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Item 1 - Cover Page
Allred Capital Management, LLC
DBA
Allred Harris Wealth Management
CRD# 297533
8333 Douglas Avenue - Suite 525
Dallas, Texas 75225
Toll Free: 844-965-7695
214-965-7695
April 24, 2025
This brochure ("Brochure") provides information about the qualifications and business practices of
Allred Capital Management, LLC D/B/A Allred Harris Wealth Management (the "Adviser"). If you have
any questions about the contents of this Brochure, please contact the Adviser at 844-965-7695 or
Jon@AllredHarris.com. The information in this Brochure has not been approved or verified by the
United States Securities and Exchange Commission (the "SEC") or by any state authority.
Additional information about the Adviser also is available on the SEC's website at
www.AdviserInfo.sec.gov.
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Item 2 Material Changes
This Brochure is a document which the Adviser provides to its clients as required by the SEC’s rules.
The purpose of Item 2 of the Brochure is to provide clients with a summary of new and/or updated
information that is contained in the remainder of the Brochure.
Since the filing of our last annual updating amendment, dated March 19, 2024, we have no material
changes to report.
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Item 3 Table Of Contents
Item 2 Material Changes .............................................................................................................. 2
Item 3 Table Of Contents ............................................................................................................. 3
Item 4 Advisory Business ............................................................................................................. 4
Item 5 Fees and Compensation ................................................................................................... 6
Item 6 Performance-Based Fees and Side-By-Side Management ............................................... 8
Item 7 Types of Clients ................................................................................................................ 8
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 8
Item 9 Disciplinary Information ................................................................................................... 11
Item 10 Other Financial Industry Activities and Affiliations ......................................................... 11
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ... 11
Item 12 Brokerage Practices ...................................................................................................... 12
Item 13 Review of Accounts ....................................................................................................... 14
Item 14 Client Referrals and Other Compensation ..................................................................... 15
Item 15 Custody ......................................................................................................................... 15
Item 16 Investment Discretion .................................................................................................... 15
Item 17 Voting Client Securities ................................................................................................. 15
Item 18 Financial Information ..................................................................................................... 16
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Item 4 Advisory Business
General Information
Allred Capital Management, LLC, a Texas limited liability company, was formed in May 2018. The
Adviser does business under the D/B/A name of Allred Harris Wealth Management.
Advisory Services
The Adviser provides portfolio management and financial planning services ("Goal Planning and
Monitoring Services") to individuals, trusts, foundations, endowments and corporate entities.
At the outset of each client relationship, the Adviser spends time with the client asking questions,
discussing the client's investment experience and financial circumstances, and broadly identifying
major goals of the client. Based on its review of the information provided by the client, the Adviser
generally develops with each client:
• a financial outline for the client based on the client's financial circumstances, goals and risk
tolerance level (the "Financial Profile"); and
• the client's investment objectives and guidelines (the "Investment Plan").
The Financial Profile is a reflection of the client's current financial situation and a look to the future
goals of the client. The Investment Plan outlines the types of investments the Adviser will make on
behalf of the client based on the Adviser's own research and analysis in order to meet those goals. The
elements of the Financial Profile and the Investment Plan are discussed periodically with each client,
but are not necessarily written documents.
Portfolio Management
As described above, the Adviser will develop an Investment Plan with each portfolio management
client. The Investment Plan will be updated from time to time when requested by the client, or when
determined to be necessary or advisable by the Adviser based on updates to the client's financial or
other circumstances.
