tax considerations.
Alterity’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Alterity will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable
restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Alterity evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Alterity may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Alterity may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement.
Alterity may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will Alterity accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
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assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to
fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
Financial Planning and Consulting Services
Alterity will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Alterity may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
Plan Sponsors may engage Alterity to serve as a 3(38) Fiduciary to their plan and assume investment
discretion over the Plan. In such instances, the Plan Sponsor shall authorize this discretion to select and implement
the Plan investment options. Services generally include:
●Vendor Analysis
●Employee Enrollment and Education Tracking
●Investment Policy Statement (“IPS”) Support
●Ongoing Investment Recommendation and Assistance
●ERISA 404(c) Assistance
C. Client Account Management
Prior to engaging Alterity to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
●Establishing an Investment Strategy – Alterity, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
●Asset Allocation – Alterity will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
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●Portfolio Construction – Alterity will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
●Investment Management and Supervision – Alterity will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Alterity does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Alterity.
E. Assets Under Management
As of December 31, 2022, Alterity manages $119,358,152 in Client assets, $100,994,052 of which are managed on
a discretionary basis and $18,364,100 on a non-discretionary basis. Alterity also provides Assets Under
Advisement for $176,899 in Client Assets. Clients may request more current information at any time by contacting
the Advisor.