Overview
- Headquarters
- Charlotte, NC
- Average Client Assets
- $3.2 million
- Minimum Account Size
- $750,000
- SEC CRD Number
- 122545
Fee Structure
Primary Fee Schedule (2025-6-27 ADV FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $3,000,000 | 0.50% |
| $3,000,001 | and above | 0.35% |
Minimum Annual Fee: $7,500
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $27,000 | 0.54% |
| $10 million | $44,500 | 0.44% |
| $50 million | $184,500 | 0.37% |
| $100 million | $359,500 | 0.36% |
Clients
- HNW Share of Firm Assets
- 92.81%
- Total Client Accounts
- 1,520
- Discretionary Accounts
- 1,515
- Non-Discretionary Accounts
- 5
Services Offered
Services: Financial Planning, Portfolio Management for Individuals
Regulatory Filings
Additional Brochure: 2025-6-27 ADV FIRM BROCHURE (2026-03-22)
View Document Text
Item 1: Cover Page
ALPHA FINANCIAL ADVISORS, LLC
11325 N Community House Rd, Suite 410
Charlotte, North Carolina 28277-0524
Phone: (704) 716-1100
Fax: (704) 716-1101
https://www.alphafa.com
ann.reilley@alphafa.com
Disclosure Brochure
(Part 2A of Form ADV)
This brochure provides information about the qualifications and business
practices of Alpha Financial Advisors, LLC (“Alpha Financial”). If you have any
questions about the contents of this brochure, please contact us at: (704) 716-
1100, or via e-mail at: ANN.REILLEY@ALPHAFA.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.
Alpha Financial is a Registered Investment Adviser. Registration of an
Investment Advisor does not imply any level of skill or training.
Additional information about Alpha Financial is available on the SEC’s website
www.adviserinfo.sec.gov. You may search this site by using a unique
identifying number, known as a CRD number. The CRD number for Alpha
Financial is 122545. The SEC’s web site also provides information about any
persons affiliated with Alpha Financial who are registered, or are required to be
registered, as Investment Adviser Representatives of Alpha Financial.
March 22, 2026
Alpha Financial Advisors, LLC
Item 2: Material Changes
Annual Update
The Material Changes section of this brochure will be updated annually or when
material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
None.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure,
please contact us by telephone at: (704) 716-1100 or by e-mail at:
ANN.REILLEY@ALPHAFA.COM.
Alpha Financial’s Chief Compliance Officer, Ann Reilley, remains available to
address any questions about this ADV Part 2A Brochure.
TOC 1
Alpha Financial Advisors, LLC
Item 3: Table of Contents
Item 1: Cover Page ......................................................................................................... i
Item 2: Material Changes .............................................................................................. 1
Item 3: Table of Contents ............................................................................................. 2
Item 4: Advisory Business ........................................................................................... 1
Item 5: Fees and Compensation .................................................................................. 9
Item 6: Performance-Based Fees ............................................................................... 11
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................. 12
Item 9: Disciplinary Information ................................................................................. 14
Item 10: Other Financial Industry Activities and Affiliations ................................... 14
Item 11: Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ......................................................................................................... 14
Item 12: Brokerage Practices ..................................................................................... 15
Item 13: Review of Accounts ...................................................................................... 17
Item 14: Client Referrals and Other Compensation.................................................. 17
Item 15: Custody ......................................................................................................... 18
Item 16: Investment Discretion .................................................................................. 19
Item 17: Voting Client Securities................................................................................ 19
Item 18: Financial Information ................................................................................... 19
Business Continuity Plan & Information Security .................................................... 21
TOC 2
Alpha Financial Advisors, LLC
Item 4: Advisory Business
Firm Description
Alpha Financial Advisors, LLC (“Alpha Financial”), founded in 2002, is a SEC-
registered investment adviser headquartered in Charlotte, North Carolina.
Alpha Financial provides personalized, confidential financial planning and
investment management to individuals, families, trusts, estates, and small
businesses. Advice is provided through consultation with the client and may
include: determination of financial objectives, identification of financial
problems, cash flow management, tax planning, insurance review, investment
management, education funding, retirement planning, and estate planning.
