Overview
- Headquarters
- Westlake Village, CA
- Total Firm Assets
- $687 million
- Average High-Net-Worth Client Portfolio Size
- $2.3 million
- Minimum Account Size
- $100,000
Fee Structure
Primary Fee Schedule (2025-03 ADV PART 2A+2B - FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 2.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $20,000 | 2.00% |
| $5 million | $100,000 | 2.00% |
| $10 million | $200,000 | 2.00% |
| $50 million | $1,000,000 | 2.00% |
| $100 million | $2,000,000 | 2.00% |
Clients
- High-Net-Worth Share of Firm Assets
- 74.27%
- Number of High-Net-Worth Clients
- 225
- Total Client Accounts
- 2,748
- Discretionary Accounts
- 1,270
- Non-Discretionary Accounts
- 1,478
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 18835
Additional Brochure: 2025-03 ADV PART 2A+2B - FIRM BROCHURE (2026-04-30)
View Document Text
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
April 29, 2026
This brochure provides information about the qualifications and business practices of Alliance Advisory
& Securities, LLC (dba Alliance Entrust). 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.
Rev. 04/29/26
Alliance Advisory & Securities, LLC (Firm Brochure)
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Item 2 Material Changes
This section discusses only material changes since the last annual update of our brochure dated March
24, 2025.
Management of Held-Away Accounts
We now offer an additional service to manage certain “held-away” accounts
(primarily
employer-sponsored retirement plans and HSAs) using an order-management platform provided by
Pontera Solutions, Inc. (“Pontera”). See Item 4 for a description of this service and Item 5 for fees and
billing for held-away accounts.
Assets Under Management
Item 4 has been updated to reflect the firm’s current assets under management, consistent with the
amounts reported in our most recent Form ADV Part 1A.
Brokerage Practices
Item 12 has been updated to reflect that, in addition to our existing preferred custodial platforms,
certain client accounts may now be held on the Altruist Financial, LLC (“Altruist”) custodial platform. This
change does not alter our advisory fee schedule but does provide an additional custodial option for
eligible clients.
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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
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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 a SEC-registered investment adviser with its principal place of
business located in California. Alliance Advisory & Securities, LLC began conducting business in 1982 and
also does business as (dba) Alliance Entrust. The Firm has also registered the trade name Devoted
Capital, which it expects to use in the future. These names are trade names/‘doing business as’ (DBA)
designations; the registered investment adviser is 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 (Non-Discretionary, Custom)
Our firm provides 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-
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dealer or insurance company and may include advice regarding the following securities:
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 overall suitability and in the client’s best interests.
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 (Discretionary, Model Driven)
Our firm provides discretionary portfolio management through a series of model asset allocation
portfolios designed to meet different risk and return objectives. Each model portfolio is designed to
meet a particular investment goal. These model portfolios and the related investment strategies are
described in more detail in Item 8 - Methods of Analysis, Investment Strategies, and Risk of Loss section
of this Brochure.
Our current model groups include:
Core: Conservative, 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
Client Control and Discretion
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.
Rebalancing and Ongoing Management
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.
Core Defensive Accounts
Because Core Defensive 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. Core Defensive accounts
generally have all interest, cash dividends, and capital gains sent directly to the cash/money market
position in the account.
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Values -Based Accounts
We offer Values-Based Accounts for clients who wish to incorporate certain values, including faith-based
or biblically responsible preferences, into their investment decisions in addition to their financial
objectives. These accounts generally use actively managed funds that apply values-based screening
criteria beyond typical index approaches, seeking to avoid companies or activities the managers view as
inconsistent with those values and to emphasize companies that demonstrate responsible business
practices. Because of this additional screening layer, these accounts may be less diversified and may
drift more in allocation and performance relative to similar portfolios that do not apply such screens or
to broad market indices.
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 and in the client’s best interest given 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 may recommend private offerings of affiliated operating companies sponsored by Commune
Capital, LLC (“Commune Capital”) to certain clients, typically structured as private limited partnerships
or limited liability companies. These offerings are generally available only to accredited investors, and
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each offering has its own private placement memorandum and related disclosure documents describing
its objectives, investment strategy, risks, restrictions, fees, and expenses.
Commune Capital offers various private placements and limited partnerships that invest in portfolios of
commercial loans and in equity interests in commercial real estate (such as multi-family and self-storage
properties). Each offering is managed by a management entity that is owned and operated, in whole or
in part, by Commune Capital (see Item 10 – Other Financial Industry Activities and Affiliations).
