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Part 2A of Form ADV: Firm Brochure
Alliance Advisory & Securities, LLC
31248 E. Oak Crest Drive, Ste 100
Westlake Village, California 91361
Telephone: 805-371-8020
Email: lmd@aewealth.com
Web Address: www.allianceadvisory.com
Web Address: www.aewealth.com
March 24, 2025
This brochure provides information about the qualifications and business practices of Alliance
Advisory & Securities, LLC. If you have any questions about the contents of this brochure, please
contact us at 805-371-8020 or lmd@aewealth.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any
state securities authority.
Additional information about Alliance Advisory & Securities, LLC, also is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number,
known as a CRD number. Our firm's CRD number is 18835. All references to Alliance Advisory &
Securities, LLC being a registered investment adviser does not imply a certain level of skill,
training, or any endorsement by the SEC.
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Item 2 Material Changes
This section discusses only material changes since the last annual update of our brochure dated
September 17, 2024.
Alliance Advisory & Securities, LLC had a change in executive officers in early 2025. Sean Sottile is the
new Vice President and Liza M. dela Cruz is the new Chief Compliance Officer. Randy Sanada Jr.
remains the President & Chief Executive Officer of Alliance Advisory & Securities, LLC, while Jerry
Sanada has resigned his position as Chief Financial Officer devoting his time to Commune Capital, LLC.,
an affiliated operating company of Alliance Advisory & Securities, LLC.
In addition, Item 4 was updated to disclose the following:
The firm's Assets Under Management has been updated to reflect the assets under management
reported in the firm's last Form ADV Part 1A.
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Item 3 Table of Contents
Item 1 Cover Page
1
Item 2 Material Changes
2
Item 3 Table of Contents
3
Item 4 Advisory Business
4
Item 5 Fees and Compensation
9
Item 6 Performance-Based Fees and Side-By-Side Management
12
Item 7 Types of Clients
12
Item 8 Methods of Analysis, Investment Strategies, and Risk of Loss
12
Item 9 Disciplinary Information
15
Item 10 Other Financial Industry Activities and Affiliations
15
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
16
Item 12 Brokerage Practices
18
Item 13 Review of Accounts
21
Item 14 Client Referrals and Other Compensation
21
Item 15 Custody
22
Item 16 Investment Discretion
22
Item 17 Voting Client Securities
22
Item 18 Financial Information
23
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Item 4 Advisory Business
OWNERSHIP AND STRUCTURE
Alliance Advisory & Securities, LLC is an SEC-registered investment adviser with its principal place of
business located in California. Alliance Advisory & Securities, LLC began conducting business in 1982
and has been doing business as (dba) Alliance Entrust, in addition to Alliance Advisory & Securities, LLC.
Our firm is wholly owned by our parent company, Alliance Financial Group, Inc.
Alliance Financial Group, Inc. is owned by:
• Randall P. Sanada Sr.,
• Randall P. Sanada, Jr.,
• Jerry V. Sanada
ADVISORY SERVICES
Alliance Advisory & Securities, LLC offers the following advisory services to our clients:
1. Investment Portfolio Services
2. Investment Model Portfolio Management
3. Affiliated Operating Companies
4. Financial Planning
1. INVESTMENT PORTFOLIO SERVICES
Our firm provides non-continuous asset management of client funds based on the individual needs of
the client. Through personal discussions in which goals and objectives based on the client's particular
circumstances are established, we develop the client's personal investment allocation. We create and
manage a portfolio based on that ideal allocation. During our data-gathering process, we determine the
client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we may
also review and discuss a client’s prior investment history, as well as family composition and background.
We manage these advisory accounts on a non-discretionary basis. Account supervision is guided by the
client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income),
as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or
industry sectors.
Once the client's portfolio has been established, we review the portfolio at least annually or more
frequently as requested by the client, and if necessary, rebalance the portfolio on an annual basis or
more frequently, based on the client's individual needs.
Our investment recommendations are not limited to any specific product or service offered by a broker-
dealer or insurance company and may include advice regarding the following securities:
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• Exchange-listed securities
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
• Interests in partnerships investing in real estate
Because some types of investments involve certain additional degrees of risk, they will only be
recommended when consistent with the client's stated investment objectives, tolerance for risk,
liquidity, and suitability.
To ensure that our initial determination of an appropriate portfolio remains suitable and that the
account continues to be managed in a manner consistent with the client's financial circumstances, we
will:
1. At least annually, contact each participating client to determine whether there have been any
changes in the client's financial situation or investment objectives; and whether the client wishes to
impose investment restrictions or modify existing restrictions.
2. Be reasonably available to consult with the client; and
3. Maintain client suitability information in each client's file.
2. INVESTMENT MODEL PORTFOLIO MANAGEMENT
Our firm provides portfolio management services to clients using the following model asset allocation
portfolios:
• Core: Conservative Income, Balanced Income, Growth & Income, Balanced Growth, Growth
• Core Defensive: Conservative, Balanced Income, Growth & Income, Balanced Growth, Growth
• Values Based: Conservative, Balanced Income, Growth & Income, Balanced Growth, Growth
• Dimensional: Income, Conservative Income & Growth, Moderate Income & Growth, Growth &
Income, Growth, Aggressive Growth, AFG Extended Equity
• Dimensional Socially Responsible: Growth & Income, Growth
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• U.S. Large Cap Equity / AFG 50
• Municipal Income
Each model portfolio is designed to meet a particular investment goal.
Control: Your account is, of course, yours. You have the final say and may choose to place reasonable
restrictions on the account at any time. Alliance Advisory & Securities LLC does reserve the right to
remove the account from the Model Program if the restrictions are unreasonable or interfere with the
operation or effectiveness of the program. You may also remove your account from the Model
Program on demand.
All Model Program accounts are discretionary accounts. This means that you have given permission for
Alliance Advisory & Securities, LLC to trade the securities in these accounts without asking you for
further permission. However, we have a fiduciary duty to act in your best interests at all times. In
addition, the accounts are guided by general principles which help you, your Advisor, and Alliance
Advisory & Securities, LLC know the manner in which the account will be handled.
Accounts will be periodically rebalanced to maintain your chosen allocation. Generally, your account
will be reviewed on a quarterly basis to make sure the individual investments are within the specific
allocation tolerances. When your investments move outside the allowed tolerance, it triggers a
rebalancing of your account. Although the tolerances may vary by specific investment, they are
generally set at approximately plus or minus 2% (relative).
As market conditions change, the specific allocations, investments, and tolerances within your account
will be adjusted by Alliance Advisory & Securities, LLC. These adjustments are guided by current and
projected market conditions and modern portfolio theory.
Core Accounts
Each Core account has an allocation to fit your financial plan. The purpose of the Core account is to
make investment decisions based on your investment objectives using modern portfolio theory to
guide the particular allocations in the account. Core accounts generally use funds with active managers
rather than passive investment managers.
Defensive Core Accounts
Because Defensive Core accounts anticipate the need to draw cash, Alliance Advisory & Securities, LLC
pays particular attention to the cash portion of the account. This strategy typically holds approximately
12-18 months of the anticipated liquidity needs in a cash/money market position. That cash reserve
allows Alliance Advisory & Securities, LLC time to make the best decision on when to transition other
securities to cash with the goal of not having to sell in unfavorable markets. Defensive Core accounts
generally have all interest, cash dividends, and capital gains sent directly to the cash/money market
position in the account.