To implement the client's Investment Plan, the Adviser typically will manage the client's investment
portfolio on a discretionary basis pursuant to an investment advisory agreement with the Client. In
certain limited cases, the Adviser may manage the client's investment portfolio on a non-discretionary
basis. As a discretionary investment adviser, the Adviser will have the authority to supervise and direct
the portfolio without prior consultation with the client. Clients who choose a non-discretionary
arrangement must be contacted prior to the execution of any trade in the account(s) under
management. This may result in a delay in executing recommended trades, which could adversely
affect the performance of the portfolio. This delay also normally means the affected account(s) will not
be able to participate in block trades, a practice designed to enhance the execution quality, timing
and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains
the responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, clients may impose certain written restrictions on the Adviser in the
management of their investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in an
investment portfolio at the commencement of the relationship. Each client should note, however, that
restrictions imposed by a client may adversely affect the composition and performance of the client's
investment portfolio. Each client should also note that his or her investment portfolio is treated
individually by giving consideration to each purchase or sale for the client's account. For these and
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other reasons, performance of client investment portfolios within the same investment objectives, goals
and/or risk tolerance may differ and clients should not expect that the composition or performance of
their investment portfolios would necessarily be consistent with similar clients of the Adviser.
The Adviser provides portfolio management services through three different platforms offered by
Raymond James Financial Services, Inc. ("Raymond James"): (1) the Investment Advisors Division
platform ("IAD"); (2) the Asset Management Services platform ("AMS"); and (3) the Raymond James
Consulting Services platform ("RJCS").
Separate Account Managers
For AMS and RJCS accounts, the Adviser may recommend or select one or more Separate Account
Managers (each, a "Manager") for a particular client. The Adviser's access to various Managers allows
the Adviser to offer a wide variety of manager styles, and provides the opportunity to utilize more than
one Manager. Factors that the Adviser considers in recommending/selecting Managers generally
include the client's stated investment objective(s), management style, performance, risk level,
reputation, financial strength, reporting, pricing, and research.
The Manager(s) generally will be granted discretionary trading authority to provide investment
supervisory services for the portfolio. In most cases, the Adviser retains the authority to terminate the
Manager's relationship or to add new Managers without specific client consent. In other cases, the
client will ultimately select one or more Managers recommended by the Adviser.
The Adviser will monitor the investment approach and performance of the Manager(s).
Goal Planning and Monitoring Services
The Adviser also offers Goal Planning and Monitoring Services coupled with ongoing portfolio
management or, in certain cases, as a stand-alone service.
The Adviser's Goal Planning and Monitoring Services may include advice that addresses one or more
areas of a client's financial situation, such as estate planning, risk management, budgeting and cash
flow controls, retirement planning, education funding, and investment portfolio design and ongoing
management. Depending on a client's particular situation, Goal Planning and Monitoring Services may
include some or all of the following:
• Gathering factual information concerning the client's personal and financial situation;
• Assisting the client in establishing financial goals and objectives;
• Analyzing the client's present situation and anticipated future activities in light of the client's
financial goals and objectives;
• Identifying problems foreseen in the accomplishment of these financial goals and objectives
and offering alternative solutions to the problems;
• Making recommendations to help achieve retirement plan goals and objectives;
• Designing an investment portfolio to help meet the goals and objectives of the client;
• Providing estate planning;
• Assessing risk and reviewing basic health, life and disability insurance needs; or
• Reviewing goals and objectives and measuring progress toward these goals.
When a full financial plan is prepared, the client may choose to have the Adviser implement the client's
financial plan and manage the investment portfolio on an ongoing basis. However, the client is under
no obligation to act upon any of the recommendations made by the Adviser under a financial planning
engagement and/or engage the services of any recommended professional.
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Principal Owner
Jonathan L. Allred is the sole owner of the Adviser.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
Type and Value of Assets Currently Managed
As of December 31, 2024, we provide continuous management services for $440,380,079 in client
assets on a discretionary basis, and $12,069,848 in client assets on a non-discretionary basis.