We recommend investments in these affiliated operating companies only when we believe they are
suitable for a client and are in the client’s best interest in light of the client’s financial situation,
investment objectives, time horizon, risk tolerance, liquidity needs, and overall circumstances. Our
recommendations regarding these offerings are made on a non-discretionary basis; clients make the
final decision whether to invest after reviewing the applicable offering documents. Because these
operating companies are affiliated with our firm and/or our supervised persons, recommending them
creates a conflict of interest, which is described in more detail in Item 10 of this brochure and in the
relevant offering materials.
Due to the illiquid and higher-risk nature of these private investments, we recommend them only when
we believe they are consistent with the client’s stated objectives, risk tolerance, liquidity needs,
suitability profile and overall best interests.
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 project future cash flows, asset
values, and withdrawal plans. Through the financial planning process, we consider all questions,
information, and analysis as they affect and are affected by the financial circumstances and objectives
of the client. Clients purchasing this service receive a written report designed to assist them in pursuing
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
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costs.
We gather required information through in-depth personal interviews and questionnaires. Information
gathered includes the client's current financial status, tax status, future goals, return objectives and
attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire
completed by the client, prepare a written report, and present a plan, typically within six months of the
contract date, provided that all information needed to prepare the financial plan has been promptly
provided.
Implementation of financial plan recommendations is entirely at the client's discretion. 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, stockbroker, and/or other professional advisers as
appropriate. We also provide general non-securities advice on topics that may include tax and budgetary
planning, estate planning, education planning, and business planning.
Our 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.
OTHER ADVISORY SERVICES – MANAGEMENT OF HELD-AWAY ACCOUNTS
We provide an additional service for accounts not held directly with preferred custodians, by leveraging
an Order Management System to help implement our investment recommendations on behalf of the
client. These are primarily 401(k) accounts, HSAs, and other assets we do not custody. We regularly
review the available investment options in these accounts, monitor them, and rebalance and implement
our strategies in a manner similar to the way we manage other types of accounts, though using different
tools, as necessary.
To provide this service, we use an Order Management System made available by Pontera Solutions, Inc.
(“Pontera”). Through Pontera, we are able to view the account and make allocation changes among the
investment options available in the plan. Our authority through Pontera is limited to managing the
investment selections and allocations within the account. We do not have the ability, and will not seek
or accept authority, to view or change beneficiaries, update contribution levels, update contact
information, or process withdrawals, loans, or distributions from these held-away accounts; these
actions remain the responsibility of the client and the plan provider.
The Order Management System allows us to assist with managing these client accounts without having
to obtain and maintain a client’s login credentials. Clients using the Order Management System will
receive a link allowing them to connect their account(s) to the platform. Once a client account is
connected to the Order Management System, we will monitor and rebalance or reallocate investments
in that account in the same way as we do for other (non-held away) accounts, though using different
tools. When clients engage us in this capacity, they are responsible to keep the Pontera platform link
active, so that we will be able to access and manage the respective account without delay. If we
determine that an Order Management System link has become inactive, we will use reasonable efforts
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to notify the client to resolve the issue. However, clients may remain subject to our fees described in
Item 5 even when we are not able to execute trades because of an inactive link.
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, 2025, we manage a total of $687,372,472 in assets under
management; with $392,526,364 under discretionary management and $294,846,108 under non-
discretionary management.
Item 5 Fees and Compensation
INVESTMENT PORTFOLIO SERVICES & INVESTMENT MODEL PORTFOLIO MANAGEMENT FEES
Our annual fees for Investment Portfolio Services and Investment Model Portfolio Management
(Investment Management Services) are based upon a percentage of assets under management and
generally range from 0.5% to 2.0%, depending on the size and type of account and the services provided.
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 client's
personal situation, we will provide an estimate for the total hours at the start of the advisory
relationship.
The client is billed in arrears based on actual hours accrued.
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
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balance is due upon completion of the plan.
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.
FEES FOR HELD-AWAY ASSETS MANAGED VIA PONTERA
The advisory fee rates for held-away accounts that we manage through Pontera may vary from other
managed accounts by our firm and will be detailed specifically in the supplemental or exhibit documents
for this service.
Advisory fees for these held-away accounts are calculated and billed to clients in the same manner as
our other advisory fees (for example, quarterly, in arrears), as described above.