Values Based Accounts
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The purpose of the Valued Based account is not only to make investment decisions based on your
investment objectives but include an additional layer, focusing on investments that align with certain
values – because how you profit matters. The accounts generally use funds with active managers that
have additional screening processes beyond the typical index. Because of this additional layer, the
accounts will drift more in terms of allocation and performance from their closest index.
Dimensional Accounts
Each Dimensional account has an allocation to fit your financial plan. The purpose of the Dimensional
account is to make investment decisions based on your investment objectives using a long-term
strategic allocation using Dimensional Funds (DFA). Dimensional Funds are passively managed funds
with low internal costs.
Socially Responsible Dimensional Accounts
Our Socially Responsible Dimensional Accounts take into consideration sustainable and ethical
alternatives to traditional investing by selecting a blend of mutual funds that promote environmental
stewardship, shareholder advocacy, and community investing.
Individual Securities Accounts (Municipal Income and U.S. Large Cap Equity / AFG 50)
Trades are made on an irregular basis, using proprietary modeling systems to monitor various lagging,
coincident, and leading macro and micro economic statistics and to calculate various valuation metrics
to project the best response to the market. Data is compiled from numerous independent research
firms, such as Applied Finance Group, and the public domain. Generally, all interest, cash dividends,
and capital gains distributions will be sent directly to the cash/money market position in your account.
We manage these advisory accounts on a discretionary basis. Account supervision is guided by the
client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income),
as well as tax considerations.
Through personal discussions with the client in which the client's goals and objectives are established,
we determine if the model portfolio is suitable for the client's circumstances. Once we determine the
suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each
client's individual needs. Clients, nevertheless, have the opportunity to place reasonable restrictions
on the types of investments to be held in their account. Clients retain individual ownership of all
securities.
3. AFFILIATED OPERATING COMPANIES
Our firm provides private offerings of affiliated operating companies to clients using private, limited
partnerships and limited liability companies. Private offerings are generally offered to accredited
investors and each has its own private placement memorandum and disclosure documents detailing its
objectives, investments, goals, restrictions, risks, and costs.
COMMUNE CAPITAL, LLC
Commune Capital, LLC offers various private placements/limited partnerships ranging from portfolios
of commercial loans to equity investments in commercial real estate (multi-family and self-storage
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properties), each with their own Management Company owned and run fully or in part by Commune
Capital, LLC (see Item 10).
General Management
Through personal discussions with the client in which the client's goals and objectives are established,
we initially determine whether the affiliated operating company is suitable to the client's
circumstances. Once we confirm suitability, the operating company is managed based on the
respective operating documents, rather than on each client's individual needs.
Because some types of investments involve certain additional degrees of risk, they will only be
recommended or implemented when consistent with the client's stated investment objectives,
tolerance for risk, liquidity, and suitability.
4. FINANCIAL PLANNING
We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s
current and future financial state by using currently known variables to predict future cash flows, asset
values and withdrawal plans. Through the financial planning process, all questions, information, and
analysis are considered as they impact and are impacted by the financial circumstances and objectives
of the client. Clients purchasing this service receive a written report which provides the client with a
detailed financial plan designed to assist clients to achieve their financial goals and objectives.
The financial plan can address any or all of the following areas:
• PERSONAL/NET WORTH: We review family records, budgeting, personal liability, estate information
and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current
and future years; then illustrate the impact of various investments on the client's current income tax
and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• RETIREMENT / FINANCIAL INDEPENDENCE: We analyze current strategies and investment plans to
help the client achieve his or her retirement goals.
• RISK MANAGEMENT: We review the client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income. We review existing policies to ensure proper
coverage for life, health, disability, long-term care, liability, home, and automobiles.
• BENEFICIARY & ESTATE: We assist the client in assessing and developing long-term strategies,
including as appropriate, living trusts, wills, estate tax reviews, powers of attorney, asset protection
plans, nursing homes, and Medicaid.
• EDUCATION: We review and assist in developing a saving plan and goal for future education costs.
We gather required information through in-depth personal interviews. Information gathered includes
the client's current financial status, tax status, future goals, return objectives and attitudes towards
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risk. We carefully review documents supplied by the client, including a questionnaire completed by the
client, and prepare a written report. Should the client choose to implement the recommendations
contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance
agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the
client's discretion.
We also provide general non-securities advice on topics that may include tax and budgetary planning,
estate planning, education planning, and business planning.
Typically, the financial plan is presented to the client within six months of the contract date, provided
that all information needed to prepare the financial plan has been promptly provided.
Financial Planning recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. All recommendations are of a generic nature.
ASSETS UNDER MANAGEMENT
Assets under Management: As noted above, we manage client assets on both a discretionary and non-
discretionary basis. As of December 31, 2024, we have a total of $639,384,881 in assets under
management; with $341,158,515 under discretionary management and $298,226,366 under non-
discretionary management.
Item 5 Fees and Compensation
INVESTMENT PORTFOLIO SERVICES & INVESTMENT MODEL PORTFOLIO MANAGEMENT FEES
Our annual fees for Investment Management Services are based upon a percentage of assets under
management and generally range from 0.5% to 2.0%.
Our fees are billed quarterly in arrears based upon the value (market value or fair market value in the
absence of market value), of the client's account at the end of the previous period. Fees are generally
debited from the client’s account in accordance with the client authorization in the Investment
Advisory Service Agreement. Clients have the option to have fees billed to them directly or to an
alternative account with written authorization.
Generally, a minimum of $100,000 of assets under management is required for this service. This
account size may be negotiable under certain circumstances. Alliance Advisory & Securities, LLC may
group certain related client accounts for the purpose of achieving the minimum account size and
determining the annualized fee.
FINANCIAL PLANNING FEES
Alliance Advisory & Securities, LLC's Financial Planning fee is determined based on the nature of the
services being provided and the complexity of each client’s circumstances. All fees are agreed upon
prior to entering into a contract with any client.
Our Financial Planning fees are calculated and charged on an hourly basis, ranging from $175 to $650
per hour. Although the length of time it will take to provide a Financial Plan will depend on each
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client's personal situation, we will provide an estimate for the total hours at the start of the advisory
relationship.
Alternatively, our Financial Planning fees may be calculated and charged on a fixed fee basis, typically
ranging from $1,250 to $10,000 per year, charged quarterly, depending on the specific arrangement
reached with the client.
We may request a retainer upon completion of our initial fact-finding session with the client; however,
advance payment will never exceed $1,200 for work that will not be completed within six months. The
balance is due upon completion of the plan.
The client is billed in arrears based on actual hours accrued.
Financial Planning Fee Offset: Alliance Advisory & Securities, LLC reserves the discretion to reduce or
waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to engage us
for our Portfolio Management Services.
GENERAL INFORMATION ABOUT FEES & COMPENSATION
Additional Compensation: an Investment Advisor Representative and other related persons of our firm
are licensed as insurance agents. In their separate capacity, these individuals are able to implement
investment recommendations for advisory clients for separate and typical compensation (i.e.,
commissions or other sales-related forms of compensation). This presents a conflict of interest to the
extent that these individuals recommend an investment which results in a commission being paid to
the individuals. Clients are not under any obligation to engage these individuals when considering
implementation of advisory recommendations. The implementation of any or all recommendations is
solely at the discretion of the client.