Item 5 Fees and Compensation
General Fee Information
Clients enter into one of two fee arrangements. For most discretionary portfolio management services,
clients participate in a Wrap Fee Program ("Wrap Program"). The Wrap Program fee structure includes
the brokerage expenses (e.g., commissions, ticket charges, etc.) of the account, charges for custody
services, the management fee paid to the Adviser and the fees of any Managers. Under the all-
inclusive billing arrangement, the Adviser will assess one client fee that captures the management,
brokerage, custody and administrative portions collectively. Any portion of Wrap Program fees that the
Adviser does not pay to third parties in connection with transaction and execution expenses and/or to
Managers is retained by the Adviser. Because of this, the Adviser may have a disincentive to trade
securities in client accounts. For IAD accounts, the Wrap Program is sponsored by the Adviser, and for
AMS and RJCS accounts, the Wrap Program is sponsored by Raymond James. The Adviser does not
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have a minimum portfolio asset value size requirement for IAD accounts, but, in its discretion, may
establish one in the future. There are minimum portfolio asset value size requirements for AMS and
RJCS accounts, which are established by Raymond James in its sole discretion from time to time.
For certain discretionary portfolio management services with respect to IAD accounts and for all non-
discretionary portfolio management services, clients will pay management fees to the Adviser
separately from the brokerage expenses and transaction costs of the account. The brokerage
expenses may take the form of asset-based pricing, meaning that the broker-dealer charges the
account a flat-rate percentage to cover all brokerage expenses, or these expenses may be assessed
on a per-trade basis. Please see Item 12 - Brokerage Practices for additional information.
In either of these arrangements, the fees noted above are separate and distinct from the internal fees
and expenses charged by mutual funds, exchange-traded funds ("ETFs") or other investment pools to
their shareholders (generally including a management fee and fund expenses, as described in each
fund's prospectus or offering materials), mark-ups and mark-downs, spreads paid to market makers,
fees for trades executed away from the custodian, wire transfer fees and other fees and taxes on
brokerage accounts and securities transactions. The client should review all fees charged by funds,
brokers, the Adviser and others to fully understand the total amount of fees paid by the client for
investment and financial-related services.
Portfolio Management Fees
Portfolio management fees are individually negotiated with each client, are based on a percentage of
assets under management, and are generally subject to the following maximum fees, based on the
account type:
Account Type
IAD
AMS
RJCS
Fee Rate
1.50%
1.75%
1.75%
Factors considered in determining the fees charged generally include, but are not limited to: the
complexity of the client's portfolio; assets to be placed under management; anticipated future assets;
related accounts; portfolio style; account composition; or other special circumstances or requirements.
The specific fee schedule will be identified in the investment advisory agreement between the client
and the Adviser. The Adviser may, at its discretion, make exceptions to the foregoing or negotiate
special fee arrangements where the Adviser deems it appropriate under the circumstances.
Portfolio management fees are generally payable quarterly, in advance, based on the value of the
managed portfolio on the last business day of the previous calendar quarter. If management begins
after the start of a quarter, fees will be prorated accordingly. Fees are normally debited directly from
client account(s), unless other arrangements are made.
Either the Adviser or the client may terminate their investment advisory agreement at any time, subject
to any written notice requirements in the investment advisory agreement. In the event of termination,
any paid but unearned fees will be promptly refunded to the client based on the number of days that
the account was managed, and any fees due to the Adviser from the client will be invoiced or deducted
from the client's account prior to termination.
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Separate Account Manager Fees
When one or more Managers are utilized, the Manager(s)' fees will be included in the Adviser's fee
charged to the client account (typically, through a Wrap Program).
Wrap Program Fees
Fees for clients participating in a Wrap Program are charged in accordance with the annual fees
described above. With respect to clients participating in a Wrap Program, the Adviser generally
receives the total fee charged less: (1) the fees charged by any Manager(s); and (2) the amounts paid
by the Adviser for all transaction and execution expenses.
Goal Planning and Monitoring Services Fees
When the Adviser provides Goal Planning and Monitoring Services to a client, these fees may be
included in the portfolio management fees or may be in the form of an hourly rate or fixed fee that is
negotiated at the time of the engagement and are normally based on the scope of the engagement.
Item 6 Performance-Based Fees and Side-By-Side Management
The Adviser currently does not have any performance-based fee arrangements. "Side by Side
Management" refers to a situation in which the same firm manages accounts that are billed based on a
percentage of assets under management and at the same time manages other accounts for which fees
are assessed on a performance fee basis. Because the Adviser has no performance-based fee
accounts, it has no side-by-side management.