For held-away accounts managed through Pontera, neither Pontera nor the plan custodian typically
offers us the ability to deduct fees directly from the held-away account. The fee payable for any
held-away account will therefore be deducted directly from another non-qualified account that we
manage for the client (such as an account held at Fidelity, Schwab, or Altruist), or, if agreed with the
client, billed directly to the client (for example, via ACH from a personal checking account). In the event
that a client’s account has insufficient funds or we and the client agree, the fees will be billed directly to
the client.
GENERAL INFORMATION ABOUT FEES & COMPENSATION
Additional Compensation
Some investment advisor representatives of our firm are licensed as insurance agents. In their separate
capacity, these individuals are able to implement insurance recommendations for advisory clients for
separate and typical compensation. This presents a conflict of interest to the extent that these
individuals recommend an insurance product 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.
Commune Capital, LLC
For certain private funds sponsored and managed by Commune Capital, LLC (“Commune Capital”),
Alliance has an agreement with Commune Capital under which Alliance assesses its investment advisory
fee directly to Commune Capital. Commune Capital satisfies this obligation using the management fees
it receives from the investment funds it sponsors and manages. Investors in those funds do not bear any
additional fees or expenses due to this arrangement other than those previously disclosed in the
relevant fund offering documents and governing agreements.
Certain investments recommended by Alliance Advisory & Securities, LLC, may be illiquid and require
ongoing communication, education and service with the client. In the event a client terminates
advisory services, Alliance Advisory & Securities, LLC, will cease providing investment management
services with respect to liquid assets as of the termination date.
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However, with respect to any remaining illiquid investments that cannot be readily liquidated, Alliance
Advisory & Securities, LLC, may continue to provide limited administrative or servicing support until
such investments are liquidated or transferred. To the extent Alliance Advisory & Securities, LLC,
receives compensation from Commune Capital, LLC, related to those investments, such compensation
will continue to be billed by Alliance Advisory & Securities, LLC, to Commune Capital, LLC.
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 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. See Item
12 – Brokerage Practices for additional details.
Mutual Fund Fees
All fees paid to Alliance Advisory & Securities, LLC for investment advisory services are separate from
the internal fees and expenses charged by mutual funds and ETFs to their shareholders (including
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management fees and, in some cases, distribution or “12b-1” fees). These fees and expenses are
described in each fund’s prospectus and will reduce the fund’s returns to investors. In no case does
Alliance Advisory & Securities, LLC receive additional revenue from any of the internal fees or 12b-1
fees specific to each individual fund. We may recommend mutual funds and exchange-traded funds
(ETFs) for client accounts. Some of the funds and share classes that are recommended may or may not
be available to an investor on their own without an Investment Advisor. Clients should review both the
fund expenses and our advisory fees to understand the total cost of their relationship with us.
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; any such arrangements and related fees will be
disclosed in the client’s advisory agreement.
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
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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 described in Item 5 – Fees and Compensation, our firm has established certain initial minimum
account requirements, based on the nature of the service(s) being provided. Requirements for opening
and maintaining an account, such as minimum account size, are discussed under Item 5- Fees and
Compensation and in the applicable service agreements.
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, equities, 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).
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.
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Quantitative Analysis
We may 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 may 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 assess
potential 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 may 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 may 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
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.
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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:
Core Model Portfolios
We manage many client accounts using diversified “Core” model portfolios constructed primarily with
mutual funds and/or exchange-traded funds (ETFs). These models are designed along a risk spectrum
(for example, Conservative, Balanced Income, Growth & Income, Balanced Growth, and Growth) and
are based on our asset allocation views and the methods of analysis described above. Core models
generally use actively managed funds rather than purely passive index funds. The goal is to provide
diversified exposure to major asset classes in a way we believe is appropriate for a client’s investment
objectives, risk tolerance, and time horizon.
Core Defensive Portfolios
Core Defensive portfolios use the same general allocation framework as our Core models but are
designed for clients who anticipate regular withdrawals. These portfolios typically maintain an elevated
cash or cash-equivalent position (often targeting approximately 12–18 months of anticipated liquidity
needs) to help fund distributions without having to sell other investments during unfavorable market
conditions. Interest, dividends, and capital gains are generally directed to the cash position. This
approach may result in different performance compared with similar non-defensive models due to the
higher cash allocation.