Limited Negotiability of Advisory Fees: Although Alliance Advisory & Securities, LLC has established the
aforementioned fee schedule(s); we retain the discretion to negotiate alternative fees on a client-by-
client basis. Client facts, circumstances, and needs are considered in determining the fee schedule.
These include the complexity of the client, assets to be placed under management, anticipated future
additional assets, related accounts, portfolio style, account composition, and reports among other
factors. The specific annual fee is identified in the contract between the adviser and each client.
Discounts, not generally available to our advisory clients, may be offered at the Advisor’s discretion.
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason by giving notice in writing to the Advisor. As disclosed above, certain fees are
paid in advance of services provided. Upon termination of any account, any prepaid and unearned fees
will be promptly refunded. In calculating a client’s reimbursement of fees, we will pro rate the
reimbursement according to the number of days remaining in the billing period.
Execution of Investment Account Transactions: When we arrange for the execution of securities
transactions for you, through non-affiliated brokers or dealers we will strive to execute the transaction
in a manner that we reasonably believe will provide best execution. In selecting a broker or dealer, we
may consider, among other things, the broker or dealer’s execution capabilities, reputation, and access
to the markets for the securities being traded. We generally will seek competitive commission rates
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but will not necessarily attempt to obtain the lowest possible commission for transactions in your
account.
Instead of allowing us to select brokers or dealers for your account, you may direct us in writing to use
a particular broker or dealer to execute some or all transactions for your account. In that case, you will
negotiate terms and arrangements for your account with that broker or dealer, and we will not seek
better execution services or prices from other brokers or dealers or be able to “batch” client
transactions for execution through other brokers or dealers with orders for other accounts advised or
managed by us. As a result, you may pay higher commissions or other transaction costs or greater
spreads, or receive less favorable net prices, on transactions for your account than would otherwise be
the case.
Mutual Fund Fees: All fees paid to Alliance Advisory & Securities, LLC for investment advisory services
are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will
generally include a management fee, other fund expenses, and a possible distribution fee. Distribution
fees are also known as 12b-1 fees. The 12b-1 fee is considered to be an operational expense and, as
such, is included in a fund's expense ratio. It is generally between 0.25 and 1% (the maximum allowed)
of a fund's net assets and can be paid to the broker or dealer. If the fund also imposes sales charges, a
client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly,
without our services. In that case, the client would not receive the services provided by our firm which
are designed, among other things, to assist the client in determining which mutual fund or funds are
most appropriate to each client's financial condition and objectives. Accordingly, the client should
review both the fees charged by the funds and our fees to fully understand the total amount of fees to
be paid by the client and to thereby evaluate the advisory services being provided. Generally, no-load
funds will be recommended when consistent with the client's particular circumstances, investment
objectives, time horizon, and suitability.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees
and expenses charged by custodians and imposed by broker dealers, including but not limited to, any
transaction charges imposed by a broker dealer with which an independent investment manager
effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item
12) of this Form ADV for additional information.
Advisory Fees in General: Clients should note that similar advisory services may be available from
other registered investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $1,200 more than six months in advance of services rendered.
Additional Fees: We may receive fees from multiple sources. For example, we may receive fees from
Clients for both financial planning and investment advisory services.
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Item 6 Performance-Based Fees and Side-By-Side Management
Alliance Advisory & Securities, LLC does not charge performance-based fees.
Item 7 Types of Clients
Alliance Advisory & Securities, LLC provides advisory services to the following types of clients:
• Individuals (other than high net worth individuals)
• High net worth individuals
• Pension and profit sharing plans (other than plan participants)
• Other pooled investment vehicles (e.g., hedge funds)
• Charitable organizations
• Corporations or other businesses not listed above
• Trusts
As previously disclosed in Item 5, our firm has established certain initial minimum account
requirements, based on the nature of the service(s) being provided. For a more detailed understanding
of those requirements, please review the disclosures provided in each applicable service agreement.
Requirements for opening and maintaining an account, such as minimum account size, are discussed
under Item 5- Fees and Compensation.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing client
assets:
Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an
appropriate allocation of asset classes (including cash, fixed income, equites, and alternative assets)
that are suitable to the client’s investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry, or market sector. Another risk is that the ratio of asset class allocations will change over time
due to market movements and, if not corrected, will no longer be appropriate for the client’s goals.
Fundamental Analysis: We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition
and management of the company itself) to determine if the company is underpriced (indicating it may
be a good time to buy) or overpriced (indicating it may be time to sell).
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Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
Technical Analysis: In some cases, we may analyze past market movements and apply that analysis to
the present to recognize recurring patterns of investor behavior and potentially predict future price
movements.
Technical analysis does not consider the underlying financial condition of a company. This presents a
risk in that a poorly managed or financially unsound company may underperform regardless of market
movement.
Quantitative Analysis: We use mathematical models in an attempt to obtain more accurate
measurements of a company’s quantifiable data, such as the value of share price or earnings per
share, and predict changes to that data.
A risk in using quantitative analysis is that the models used may be based on assumptions that prove to
be incorrect.
Qualitative Analysis: We subjectively evaluate non-quantifiable factors such as quality of
management, labor relations, and strength of research and development factors not readily subject to
measurement and predict changes to share price based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Mutual Fund and/or ETF Analysis: We look at the experience and track record of the manager of the
mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest
over a period of time and in different economic conditions. We also look at the underlying assets in a
mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying
investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an
attempt to determine if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance
does not guarantee future results. A manager who has been successful may not be able to replicate
that success in the future. In addition, as we do not control the underlying investments in a fund or
ETF, managers of different funds held by the client may purchase the same security, increasing the risk
to the client if that security were to fall in value. There is also a risk that a manager may deviate from
the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less
suitable for the client’s portfolio.
Third-Party Money Manager Analysis: We examine the experience, expertise, investment
philosophies, and past performance of independent third-party investment managers in an attempt to
determine if that manager has demonstrated an ability to invest over a period of time and in different
economic conditions. We monitor the manager’s underlying holdings, strategies, concentrations, and
leverage as part of our overall periodic risk assessment. Additionally, as part of our due diligence
process, we survey the manager’s compliance and business enterprise risks.
A risk of investing with a third-party manager who has been successful in the past is that he/she may
not be able to replicate that success in the future. In addition, as we do not control the underlying
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investments in a third-party manager’s portfolio, there is also a risk that a manager may deviate from
the stated investment mandate or strategy of the portfolio, making it a less suitable investment for our
clients. Moreover, as we do not control the manager’s daily business and compliance operations, we
may be unaware of the lack of internal controls necessary to prevent business, regulatory or
reputational deficiencies.
Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities, and
other publicly-available sources of information about these securities, are providing accurate and
unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that
our analysis may be compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases: We purchase securities with the idea of holding them in the client's account for
a year or longer. Typically, we employ this strategy when:
• we believe the securities to be currently undervalued, and/or;
• we want exposure to a particular asset class over time, regardless of the current projection for this
class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may
not take advantage of short-term gains that could be profitable to a client. Moreover, if our
predictions are incorrect, a security may decline sharply in value before we make the decision to sell.