Item 7 Types of Clients
The Adviser serves individuals, trusts, foundations, endowments, and corporate entities.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
The Adviser reviews each client's Investment Plan and develops a customized investment strategy for
each client. The primary vehicles for investment used by the Adviser are common stock, fixed income
securities, mutual funds, ETFs and separately-managed accounts ("SMAs"). In selecting investments
for an individual account in accordance with the client's Investment Plan, the Adviser generally
considers third-party research and applies traditional fundamental analysis including, without limitation,
the following factors:
• Financial strength ratios;
• Price-to-earnings ratios;
• Dividend yields; and
• Growth rate-to-price earnings ratios
The Adviser may incorporate other methods of analysis, such as:
Charting Analysis - involves gathering and processing price and volume information for a particular
security and may include, without limitation:
• mathematical analysis;
• graphing charts; and
• estimations of future price movements based on perceived patterns and trends.
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Technical Analysis - involves studying past price patterns and trends in the financial markets to predict
the direction of both the overall market and specific stocks.
Cyclical Analysis - involves evaluating recurring price patterns and trends.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors, including,
as applicable and without limitation, past performance, consistency of performance, fee structure,
portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill liquidity or
income needs in a portfolio, or to add a component of capital preservation. The Adviser may evaluate
and select individual bonds or bond funds based on a number of factors including, without limitation,
rating, yield and duration.
Investment Strategies
The Adviser's strategic approach is to invest each portfolio in accordance with the Investment Plan that
has been developed specifically for each client. This means that the following strategies may be used
in varying combinations over time for a given client, depending upon the client's individual
circumstances:
Long Term Purchases - securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year.
Short Term Purchases - securities purchased with the expectation that they will be sold within a
relatively short period of time, generally less than one year, to take advantage of the securities' short
term price fluctuations.
Margin Transactions (in limited circumstances) - a securities transaction in which an investor borrows
money to purchase a security, in which case the security serves as collateral on the loan.
Trading - generally considered holding a security for less than thirty (30) days.
Options Trading/Writing - a securities transaction that involves buying or selling (writing) an option. If
you write an option, and the buyer exercises the option, you are obligated to purchase or deliver a
specified number of shares at a specified price at the exercise of the option regardless of the market
value of the security at expiration of the option. Buying an option gives you the right to purchase or sell
a specified number of shares at a specified price until the date of expiration of the option regardless of
the market value of the security at expiration of the option.
Risk of Loss
While the Adviser seeks to diversify clients' investment portfolios across various asset classes in an
effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no
assurance that client investment portfolios will be able to fully meet their investment objectives and
goals, or that investments will not lose money.
Below is a description of several of the principal risks that client investment portfolios face.
Management Risks. While the Adviser manages client investment portfolios or selects one or more
Managers based on the Adviser's experience, research and proprietary methods, the value of client
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investment portfolios will change daily based on the performance of the underlying securities in which
they are invested. Accordingly, client investment portfolios are subject to the risk that the Adviser or a
Manager allocates assets to asset classes that are adversely affected by unanticipated market
movements, and the risk that the Adviser's or a Manager's specific investment choices could
underperform their relevant indexes.
Economic Conditions. Changes in economic conditions, including, for example, interest rates, inflation
rates, employment conditions, competition, technological developments, political and diplomatic events
and trends, and tax laws may adversely affect the business prospects or perceived prospects of
companies. While the Adviser or a Manager performs due diligence on the companies in whose
securities it invests, economic conditions are not within the control of the Adviser or the Manager and
no assurances can be given that the Adviser or the Manager will anticipate adverse developments.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, the
Adviser and any Managers may invest client portfolios in mutual funds, ETFs and other investment
pools ("pooled investment funds"). Investments in pooled investment funds are generally less risky
than investing in individual securities because of their diversified portfolios; however, these
investments are still subject to risks associated with the markets in which they invest. In addition,
pooled investment funds' success will be related to the skills of their particular managers and their
performance in managing their funds. Pooled investment funds are also subject to risks due to
regulatory restrictions applicable to registered investment companies under the Investment Company
Act of 1940, as amended.