Values-Based Portfolios
We offer values-based model portfolios, including faith-based and biblically responsible investing
options, for clients who wish to align their investments with certain values in addition to their financial
objectives. We currently offer a series of these models ranging from more conservative to more
growth-oriented so that a client’s risk tolerance can be aligned with the client’s stated values. To the
extent that it is practical and possible, theses portfolios generally use mutual funds and/or
exchange-traded funds whose managers apply values-based screening criteria and a research process
that seeks to invest in companies creating value for the global common good and to avoid companies
whose products or practices are viewed as harmful to people or the environment. This may include
avoiding exposure to areas such as abortion-related products or services, alcohol, pornography and
explicit content, gambling, tobacco and recreational cannabis, certain controversial weapons, and other
activities considered inconsistent with the client’s stated values, while emphasizing companies that
demonstrate respect for human dignity, family and community, responsible corporate conduct, and
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environmental stewardship. The client’s election to use a values-based or faith-based model, and any
specific values-related preferences or limitations, will be documented as part of our onboarding or
review process. Because of these additional constraints, these portfolios may be less diversified than,
and may perform differently from, similar portfolios that do not apply such screens, and their
performance may deviate, potentially significantly, from broad market indices.
Dimensional Model Portfolios
We also offer model portfolios built primarily with funds managed by Dimensional Fund Advisors
(“Dimensional”). These models (for example, Income, Conservative Income & Growth, Moderate Income
& Growth, Growth & Income, Growth, Aggressive Growth, and AFG Extended Equity) use a long-term,
strategic allocation approach and are implemented using broadly diversified, factor-tilted, passively
managed funds with relatively low internal costs. Dimensional model portfolios are designed to provide
broad market exposure with an emphasis on certain risk/return characteristics such as size, value, and
profitability factors.
Dimensional Socially Responsible Portfolios
Our Dimensional Socially Responsible model portfolios use Dimensional funds that incorporate certain
environmental, social, or governance (“ESG”) considerations and/or other socially responsible criteria
into their investment processes. These models seek to provide diversified exposure similar to other
Dimensional models while taking into account sustainable or responsible investing considerations. There
is no guarantee that these portfolios will achieve better performance, and their results may differ from
portfolios that do not apply these criteria.
Individual Securities Strategies (U.S. Large Cap Equity / Municipal Income)
For certain strategies, such as our U.S. Large Cap Equity (AFG 50) and Municipal Income portfolios, we
invest directly in individual securities instead of, or in addition to, funds. These strategies use proprietary
models and external research to evaluate macro- and micro-economic indicators and company-specific
valuation metrics, and trades are made on an as-needed basis rather than according to a fixed schedule.
For Municipal Income, we typically focus on generating tax-efficient income through diversified holdings
of municipal bonds. For these strategies, interest, cash dividends, and capital gains distributions are
generally directed to the cash or money market position in the account.
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
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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 involves risk of loss that clients should be prepared to bear. All investment
programs we offer are subject to various types and degrees of market, interest rate, credit, liquidity, and
other risks, and there is no guarantee that any investment strategy will achieve its objectives or avoid
losses. We ask that clients work with us to help us understand their tolerance for risk so we can
recommend strategies we believe are appropriate.
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 licensed as insurance agents with various
insurance companies. As such, these individuals are able to receive separate, 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 (AFG). Alliance
Financial Group, Inc. or one or more of our related persons also act as general partner or manager of
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Commune Capital, LLC, (“Commune Capital”) 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.)
For certain private funds sponsored and managed by Commune Capital, Alliance Advisory & Securities,
LLC, has an agreement with Commune Capital under which Alliance Advisory & Securities, LLC, assesses
its investment advisory fee directly to Commune Capital. Commune Capital satisfies this obligation using
the management fees it receives from the investment funds it sponsors and manages. Investors in those
funds do not bear any additional fees or expenses due to this arrangement other than those disclosed
in the relevant fund offering documents and governing agreements.
Because AFG and Commune Capital are under common ownership or control with our firm, we have a
conflict of interest when we recommend that advisory clients invest in private funds or other operating
companies sponsored or managed by Commune Capital or its affiliates. We address this conflict through
our fiduciary duty to act in each client’s best interest by recommending such investments only when we
reasonably believe that they are suitable for and in the client’s best interest in light of the client’s
objectives, risk tolerance, liquidity needs, costs, and reasonably available alternatives; by providing
clients with the applicable private placement memorandum and offering documents, and by clearly
disclosing this affiliation and fee arrangement in this brochure and in the offering materials. Clients are
under no obligation to invest in any Commune-related fund or other affiliated offering.