Short-term purchases: When utilizing this strategy, we purchase securities with the idea of selling
them within a relatively short time (typically a year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we purchase.
A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are
then left with the option of having a long-term investment in a security that was designed to be a
short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy, and will
result in increased brokerage and other transaction-related costs, as well as less favorable tax
treatment of short-term capital gains.
RISK OF LOSS
Investing in securities does not guarantee returns and involves a risk of loss that clients should be
prepared to bear. We ask that you work with us to help us understand your tolerance for risk.
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Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management.
There are no material disciplinary events relating to our firm and/or our management personnel.
Item 10 Other Financial Industry Activities and Affiliations
While Alliance Advisory & Securities, LLC, and its personnel endeavor at all times to put the interest of
the clients first as part of our fiduciary duty, clients should be aware that the receipt of additional
compensation itself creates a conflict of interest, and may affect the judgment of these individuals
when making recommendations.
Personnel of our firm, in their individual capacities, are agents for various insurance companies. As
such, these individuals are able to receive separate, yet customary commission compensation resulting
from implementing product transactions on behalf of advisory clients. Clients, however, are not under
any obligation to engage these individuals when considering implementation of advisory
recommendations. The implementation of any or all recommendations is solely at the discretion of the
client.
Alliance Advisory & Securities, LLC and/or Management personnel of Alliance Advisory & Securities,
LLC are related, through common ownership and control, to Alliance Financial Group, Inc. Alliance
Financial Group, Inc. or one or more of our related persons also act as general partner or manager of
Commune Capital, LLC, and its various entities. (described in Item 4 above and disclosed on Item 7.A
and Item 7.B of our ADV Part 1). (Part 1 of our Form ADV can be accessed by following the directions
provided on the Cover Page of this Firm Brochure.)
Advisory clients of our firm are solicited to invest in these entities; however, because investment in
these types of entities may involve certain additional degrees of risk, they will only be recommended
when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and
suitability. Clients are under no obligation to invest in any of the above described entities or to
implement any advisory recommendations.
Clients should be aware that the receipt of additional compensation by Alliance Advisory & Securities,
LLC and its management persons or employees creates a conflict of interest that may impair the
objectivity of our firm and these individuals when making advisory recommendations. Alliance
Advisory & Securities, LLC, endeavors at all times to put the interest of its clients first as part of our
fiduciary duty as a registered investment adviser; we take the following steps to address this conflict:
• we disclose to clients the existence of all material conflicts of interest, including the potential for our
firm and our employees to earn compensation from advisory clients in addition to our firm's advisory
fees;
• we disclose to clients that they are not obligated to purchase recommended investment products
from our employees or affiliated companies;
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15
• we collect, maintain and document accurate, complete, and relevant client background information,
including the client’s financial goals, objectives, and risk tolerance;
• our firm's management conducts regular reviews of each client account to verify that all
recommendations made to a client are suitable to the client’s needs and circumstances;
• we require that our employees seek prior approval of any outside employment activity so that we
may ensure that any conflicts of interests in such activities are properly addressed;
• we periodically monitor these outside employment activities to verify that any conflicts of interest
continue to be properly addressed by our firm; and
• we educate our employees regarding the responsibilities of a fiduciary, including the need for having
a reasonable and independent basis for the investment advice provided to clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws. We will
provide a copy of this code of ethics to any client or prospective client upon request.
Alliance Advisory & Securities, LLC and our personnel owe a duty of loyalty, fairness, and good faith
towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of
Ethics but to the general principles that guide the Code of Ethics.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm’s
access persons. Among other things, our Code of Ethics also requires prior approval of any acquisition
of securities in a limited offering (e.g., private placement) or an initial public offering. Our Code of
Ethics also provides for oversight, enforcement, and recordkeeping provisions.
Our Code of Ethics further includes the firm's policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public information, all
employees are reminded that such information may not be used in a personal or professional capacity.
A full copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to lmd@aewealth.comor by calling us at 805-371-8020.
Agency Cross-Transactions
Alliance Advisory & Securities, LLC and individuals associated with our firm are prohibited from
engaging in principal transactions.
Alliance Advisory & Securities, LLC may, at times, effect an agency cross transaction for an advisory
client, provided that the transaction is consistent with our firm's fiduciary duty to the client and that all
requirements outlined in Sec. 206(3)-2 of the Investment Advisers Act of 1940 are met.
An agency cross transaction is a transaction where our firm acts as an investment adviser in relation to
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a transaction in which Alliance Advisory & Securities, LLC, or any person controlled by or under
common control with our firm, acts as broker for both the advisory client and for another person on
the other side of the transaction.
Other Entities:
Alliance Advisory & Securities, LLC and/or Management personnel of Alliance Advisory & Securities,
LLC are related, through common ownership and control, to Alliance Financial Group, Inc. Alliance
Financial Group, Inc. also acts as general partner or manager of Commune Capital, LLC, and its various
entities (the “Entity”).
Investments in the Entity may be recommended to advisory clients for whom such an investment may
be more suitable than would a separate advisory account managed by our firm. Clients who invest in
the Entity are not charged any additional advisory fees other than the advisory fee allocated to the
limited partners or members of the Entity.
The Entity is not required to register as an investment company under the Investment Company Act of
1940 in reliance upon an exemption available to funds whose securities are not publicly offered.
Alliance Advisory & Securities, LLC and affiliates manage the Entity on a discretionary basis in
accordance with the terms and conditions of the Entity's offering and organizational documents.
Personal Transactions
Our Code of Ethics is designed to assure that the personal securities transactions, activities, and
interests of our employees will not interfere with (i) making decisions in the best interest of advisory
clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for
their own accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal accounts
securities identical to or different from those recommended to our clients. In addition, any related
person(s) may have an interest or position in a certain security which may also be recommended to a
client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account, thereby preventing such
employee(s) from benefiting from transactions placed on behalf of advisory accounts.
We may aggregate our employee trades with client transactions where possible and when compliant
with our duty to seek best execution for our clients. In these instances, participating clients will receive
an average share price and transaction costs (when applicable) will be shared equally and on a pro-rata
basis. In the instances where there is a partial fill of a particular batched order, we will allocate all
purchases pro-rata, with each account paying the average price. Our employee accounts will be
included in the pro-rata allocation.
As these situations represent actual or potential conflicts of interest to our clients, we have established
the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm
complies with its regulatory obligations and provides our clients and potential clients with full and fair
disclosure of such conflicts of interest:
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1. No principal or employee of our firm may put his or her own interest above the interest of an
advisory client.
2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where
their decision is a result of information received as a result of his or her employment unless the
information is also available to the investing public.
3. It is the expressed policy of our firm that no person employed by us may purchase or sell any
security prior to a transaction(s) being implemented for an advisory account. This prevents such
employees from benefiting from transactions placed on behalf of advisory accounts.
4. Our firm requires prior approval for any IPO or private placement investments by related persons of
the firm.
5. We maintain a list of all reportable securities holdings for our firm and anyone associated with this
advisory practice that has access to advisory recommendations ("access person"). These holdings are
reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee.
6. We have established procedures for the maintenance of all required books and records.
7. All clients are fully informed that related persons may receive separate commission compensation
when effecting transactions during the implementation process.