Risks Related to Alternative Investment Vehicles. From time to time and as appropriate, the Adviser
and any Managers may invest a portion of a client's portfolio in alternative vehicles. The value of client
portfolios will be based in part on the value of alternative investment vehicles in which they are
invested, the success of each of which will depend heavily upon the efforts of their respective
managers. When the investment objectives and strategies of a manager are out of favor in the market
or a manager makes unsuccessful investment decisions, the alternative investment vehicles managed
by the manager may lose money. A client account may lose a substantial percentage of its value if the
investment objectives and strategies of many or most of the alternative investment vehicles in which it
is invested are out of favor at the same time, or many or most of the managers make unsuccessful
investment decisions at the same time.
Equity Market Risks. The Adviser and any Managers will generally invest portions of client assets
directly into equity investments, primarily stocks, or into pooled investment funds that invest in the
stock market. As noted above, while pooled investment funds have diversified portfolios that may make
them less risky than investments in individual securities, pooled investment funds that invest in stocks
and other equity securities are nevertheless subject to the risks of the stock market. These risks
include, without limitation, the risks that stock values will decline due to daily fluctuations in the
markets, and that stock values will decline over longer periods (e.g., bear markets) due to general
market declines in the stock prices for all companies, regardless of any individual security's prospects.
Fixed Income Risks. The Adviser and any Managers may invest portions of client assets directly into
fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that
invest in bonds and notes. While investing in fixed income instruments, either directly or through
pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed
income investments nevertheless are subject to risks. These risks include, without limitation, interest
rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default
by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to
maturity).
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Foreign Securities Risks. The Adviser and any Managers may invest portions of client assets into
pooled investment funds that invest internationally. While foreign investments are important to the
diversification of client investment portfolios, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial reporting
or disclosure standards, practices or requirements comparable to those found in the United States.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency risk,
which is the risk that the value of the foreign security will decrease due to changes in the relative value
of the U.S. dollar and the security's underlying foreign currency.
Lack of Diversification. Client accounts may not have a diversified portfolio of investments at any given
time, and a substantial loss with respect to any particular investment in an undiversified portfolio will
have a substantial negative impact on the aggregate value of the portfolio.
Item 9 Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to a client's evaluation of the Adviser or the integrity of the
Adviser's management. The Adviser has no disciplinary events to report.
Item 10 Other Financial Industry Activities and Affiliations
Licensed Insurance Agents
Certain of the Firm's Supervised Persons are also licensed insurance agents and offer certain
insurance products on a fully-disclosed commissionable basis. A conflict of interest exists to the extent
that the Firm recommends the purchase of insurance products where its Supervised Persons are
entitled to insurance commissions or other additional compensation. the Firm has procedures in place
whereby it seeks to ensure that all recommendations are made in its clients’ best interest regardless of
any such affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics and Personal Trading
The Adviser has adopted a Code of Ethics ("the Code"), the full text of which is available to you upon
request. The Adviser's Code has several goals. First, the Code is designed to assist the Adviser in
complying with applicable laws and regulations governing its investment advisory business. Under the
Investment Advisers Act of 1940, as amended, the Adviser owes fiduciary duties to its clients.
Pursuant to these fiduciary duties, the Code requires Adviser associated persons to act with honesty,
good faith and fair dealing in working with clients. In addition, the Code prohibits associated persons
from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for the Adviser's associated persons
(managers, officers and employees). Under the Code's Professional Standards, the Adviser expects its
associated persons to put the interests of its clients first, ahead of personal interests. In this regard,
Adviser associated persons are not to take inappropriate advantage of their positions in relation to
Adviser clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading activities
of associated persons. From time to time the Adviser's associated persons may invest in the same
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securities recommended to clients. This may create a conflict of interest because associated persons
of the Adviser may invest in securities ahead of or to the exclusion of Adviser clients. Under its Code,
the Adviser has adopted procedures designed to reduce or eliminate conflicts of interest that this could
potentially cause. The Code's personal trading policies include procedures for limitations on personal
securities transactions of associated persons, including generally disallowing trading by an associated
person in any security within one day before any client account trades or considers trading the same
security and the creation of a restricted securities list, reporting and review of personal trading activities
and pre-clearance of certain types of personal trading activities. These policies are designed to
discourage and prohibit personal trading that would disadvantage clients. The Code also provides for
disciplinary action as appropriate for violations.