Advisory clients of our firm may be 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 needs, and
overall suitability and in the client’s best interests. 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
investment adviser; we take the following steps to address this conflict:
as a registered
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;
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 and in the client’s best interest in light of 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;
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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.
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.com or 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
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”).
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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.
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:
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 policy of our firm that no principal or employee may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account. This prevents such
individuals 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.
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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 may 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 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
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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.
Custodians and Brokerage Platforms (Fidelity Investments, Charles Schwab, National Advisors Trust
Company, and Altruist
Alliance Advisory & Securities, LLC does not have any soft-dollar arrangements. We do not receive
research or other “soft dollar” benefits that fall within Section 28(e); however, we do receive technology,
custody, and other platform services as described below.
Alliance Advisory & Securities, LLC has arrangements with Fidelity Investments, Charles Schwab
Institutional, National Advisors Trust Company, and Altruist Financial, LLC, (together, with all affiliates,
“Fidelity,” "Schwab," “NATC,,” and “Altruist”) through which these firms 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, Schwab, NATC, and Altruist charge brokerage commissions and transaction fees for effecting
certain securities transactions (i.e., transactions fees may be charged for certain no-load mutual funds,
commissions may be charged for individual equity and debt securities transactions), while making other
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trades or funds available with reduced or no transaction charges Their commission and transaction-fee
rates are generally considered competitive with customary retail commission rates; however, the
commissions and transaction fees charged by Fidelity, Schwab, NATC, or Altruist 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, and comparable custodial and technology tools from NATC and Altruist,
which we use to manage client accounts, generate and allocated trade orders, and produce reports.
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 these potential conflicts 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, Schwab, and Altruist
are not affiliated.
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 periodic written reports (typically 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
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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;
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. Client
assets are maintained at qualified custodians in accounts held in the client’s name. For any private
offering a client may choose to make, those assets are held in the name of the offering and under the
control of the manager or general partner (which is not Alliance Advisory & Securities, LLC). In addition
to the periodic account statements that clients receive directly from their qualified custodians, we may
also send account statements directly to our clients on a quarterly basis, depending on their investment
advisory service. We urge our clients to carefully compare the information provided on the account
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statements that we send with the account statements they receive from their custodian 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.
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.aewealth.com
April 29, 2026
This Brochure Supplement provides information about your financial representative that supplements
the Alliance Advisory & Securities, LLC’s (dba Alliance Entrust) Brochure. You should have received a
copy of that Brochure. Please contact our service department at 805-371-8020 or at the email address
above if you did not receive Alliance Advisory & Securities, LLC’s Brochure or if you have any questions
about the contents of this Brochure Supplement.
Additional information about the financial representatives listed in this brochure is available on the SEC’s
website at https://adviserinfo.sec.gov/.
Rev. 04/29/26
Alliance Advisory & Securities, LLC (Firm Brochure)
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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® certification, granted by Certified Financial Planner
Board of Standards, Inc. (CFP Board), is for advisers who demonstrate competence in
comprehensive financial planning and agree to act as fiduciaries when providing financial advice.
To earn and maintain the CFP® mark, candidates must complete a CFP Board-approved education
program, pass a comprehensive exam, satisfy an experience and ethics requirement, and
complete 30 hours of continuing education every two years.
Chartered Retirement Planning Counselor (CRPC®) – The CRPC® designation, awarded by the College
for Financial Planning, is for professionals specializing in retirement planning, including pre- and
post-retirement income, asset management, and related planning issues. Candidates must
complete a retirement-focused course of study, pass a proctored exam, and renew the
designation every two years through required continuing education.
Certified Kingdom Advisor (CKA®) – The CKA® designation, offered by Kingdom Advisors, is for
financial professionals who integrate biblical principles with financial advice. Candidates must
complete the CKA® education program, pass a certification exam, meet credential or experience
standards, sign a Statement of Faith and stewardship commitment, provide references, and
complete ongoing annual continuing education.
Investment Adviser Certified Compliance Professional (IACCP®) – The
IACCP® designation,
co-sponsored by COMPLY and the Investment Adviser Association, recognizes compliance
professionals with training in investment adviser regulatory obligations. Candidates must
complete a prescribed curriculum, have investment adviser compliance experience, pass a
certifying exam, meet ethics requirements, and complete annual continuing education to
maintain the credential.