8. Clients can decline to implement any advice rendered, except in situations where our firm is granted
discretionary authority.
9. All of our principals and employees must act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
10. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our
firm.
11. We have established policies requiring the reporting of Code of Ethics violations to our senior
management.
12. Any individual who violates any of the above restrictions may be subject to termination.
As disclosed in the preceding section of this Brochure (Item 10), related persons of our firm are
licensed as an insurance agent/broker of various insurance companies. Please refer to Item 10 for a
detailed explanation of these relationships and important conflict of interest disclosures.
Item 12 Brokerage Practices
Alliance Advisory & Securities, LLC does not have any soft-dollar arrangements.
Alliance Advisory & Securities, LLC will block trade where possible and when advantageous to clients.
This blocking of trades permits the trading of aggregate blocks of securities composed of assets from
multiple client accounts.
Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an
average share price. Alliance Advisory & Securities, LLC will typically aggregate trades among clients
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whose accounts can be traded at a given broker. Alliance Advisory & Securities, LLC's block trading
policy and procedures are as follows:
1) Transactions for any client account may not be aggregated for execution if the practice is prohibited
by or inconsistent with the client's advisory agreement with Alliance Advisory & Securities, LLC, or our
firm's order allocation policy.
2) The trading desk in concert with the portfolio manager must determine that the purchase or sale of
the particular security involved is appropriate for the client and consistent with the client's investment
objectives and with any investment guidelines or restrictions applicable to the client's account.
3) The portfolio manager must reasonably believe that the order aggregation will benefit, and will
enable Alliance Advisory & Securities, LLC to seek best execution for each client participating in the
aggregated order. This requires a good faith judgment at the time the order is placed for the
execution. It does not mean that the determination made in advance of the transaction must always
prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the
duty to seek the best quality of execution, as well as the best net price.
4) Prior to entry of an aggregated order, orders for each individual account are created but not sent.
An allocation list is created based on these orders at which time a block order ticket is created,
reviewed, and submitted.
5) If the order cannot be executed in full at the same price or time, the securities actually purchased or
sold by the close of each business day must be allocated pro rata among the participating client
accounts in accordance with the initial order ticket or other written statement of allocation. However,
adjustments to this pro rata allocation may be made to participating client accounts in accordance
with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this
pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or
to avoid excessive ticket charges in smaller accounts.
6) Generally, each client that participates in the aggregated order must do so at the average price for
all separate transactions made to fill the order, and must share in any fees associated with the trades
on a pro rata basis in proportion to the client's participation. Under the client’s agreement with the
custodian/broker, transaction costs may be based on the number of shares traded for each client.
7) If the order will be allocated in a manner other than that stated in the initial statement of allocation,
a written explanation of the change must be provided to and approved by the Chief Compliance
Officer no later than the morning following the execution of the aggregate trade.
8) Alliance Advisory & Securities, LLC's client account records separately reflect, for each account in
which the aggregated transaction occurred, the securities which are held by, and bought and sold for,
that account.
9) Funds and securities for aggregated orders are clearly identified on Alliance Advisory & Securities,
LLC's records and to the broker-dealers or other intermediaries handling the transactions, by the
appropriate account numbers for each participating client.
10) No client or account will be favored over another.
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Fidelity Investments & Charles Schwab
Alliance Advisory & Securities, LLC has arrangements with both Fidelity Investments and Charles
Schwab Institutional (together with all affiliates, “Fidelity” and "Schwab") through which Fidelity and
Schwab provide our firm with their "platform" services. The platform services include, among others,
brokerage, custodial, administrative support, record keeping and related services that are intended to
support Alliance Advisory & Securities, LLC in conducting business and in serving the best interests of
our clients but that may also benefit us.
Fidelity and Schwab charge brokerage commissions and transaction fees for effecting certain securities
transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions can be
charged for individual equity and debt securities transactions). Fidelity and Schwab enable Alliance
Advisory & Securities, LLC to obtain many no-load mutual funds without transaction charges and other
no-load funds at nominal transaction charges. Both Fidelity and Schwab’s commission rates are
generally considered discounted from customary retail commission rates. However, the commissions
and transaction fees charged by Fidelity and Schwab may be higher or lower than those charged by
other custodians and broker-dealers.
Alliance Advisory & Securities, LLC receives services called WealthScape from Fidelity and Schwab
Advisor Center from Schwab which we use to manage and generate trade orders. Without these
arrangements, we might be compelled to purchase the same or similar services at our own expense.
As a result of receiving such services for no additional cost, we may have an incentive to continue to
use or expand the use of Fidelity and Schwab's services. We examined this potential conflict of interest
when we chose to enter into these relationships and have determined that these relationships are in
the best interests of Alliance Advisory & Securities, LLC's clients and satisfies our client obligations,
including our duty to seek best execution. A client may pay a commission or transaction fee that is
higher than another qualified broker-dealer might charge to effect the same transaction where we
determine in good faith that the fee is reasonable in relation to the value of the brokerage and
research services received. In seeking best execution, the determinative factor is not the lowest
possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a broker-dealer’s services, including the value of research provided,
execution capability, commission rates, and responsiveness. Accordingly, while Alliance Advisory &
Securities, LLC will seek competitive rates, to the benefit of all clients, we may not necessarily obtain
the lowest possible commission or transaction fee rates for specific client account transactions.
Although the services that may be obtained by us will generally be used to service all of our clients, a
brokerage commission paid by a specific client may be used to pay for services that are not used in
managing that specific client’s account. Alliance Advisory & Securities, LLC, Fidelity, and Schwab are
not affiliated.
National Advisors Trust Company, FSB
Alliance Advisory & Securities, LLC has an arrangement with National Advisors Trust Company , FSB
(together with all affiliates, "NATC") through which NATC provides our firm with their "platform"
services. The platform services include, among others, brokerage, custodial, administrative support,
record keeping and related services that are intended to support intermediaries like Alliance Advisory
& Securities, LLC in conducting business and in serving the best interests of our clients but that may
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20
also benefit us.
NATC charges brokerage commissions and transaction fees for effecting certain securities transactions
(i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for
individual equity and debt securities transactions). NATC’s commission rates are in line with other
retail commission rates. However, the commissions and transaction fees charged by NATC may be
higher or lower than those charged by other custodians and broker-dealers.
Item 13 Review of Accounts
As noted below, Client accounts are reviewed by the Client’s Advisor and randomly reviewed by the
Chief Compliance Officer, or designee.
INVESTMENT PORTFOLIO SERVICES & INVESTMENT MODEL PORTFOLIO MANAGEMENT SERVICES
REVIEWS: While the underlying securities within the accounts are regularly monitored, these accounts
are reviewed at least annually. Accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in variables
such as the client's individual circumstances, or the market.
REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive
from their broker-dealer or custodian, we may provide written reports quarterly, semi-annually, or
annually, depending on client request and investment advisory agreements, summarizing account
performance, balances, and holdings. These reports along with the custodial reports will also remind
the client to notify us if there have been changes in the client's financial situation or investment
objectives and whether the client wishes to impose investment restrictions or modify existing
restrictions.
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms of the
specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless
otherwise contracted for.