Participation or Interest in Client Transactions
As outlined above, the Adviser has adopted procedures to protect client interests when its associated
persons invest in the same securities as those selected for or recommended to clients. In the event of
any identified potential trading conflicts of interest, the Adviser's goal is to place client interests first.
Consistent with the foregoing, the Adviser maintains policies regarding participation in initial public
offerings ("IPOs") and private placements in order to comply with applicable laws and avoid conflicts
with client transactions. If an associated person wishes to participate in an IPO or invest in a private
placement, he/she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
If associated persons trade with client accounts (e.g., in a bundled or aggregated trade), and the trade
is not filled in its entirety, the associated person's shares will be removed from the block, and the
balance of shares will be allocated among client accounts in accordance with the Adviser's written
policy.
Item 12 Brokerage Practices
Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, the
Adviser seeks "best execution" for client trades, which is a combination of a number of factors,
including, without limitation, quality of execution, services provided and commission rates. Therefore,
the Adviser may use or recommend the use of brokers who do not charge the lowest available
commission in the recognition of research and securities transaction services, or quality of execution.
Research services received with transactions may include proprietary or third-party research (or any
combination), and may be used in servicing any or all of the Adviser's clients. Therefore, research
services received may not be used for the account for which the particular transaction was effected.
The Adviser may recommend that clients establish brokerage accounts with Raymond James, a
FINRA registered broker-dealer, member SIPC, to maintain custody of clients' assets. The Adviser
may effect trades for client accounts at Raymond James, or may in some instances, consistent with
the Adviser's duty of best execution and specific investment advisory agreement with each client, elect
to execute trades elsewhere. Although the Adviser may recommend that clients establish accounts at
Raymond James, it is ultimately the client's decision where to custody assets. The Adviser is
independently owned and operated and is not affiliated with Raymond James.
The Adviser participates in the Raymond James service program. While there is no direct link between
the investment advice the Adviser provides and participation in the Raymond James program, the
Adviser receives certain economic benefits from the Raymond James program. These benefits may
include software and other technology that provides access to client account data (such as trade
confirmations and account statements), facilitates trade execution (and allocation of aggregated orders
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for multiple client accounts), provides research, pricing information and other market data, facilitates
the payment of the Adviser's fees from its clients' accounts, and assists with back-office functions,
recordkeeping and client reporting. Many of these services may be used to service all or a substantial
number of the Adviser's accounts, including accounts not held at Raymond James. Raymond James
may also make available to the Adviser other services intended to help the Adviser manage and further
develop its business. These services may include consulting, publications and conferences on practice
management, information technology, business succession, regulatory compliance and marketing. In
addition, Raymond James may make available, arrange and/or pay for these types of services to be
rendered to the Adviser by independent third parties. Raymond James may discount or waive fees it
would otherwise charge for some of these services, pay all or a part of the fees of a third-party
providing these services to the Adviser, and/or Raymond James may pay for travel expenses relating
to participation in such training. Finally, participation in the Raymond James program provides the
Adviser with access to mutual funds which normally require significantly higher minimum initial
investments or are normally available only to institutional investors.
The benefits received through participation in the Raymond James program do not necessarily depend
upon the proportion of transactions directed to Raymond James. The benefits are received by the
Adviser, in part because of commission revenue generated for Raymond James by the Adviser's
clients. This means that the investment activity in client accounts is beneficial to the Adviser, because
Raymond James does not assess a fee to the Adviser for these services. This creates an incentive for
the Adviser to continue to recommend Raymond James to its clients. While it may be possible to
obtain similar custodial, execution and other services elsewhere at a lower cost, the Adviser believes
that Raymond James provides an excellent combination of these services. These services are not soft
dollar arrangements, but are part of the institutional platforms offered by Raymond James.