Certified Anti-Money Laundering Specialist (CAMS®) – CAMS
is an anti-money-laundering
certification administered by the Association of Certified Anti-Money Laundering Specialists
(ACAMS). Candidates must meet eligibility and experience criteria, pass the CAMS exam covering
money-laundering risks, regulations, and AML/CTF practices, and renew the certification every
three years through ACAMS membership and required continuing education.
Certified Fraud Examiner (CFE®) – The CFE credential, awarded by the Association of Certified Fraud
Examiners (ACFE), recognizes professionals with expertise in fraud prevention, detection, and
investigation. Candidates must meet membership, education, and experience requirements,
pass the CFE exam, and maintain the credential through annual continuing professional
education and adherence to the ACFE Code of Professional Ethics.
28
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
Business Background
Alliance Entrust: 2023 – present
- President
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.
29
Sandi L. Bublitz, CFP®
Year of Birth
1956
Education
University of California, Santa Barbara, B.A., Communications
Credentials & Licenses
Certified Financial Planner (CFP®)
Investment Advisor Representative
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.
30
Crystal A. Lary
Year of Birth
o 1984
Education
o College of the Canyons - General Education
Credentials & Licenses
o
Investment Advisor Representative
Business Background
o Alliance Advisory & Securities, LLC: 2023 – present
- Paraplanner / Investment Advisor Representative
o David S. Reinders, Inc.: 2004-2023
- Executive Administrative Assistant
Disciplinary Information
o None
Other Business Activities
o None
Additional Compensation
o n/a
Supervision
Crystal Lary’s advisory activities are supervised by the Compliance Department of Alliance
Advisory & Securities, LLC. The trades of Ms. Lary’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. Lary’s
advisory activities.
31
Patrick K. McIlrath, MBA, CRPC®
Year of Birth
1951
Education
United State Naval Academy, B.Sc., Oceanography
Wharton School of Finance, University of Pennsylvania, MBA, Strategic Planning & General
Management
Credentials & Licenses
Chartered Retirement Planning Consultant (CRPC®)
Investment Advisor Representative
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.
32
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
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.
33
Jon Rehurek, CFP®, CKA®, ThM
Year of Birth
1971
Education
Southwest Baptist University, B.S. Business Administration, Finance & 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
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.
34
Ben Simonds, CFP®, CKA®
Year of Birth
1987
Education
The Master’s University, B.S., Finance & Management
Credentials & Licenses
Certified Financial Planner (CFP®)
Certified Kingdom Advisor (CKA®)
Investment Advisor Representative
Business Background
Alliance Advisory & Securities, LLC: 2011 – present
-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.
35
Robert Knight, CRPC®, MBA
Year of Birth
1975
Education
California Lutheran University, Master’s in Financial Planning
California State University Northridge, B.S., Finance
Credentials & Licenses
Chartered Retirement Planning Counselor (CRPC®)
Investment Advisor Representative
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.
36
Vance Lavizzo, CFP®
Year of Birth
1986
Education
Western Governors University, B.S., Business Administration
Credentials & Licenses
Certified Financial Planner (CFP®)
Investment Advisor Representative
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.
37
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
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.
38
Emily Swan, CFP®
Year of Birth
1978
Education
Boston University, B.S., Communication
Credentials & Licenses
Certified Financial Planner (CFP®)
Investment Advisor Representative
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
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.
39
Jeff Garagliano
Year of Birth
1975
Education
Colorado State University, B.A., Economics
Credentials & Licenses
Investment Advisor Representative
Business Background
Alliance Advisory & Securities, LLC: 1998 – present
- Investment Advisor Representative
- Operations
- 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.
40
Sean Nicholas Sottile, DBA
Year of Birth
1986
Education
Life Pacific University, B.A., Biblical Studies
Azusa Pacific University, M.A, Organizational Leadership
Grand Canyon University, Doctor of Business Administration
Credentials & Licenses
Investment Advisor Representative
Business Background
Alliance Advisory & Securities, LLC: 2024 – present
- Vice President
Life Pacific University: 2021-2026
- 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.
41
Liza M. Dela Cruz, CAMS®, CFE®, IACCP®
Year of Birth
1975
Education
Pepperdine University, B.Sc., Management
Pepperdine University, MBA, Finance
Pepperdine University School of Law, Certificate in Dispute Resolution
Credentials & Licenses
Investment Advisor Representative
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.
42