REPORTS: Financial Planning clients will receive a completed financial plan. Additional reports will not
typically be provided unless otherwise contracted for.
Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
Our firm may pay referral fees to independent persons or firms ("Solicitors") for introducing clients to
us. Whenever we pay a referral fee, we require the Solicitor to provide the prospective client with a
copy of this document (our Firm Brochure) and a separate disclosure statement that includes the
following information:
• the Solicitor's name and relationship with our firm;
• the fact that the Solicitor is being paid a referral fee;
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• the amount of the fee; and
• Whether the fee paid to us by the client will be increased above our normal fees in order to
compensate the Solicitor.
As a matter of firm practice, the advisory fees paid to us by clients referred by solicitors are not
increased as a result of any referral.
It is Alliance Advisory & Securities, LLC's policy not to accept or allow our related persons to accept any
form of compensation, including cash, sales awards, or other prizes, from a non-client in conjunction
with the advisory services we provide to our clients.
Item 15 Custody
Alliance Advisory & Securities, LLC is not deemed to have custody of client funds or securities. In
addition to the periodic statements that clients receive directly from their custodians, we may also
send account statements directly to our clients on a quarterly basis, based on their investment
advisory service. We urge our clients to carefully compare the information provided on these
statements to ensure that all account transactions, holdings, and values are correct and current.
Item 16 Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a client's account without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the client:
• determine the security to buy or sell; and/or
• determine the amount of the security to buy or sell
Clients may give us discretionary authority when they sign a discretionary agreement with our firm,
and may limit this authority by giving us written instructions. Clients may also change/amend such
limitations by once again providing us with written instructions.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm
may provide investment advisory services relative to client investment assets, clients maintain
exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Clients are responsible for instructing each custodian of the assets, to forward to
the client copies of all proxies and shareholder communications relating to the client’s investment
assets. We may provide clients with consulting assistance regarding proxy issues if they contact us with
questions at our principal place of business.
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Item 18 Financial Information
Alliance Advisory & Securities, LLC does not require prepayment of more than $1,200 in fees per client
and more than six months in advance of services rendered. Alliance Advisory & Securities, LLC is not
currently experiencing, and does not currently anticipate, any financial condition that it believes is
reasonably likely to impair its ability to meet contractual commitments to clients.
Alliance Advisory & Securities, LLC has not been the subject of any bankruptcy proceeding.
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Part 2B of Form ADV: Brochure Supplement
Alliance Advisory & Securities, LLC
31248 Oak Crest Drive, Ste 100
Westlake Village, California 91361
Telephone: 805-371-8020
Email: lmd@aewealth.com
Web Address: www.allianceadvisory.com
Web Address: www.aewealth.com
March 24, 2025
This brochure supplement provides information about your financial representative that supplements
the Alliance Advisory & Securities, LLC (dba Alliance Entrust) brochure. You should have received a copy
of that brochure. Please contact our service department at 805-371-8020 if you did not receive Alliance
Advisory & Securities, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about the financial representatives listed in this brochure is available on the SEC’s
website at www.adviserinfo.sec.com
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Some of our financial representatives (our “Advisors”) hold professional designations. The following is
an explanation of those designations and the minimum qualifications required to obtain and maintain
them.
Certified Financial Planner (CFP) ®:
The CFP® (Certified Financial Planner) designation signifies a financial planner who has met rigorous
education, training, and ethical standards, demonstrating competency in comprehensive financial
planning and a commitment to acting as a fiduciary, prioritizing clients' best interests. To obtain the
Certified Financial Planner (CFP®) certification, a candidate must complete a CFP Board-registered
education program, pass the CFP® exam, demonstrate relevant financial planning experience, and meet
ethics requirements, including signing an ethics declaration and passing a background check. Program
Requirements
Education: CFP® professionals must develop their theoretical and practical financial planning knowledge
by completing a comprehensive course of study at a college or university offering a financial planning
curriculum approved by CFP Board. Other options for satisfying the education component include
submitting a transcript review or previous financial planning-related course work to CFP Board for
review and credit, or showing the attainment of certain professional designations or academic degrees.
Examination: CFP® practitioners must pass a comprehensive two-day, 10-hour CFP® Certification
Examination that tests their ability to apply financial planning knowledge in an integrated format. Based
on regular research of what planners do, the exam covers the financial planning process, tax planning,
employee benefits and retirement planning, estate planning, investment management and insurance.
Experience: CFP® professionals must have three years’ minimum experience in the financial planning
process prior to earning the right to use the CFP® certification marks. As a result, CFP® practitioners
possess financial counseling skills in addition to financial planning knowledge.
Ethics: As a final step to certification, CFP® practitioners agree to abide by a strict code of professional
conduct, known as CFP Board’s Code of Ethics and Professional Responsibility that sets forth their ethical
responsibilities to the public, clients, and employers. CFP Board also performs a background check during
this process, and each individual must disclose any investigations or legal proceedings related to their
professional or business conduct.
Continuing Education Requirements: Once certified, CFP® practitioners are required to maintain
technical competence and fulfill ethical obligations. Every two years, they must complete a minimum 30
hours of continuing education to stay current with developments in the financial planning profession
and better serve clients.
Chartered Retirement Planning Counselor (CRPC) ®:
The CRPC designation, or Chartered Retirement Planning Counselor, is a professional certification for
financial advisors specializing in retirement planning, awarded by the College for Financial Planning
(CFFP). CRPC designation holders are experts in helping clients navigate retirement planning, including
pre- and post-retirement needs, asset management, and estate planning.
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Program Requirements: To earn the CRPC designation, financial professionals must complete specific
course materials and pass a proctored exam.
Continuing Education Requirements: Once certified, CRPC holders must renew their certification every
two years by completing 16 hours of ongoing education and reaffirming compliance.
Certified Kingdom Advisor (CKA®)
The CKA is a certification designed for professionals serving clients in the Christian faith and who take a
values-based approach to financial matters. It involves a course of study that integrates biblical
principles with core financial advisory training. This issuing organization for the CKA certification is
Kingdom Advisors, Inc.
Program Requirements: All candidates must complete Kingdom Advisors Core Training, pass a
certification exam, and sign a "Statement of Faith," obtain a letter of reference from a pastor or
member of pastoral staff, a signed statement of personal stewardship, and two client references.
Additional prerequisites vary by discipline:
• Accountant: CPA, EA
• Attorney: JD
• Financial Planner: CFP, ChFC, or CPA/PFS designation or have 10 years of full-time financial-
•
•
planning experience.
Insurance Professional: CLU or 10 years of full-time experience practicing with clients in this
discipline
Investment Professional: CFP, ChFC, CPA/PFS, CFA, CIMA, AAMS designation or have 10 years of
full time experience practicing with clients in this discipline.
Continuing Education Requirements: CKA holders must complete 10 of continuing education hours
per year.
Doctor of Business Administration (DBA)
A Doctor of Business Administration (DBA) is a professional doctorate designed for individuals seeking
to enhance their business skills and knowledge, typically those with experience in owning, managing,
or operating a business. It focuses on practical application of business principles and research to solve
real-world problems.
Investment Advisory Certified Compliance Professional (IACCP®)
The IACCP® is a professional designation program, co-sponsored by COMPLY and the Investment Adviser
Association (IAA), designed for compliance professionals to demonstrate their knowledge of investment
adviser regulatory obligations and gain competence in trading, regulatory mandates, and current
compliance priorities.