Directed Brokerage
Clients may direct the Adviser to use a particular broker for custodial or transaction services on behalf
of the client's portfolio. In directed brokerage arrangements, the client is responsible for negotiating the
commission rates and other fees to be paid to the broker. Accordingly, a client who directs brokerage
should consider whether such designation may result in certain costs or disadvantages to the client,
either because the client may pay higher commissions or obtain less favorable execution, or the
designation limits the investment options available to the client.
The arrangement that the Adviser has with Raymond James is designed to maximize efficiency and to
be cost effective. By directing brokerage arrangements, the client acknowledges that these economies
of scale and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that a client chooses to use the brokerage
and/or custodial services of these alternative service providers may in fact result in a certain degree of
delay in executing trades for their account(s) and otherwise adversely affect management of their
account(s).
By directing the Adviser to use a specific broker or dealer, clients who are subject to ERISA confirm
and agree with the Adviser that they have the authority to make the direction, that there are no
provisions in any client or plan document which are inconsistent with the direction, that the brokerage
and other goods and services provided by the broker or dealer through the brokerage transactions are
provided solely to and for the benefit of the client's plan, plan participants and their beneficiaries, that
the amount paid for the brokerage and other services have been determined by the client and the plan
to be reasonable, that any expenses paid by the broker on behalf of the plan are expenses that the
plan would otherwise be obligated to pay, and that the specific broker or dealer is not a party in interest
of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
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The Adviser may enter trades as a block where possible and when advantageous to clients whose
accounts have a need to buy or sell shares of the same security. This blocking of trades permits the
trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as
transaction costs are shared equally and on a pro-rata basis between all accounts included in any such
block. Block trading allows the Adviser to execute equity trades in a timelier, equitable manner, and
may reduce overall costs to clients.
The Adviser will only aggregate transactions when it believes that aggregation is consistent with its
duty to seek best execution (which includes the duty to seek best price) for its clients, and is consistent
with the terms of the Adviser's investment advisory agreement with each client for which trades are
being aggregated. No advisory client will be favored over any other client; each client that participates
in an aggregated order will participate at the average share price for all the Adviser's transactions in a
given security on a given business day, with transaction costs generally shared pro-rata based on each
client's participation in the transaction. On occasion, owing to the size of a particular account's pro rata
share of an order or other factors, the commission or transaction fee charged could be above or below
a breakpoint in a pre-determined commission or fee schedule set by the executing broker, and
therefore transaction charges may vary slightly among accounts. Accounts may be excluded from a
block due to tax considerations, client direction or other factors making the account's participation
ineligible or impractical.
The Adviser will prepare, before entering an aggregated order, a written statement ("Allocation
Statement") specifying the participating client accounts and how it intends to allocate the order among
those clients. If the aggregated order is filled in its entirety, it will be allocated among clients in
accordance with the Allocation Statement. If the order is partially filled, it will generally be allocated
pro-rata, based on the Allocation Statement, or randomly in certain circumstances. Notwithstanding the
foregoing, the order may be allocated on a basis different from that specified in the Allocation
Statement if all client accounts receive fair and equitable treatment over time, and the reason for
different allocation is explained in writing and is approved by an appropriate individual/officer of the
Adviser. The Adviser's books and records will separately reflect, for each client account included in a
block trade, the securities held by and bought and sold for that account. Funds and securities of clients
whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither
the clients' cash nor their securities will be held collectively any longer than is necessary to settle the
transaction on a delivery versus payment basis; cash or securities held collectively for clients will be
delivered out to the custodian bank or broker-dealer as soon as practicable following the settlement,
and the Adviser will receive no additional compensation or remuneration of any kind as a result of the
proposed aggregation.
Item 13 Review of Accounts
Managed portfolios are reviewed periodically but may be reviewed more often if requested by the
client, upon receipt of information material to the management of the portfolio, or at any time such
review is deemed necessary or advisable by the Adviser. One of the Adviser's investment adviser
representatives or principals is responsible for reviewing all accounts.
Account custodians are responsible for providing monthly or quarterly account statements which reflect
the positions (and current pricing) in each account as well as transactions in each account, including
fees paid from an account. Account custodians also provide prompt confirmation of all trading activity,
and year-end tax statements, such as 1099 forms. The Adviser will provide additional written reports
as needed or requested by the client. Clients should carefully compare the statements that they
receive from the Adviser against the statements that they receive from their account custodian(s).
For those clients to whom the Adviser provides separate Goal Planning and Monitoring Services,
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reviews are conducted on an as-needed or agreed-upon basis. Such reviews are conducted by one of
the Adviser's investment adviser representatives or principals.  
Item 14 Client Referrals and Other Compensation
As noted above, the Adviser may receive some benefits from Raymond James based on the amount of
client assets held at Raymond James. Please see Item 12 - Brokerage Practices for more
information. However, neither Raymond James nor any other party is paid to refer clients to the
Adviser.
Item 15 Custody
Raymond James is the custodian of nearly all client accounts at the Adviser. From time to time
however, clients may select an alternate broker to hold accounts in custody. In any case, it is the
custodian’s responsibility to provide clients with confirmations of trading activity, tax forms and at least
quarterly account statements. Clients are advised to review this information carefully, and to notify the
Adviser of any questions or concerns. Clients are also asked to promptly notify the Adviser if the
custodian fails to provide statements on each account held.
From time to time and in accordance with the Adviser’s investment advisory agreement with clients,
the Adviser will provide additional reports. As mentioned above, the account balances reflected on
these reports should be compared to the balances shown on the brokerage statements to ensure
accuracy. At times there may be small differences due to the timing of dividend reporting, pending
trades or other similar issues.
The Adviser may be deemed to have “soft” custody of its client accounts because the Adviser’s
portfolio management fees are normally debited directly from client account(s), unless other
arrangements are made.
Item 16 Investment Discretion
As described in Item 4 - Advisory Business, the Adviser will accept clients on either a discretionary
or non-discretionary basis. For discretionary accounts, a Limited Power of Attorney ("LPOA") is
executed by the client, giving the Adviser the authority to carry out various activities in the account,
generally including the following: (i) trade execution; (ii) the ability to request checks on behalf of the
client; and (iii) the withdrawal of advisory fees directly from the account. The Adviser then directs
investment of the client's portfolio using its discretionary authority. The client may limit the terms of the
LPOA to the extent consistent with the client's investment advisory agreement with the Adviser and the
requirements of the client's custodian.
For non-discretionary accounts, the client may also execute an LPOA, which allows the Adviser to
carry out trade recommendations and approved actions in the portfolio. However, in accordance with
the investment advisory agreement between the Adviser and the client, the Adviser does not
implement trading recommendations or other actions in the account unless and until the client has
approved the recommendation or action. As with discretionary accounts, clients may limit the terms of
the LPOA, subject to the Adviser's investment advisory agreement with the client and the requirements
of the client's custodian.
Item 17 Voting Client Securities
As a policy and in accordance with the Adviser's investment advisory agreement, the Adviser does not
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vote proxies related to securities held in client accounts unless the Adviser has previously agreed to do
so in writing with a particular client. The custodian of the account will normally provide proxy materials
directly to the client. Clients may contact the Adviser with questions relating to proxy procedures and
proposals; however, the Adviser generally does not research particular proxy proposals.
Item 18 Financial Information
The Adviser does not require nor solicit prepayment of more than $1,200 in fees per client, six months
or more in advance, and therefore has no disclosure with respect to this item.
Allred Capital Management, LLC, D/B/A Allred Harris Wealth Management, is required to disclose any
financial condition that is reasonably likely to impair our ability to meet our contractual commitments to
our clients. The Adviser does not have any financial conditions that are reasonably likely to impair our
ability to meet our contractual commitments to our clients.
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