Program Requirements: A candidate must complete 17 required compliance courses, 3 elective courses,
submit an ethics assessment and statement, have 2 years of work experience in investment adviser
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compliance and pass the 3-hour IACCP® certifying examination. The IACCP® program takes
approximately 18 months to complete.
Continuing Education Requirements: Maintaining the IACCP designation requires the annual completion
of 12 continuing education requirements.
Certified Anti-Money Laundering Specialist (CAMS)
The CAMS (Certified Anti-Money Laundering Specialist) certification, offered by the Association of
is a globally recognized credential for
Certified Anti-Money Laundering Specialists (ACAMS),
professionals in the anti-money laundering (AML) field, demonstrating expertise in AML/CFT principles
It's designed for professionals working in AML/CFT compliance, financial crime investigation, and related
roles.
Program Requirements: Candidates must pass a proctored exam covering various aspects of AML/CFT,
including money laundering risks, compliance standards, and regulatory requirements. The exam
consists of 120 questions with 3.5 hours to complete the exam.
Continuing Education Requirements: The CAMS certification is valid for three years. To recertify,
professionals must complete continuing education credits and meet other requirements set by ACAMs.
Certified Fraud Examiner (CFE)
The Certified Fraud Examiner (CFE) credential, awarded by the Association of Certified Fraud Examiners
(ACFE), is a globally recognized standard of excellence in the anti-fraud profession, demonstrating
expertise in fraud prevention, detection, and investigation. A CFE is a professional who specializes in
detecting, investigating, and preventing fraud.
Program Requirements: 1) Join the ACFE: Become a member of the Association of Certified Fraud
Examiners. 2) Meet eligibility requirements: This involves having a bachelor's degree, two years of fraud-
related experience, and meeting a minimum number of qualifying points based on education and
experience. 3) Examination: Pass the CFE exam which covers four areas: Financial Transactions and
Fraud Schemes, Law, Investigation, and Fraud Prevention and Deterrence. 4) Adhere to the CFE Code of
Professional Ethics.
Continuing Education Requirements: Active membership, and the completion of 40 credits within the
24 months preceding the date of application for recertification. At least 20 credits must relate directly
to the detection and deterrence of fraud and 4 credits must relate directly to ethics.
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Randy Sanada Jr., CFP®, CKA®
Year of Birth
•
1974
Education
•
Biola University, B.A., Business Administration
Credentials & Licenses
•
•
•
Certified Financial Planner (CFP®)
Certified Kingdom Advisor (CKA®)
Investment Advisor Representative – Series 63
Business Background
•
•
Alliance Financial Group, Inc.: 1994 - present
- Vice President
Alliance Advisory & Securities, LLC: 1994 – present
- President & Chief Executive Officer
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Randy Sanada Jr. is part of the management team of Alliance Advisory & Securities, LLC. The
trades of Mr. Sanada’s clients are reviewed on a periodic basis and client files are randomly
reviewed for compliance with the Firm’s policies and procedures. Liza M. Dela Cruz, Chief
Compliance Officer; (805) 371-8020 is responsible for supervising Mr. Sanada’s advisory
activities.
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Sandi L. Bublitz, CFP®
Year of Birth
•
1956
Education
•
University of California, Santa Barbara, B.A., Communications
Credentials & Licenses
•
Certified Financial Planner (CFP®)
Business Background
•
Alliance Advisory & Securities, LLC: 1991 – present
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
Sandi Bublitz is licensed as an insurance agent and is compensated by commissions from the
sale of insurance products. Receipt of such compensation creates an incentive to recommend
investment products based on the compensation received, rather than on the client’s needs.
Supervision
•
Sandi Bublitz’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Ms. Bublitz’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Ms.
Bublitz’s advisory activities.
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Lee H. Falberg, MBA
Year of Birth
•
1938
Education
•
•
Bradley University, Illinois, B.S., Mechanical Engineering
Loyola University, Illinois, MBA, Business Administration
Credentials & Licenses
•
Investment Advisor Representative – Series 63 & Series 65
Business Background
•
Alliance Advisory & Securities, LLC: 2002 – present
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Lee Falberg’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Falberg’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Falberg’s advisory activities.
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Patrick K. McIlrath, MBA, CRPC®
Year of Birth
•
1951
Education
•
United State Naval Academy, B.S., Oceanography
• Wharton School of Finance, University of Pennsylvania, MBA, Strategic Planning & General
Management
Credentials & Licenses
•
•
Chartered Retirement Planning Consultant (CRPC®)
Investment Advisor Representative – Series 63
Business Background
•
•
Alliance Advisory & Securities, LLC: 2005 – present
- Investment Advisor Representative
Aerie Financial Group: 2005 – present
- Chief Executive Officer
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
Pat McIlrath is licensed as an insurance agent and is compensated by commissions from the
sale of insurance products. Receipt of such compensation creates an incentive to recommend
investment products based on the compensation received, rather than on the client’s needs.
Supervision
•
Pat McIlrath’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. McIlrath’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
McIlrath’s advisory activities.
3/24/25
Firm Brochure Supplement
Hoby Pearce, CFP®
Year of Birth
•
1973
Education
•
California State University Northridge, B.S., Business & Marketing
Credentials & Licenses
•
•
Certified Financial Planner (CFP®)
Investment Advisor Representative – Series 63 & Series 65
Business Background
•
Alliance Advisory & Securities, LLC: 2009 – present
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Hoby Pearce’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Pearce’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Pearce’s advisory activities.
3/24/25
Firm Brochure Supplement
Jon Rehurek, CFP®, CKA®, ThM
Year of Birth
•
1971
Education
•
•
•
•
Southwest Baptist University, B.S. Business Administration with a concentration in Financial &
Economics
The Master’s Seminary, Master of Theology (ThM)
The Master’s Seminary, Master of Divinity (MDiv)
Ron Blue Institute at Indiana Wesleyan University, Executive Certificate in Financial Planning
Credentials & Licenses
•
•
•
Certified Financial Planner (CFP®)
Certified Kingdom Advisor (CKA®)
Investment Advisor Representative – Series 66
Business Background
•
•
Alliance Advisory & Securities, LLC: 2015 – present
- Investment Advisor Representative
Raymond James Financial Services: 2013 – 2015
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Jon Rehurek’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Rehurek’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Rehurek’s advisory activities.
3/24/25
Firm Brochure Supplement
Ben Simonds, CFP®, CKA®
Year of Birth
•
1987
Education
•
The Master’s College, B.S., Finance & Management
Credentials & Licenses
•
•
•
Certified Financial Planner (CFP®)
Certified Kingdom Advisor (CKA®)
Investment Advisor Representative – Series 66
Business Background
•
Alliance Advisory & Securities, LLC: 2011 – present
- Director of Operations
-Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Ben Simonds’ advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Simonds’ clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Simonds’ advisory activities.
3/24/25
Firm Brochure Supplement
Robert Knight, CRPC®, MBA
Year of Birth
•
1975
Education
•
•
California Lutheran University, Master in Financial Planning
California State University Northridge, B.S., Finance
Credentials & Licenses
•
•
Chartered Retirement Planning Counselor (CRPC®)
Investment Advisor Representative – Series 66
Business Background
•
•
Alliance Advisory & Securities, LLC: 2019 – present
- Investment Advisor Representative
Partnervest Advisory Services LLC: 2004-2019
• Waddell & Reed, Inc: 2001-2004
Disciplinary Information
•
Settled Customer Dispute in August 2011
Other Business Activities
•
None
Additional Compensation
•
Robert Knight is licensed as an insurance agent and is compensated by commissions from the
sale of insurance products. Receipt of such compensation creates an incentive to recommend
investment products based on the compensation received, rather than on the client’s needs.
Supervision
•
Robert Knight’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities LLC. The trades of Mr. Knight’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Knight’s advisory activities.
3/24/25
Firm Brochure Supplement
Vance Lavizzo, CFP®
Year of Birth
•
1986
Education
• Western Governors University, B.S., Business Administration
Credentials & Licenses
•
•
Certified Financial Planner (CFP®)
Investment Advisor Representative – Series 66
Business Background
•
Alliance Advisory & Securities, LLC: 2019 – present
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
• Vance Lavizzo’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Lavizzo’s clients are reviewed on a periodic basis and
client files are randomly reviewed for compliance with the Firm’s policies and procedures. Liza M.
Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr. Lavizzo’s
advisory activities.
3/24/25
Firm Brochure Supplement
Christopher Tyler, CFP®
Year of Birth
•
1993
Education
•
•
Hope International University, B.A., Business Management
University of California Los Angeles, Certificate, Personal Financial Planning
Credentials & Licenses
•
•
Certified Financial Planner (CFP®)
Investment Advisor Representative – Series 66
Business Background
•
•
•
•
Alliance Advisory & Securities, LLC: 2022 – present
- Investment Advisor Representative
Raymond James Financial Services: 2020 – 2022
- Investment Advisor Representative
Commonwealth Financial Network: 2019 – 2020
- Investment Advisor Representative
Alliance Advisory & Securities, Inc.: 2018 – 2019
- Investment Advisor Representative
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Christopher Tyler’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Tyler’s clients are reviewed on a periodic basis and
client files are randomly reviewed for compliance with the Firm’s policies and procedures. Liza
M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Tyler’s advisory activities.
3/24/25
Firm Brochure Supplement
Adam Silva
Year of Birth
• 1986
Education
• Liberty University – Certificate in Financial Planning
Credentials & Licenses
Investment Advisor Representative – Series 65
•
Business Background
• Alliance Advisory & Securities, LLC: 2021 – Present
Investment Advisor Representative
-
• PAC Properties: 2017 – 2021
- Property Manager
Disciplinary Information
• None
Other Business Activities
• None
Additional Compensation
• N/A
Supervision
• Adam Silva’s advisory activities are supervised by the Compliance Department of Alliance Advisory
& Securities, LLC. The trades of Mr. Silva’s clients are reviewed on a periodic basis and client files
are randomly reviewed for compliance with the Firm’s policies and procedures. Liza M. Dela Cruz,
Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr. Silva’s advisory
activities.
3/24/25
Firm Brochure Supplement
Neil Unger, CFP®
Year of Birth
•
1988
Education
•
•
•
Indiana University Bloomington – Chemistry
Indiana University Bloomington – Theatre and Drama
California University Berkley Extension - Financial Planning Certificate
Credentials & Licenses
•
•
Investment Advisor Representative – Series 65
Certified Financial Planner (CFP®)
Business Background
•
-
•
Alliance Advisory & Securities, LLC: 2023 – present
Investment Advisor Representative
David S Reinder, Inc: 2021-2023
Investment Advisor Representative
-
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Neil Unger’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Unger’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Mr.
Unger’s advisory activities.
3/24/25
Firm Brochure Supplement
Emily Swan
Year of Birth
•
1978
Education
•
Boston University, B.S., Communication
Credentials & Licenses
•
•
Investment Advisor Representative – Series 65
Notary – State of California
Business Background
•
•
•
Alliance Advisory & Securities, LLC: 2023 – present
- Investment Advisor Representative
David S. Reinders, Inc.: 2018-2023
- Investment Advisor Representative
-Administrative
Cloud & Fire: 2009-2018
-Finance & HR Administrator
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Emily Swan’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Ms. Swan’s clients are reviewed on a periodic basis
and client files are randomly reviewed for compliance with the Firm’s policies and procedures.
Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is responsible for supervising Ms.
Swan’s advisory activities.
3/24/25
Firm Brochure Supplement
Jeff Garagliano
Year of Birth
•
1975
Education
•
Colorado State University, B.A., Economics
Credentials & Licenses
•
•
•
Registered Representative – Series 7
General Securities Principal – Series 24
Investment Advisor Representative – Series 66
Business Background
•
Alliance Advisory & Securities, LLC: 1998 – present
- Investment Advisor Representative
- Chief Compliance Officer: 2012-2025
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Jeff Garagliano’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Mr. Garagliano are reviewed for compliance with the
Firm’s policies and procedures. Liza M. Dela Cruz, Chief Compliance Officer; (805) 371-8020 is
responsible for supervising Mr. Garagliano’s advisory activities.
3/24/25
Firm Brochure Supplement
Sean Nicholas Sottile, DBA
Year of Birth
•
1986
Education
•
•
•
Life Pacific University, BA, Biblical Studies
Azusa Pacific University, MA, Organizational Leadership
Grand Canyon University, Doctor of Business Administration
Credentials & Licenses
•
Investment Advisor Representative – Series 65
Business Background
•
•
•
Alliance Advisory & Securities, LLC: 2024 – present
- Vice President
Life Pacific University: 2021-2025
- Adjunct Professor
Crosspoint: 2013-2024
- Lead Pastor, Executive Director
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Sean Sottile is part of the management team of Alliance Advisory & Securities, LLC. His trades
are reviewed for compliance with the Firm’s policies and procedures. Liza M. Dela Cruz, Chief
Compliance Officer; (805) 371-8020, is responsible for supervising Mr. Sottile’s advisory
activities.
3/24/25
Firm Brochure Supplement
Liza M. Dela Cruz, CAMS, CFE, IACCP®
Year of Birth
•
1975
Education
•
•
•
Pepperdine University, Bachelor of Science, Management
Pepperdine University, Master in Business Administration, Finance
Pepperdine University School of Law, Certificate in Dispute Resolution
Credentials & Licenses
•
•
•
•
Investment Advisor Representative – Series 65
Investment Advisor Certified Compliance Professional (IACCP®)
Certified Anti-Money Laundering Specialist (CAMS)
Certified Fraud Examiner (CFE)
Business Background
•
•
•
Alliance Advisory & Securities, LLC: 2025 – present
- Chief Compliance Officer
SteelPeak Wealth, LLC: 2024-2024
- Senior Compliance Manager
DoubleLine Capital: 2016-2023
- Compliance Analyst
Disciplinary Information
•
None
Other Business Activities
•
None
Additional Compensation
•
n/a
Supervision
•
Liza M. Dela Cruz is part of the management team of Alliance Advisory & Securities, LLC. Her
trades are reviewed for compliance with the Firm’s policies and procedures and are supervised
by the Compliance Department or Executive Team.
3/24/25
Firm Brochure Supplement