Investment advice is an integral part of financial planning. In addition, Alpha
Financial advises clients regarding cash flow, college planning, retirement
planning, tax planning and estate planning.
Alpha Financial may act as a custodian of client assets under certain
circumstances outlined in Item 15. However, the client typically maintains asset
control. Alpha Financial places trades for clients under a limited power of
attorney. Assets under the direct management of Alpha Financial are held
directly by independent custodian including Charles Schwab and Company
(”Schwab”), Nationwide Advisory Solutions, my529 Plan and American Funds
CollegeAmerica, in the client’s name.
The goals and objectives for each client are documented in our client
relationship management system. A written evaluation of each client's initial
situation is provided to the client, often in the form of an Investment Objective
Letter. Clients can impose reasonable restrictions on investing in certain
securities or types of securities.
We may recommend other professionals (e.g., lawyers, accountants, insurance
agents, real estate agents, etc.) at the request of the client. Other professionals
are engaged directly by the client on an as-needed basis even when
recommended by Alpha Financial. Conflicts of interest will be disclosed to the
client in the unlikely event they should occur and managed in the best interests
of the client.
The initial meeting, which may be by telephone, is free of charge and is
considered an exploratory interview to determine the extent to which financial
planning and investment management may be beneficial to the client.
- 1 -
Alpha Financial Advisors, LLC
Principal Owners
ANN REILLEY is Alpha Financial’s Managing Member, Chief Compliance
Officer, and 83% principal owner.
H. NICK BARRINGER, is a 10% Member owner.
TYLER W. WEAVER, is a 5% Member owner
VANESSA O. DANCZAK is a 2% Member owner
Types of Advisory Services
Alpha Financial provides ongoing investment advisory and financial planning
services. Advice is furnished to clients on financial planning matters not
involving securities, such as taxation issues, insurance and estate planning
services.
In performing its services, Alpha Financial is not required to verify any
information received from the client or from the client’s other professionals.
Each client is advised that it remains his/her responsibility to promptly notify
Alpha Financial when there is any change in his/her financial situation and/or
financial objectives for the purpose of reviewing, evaluating, or revising
previous recommendations and/or services.
As of December 31, 2025, Alpha Financial had $617,135,744 of assets under
management on a discretionary basis and $2,184,315 of assets under
management on a non-discretionary basis for a total $619,320,059.
Financial Planning and Investment Advisory Services
Financial Planning and Investment Advisory Services may include, but are not
limited to: ongoing discretionary investment management based on an agreed-
upon investment objective and asset allocation; a net worth statement; a cash
flow statement; strategic tax planning; a review of retirement plans including
recommendations; a review of insurance policies and recommendations for
changes; retirement planning scenarios; estate planning review and
recommendations; and education planning with funding recommendations.
Alpha Financial manages client investment assets on a discretionary basis in
order to integrate the financial plan and to provide ongoing in-depth advice.
The financial plan is based on realistic and measurable goals, which are set
along with objectives to reach the goals as defined. As goals and objectives
change over time, recommendations are made and implemented on an
ongoing basis.
Assets are invested primarily in no-load mutual funds and exchange-traded
funds, usually through discount brokers or fund companies. Fund companies
charge each fund shareholder an investment management fee that is disclosed
in the fund prospectus. Discount brokerages may charge a transaction fee for
the purchase of some funds.
- 2 -
Alpha Financial Advisors, LLC
The scope of work and fee for Investment Advisory Services is provided to the
client in writing in the form of an Investment Advisory Agreement prior to the
start of the relationship.
Use of Independent Managers and Separate Account Management
Alpha Financial may recommend that a client engage one or more unaffiliated
Independent Managers (“Independent Managers”) to manage a portion of their
investment portfolio, based on their needs and objectives. In such cases, the
client may be required to enter into an investment management agreement with
the Independent Manager, outlining the terms of service. Alpha Financial will
conduct initial and ongoing oversight and due diligence to ensure the
Independent Manager's strategy is aligned with the client’s investment
objectives and best interests. Additionally, Alpha Financial will assist in
developing recommendations and managing the ongoing client relationship.
Prior to entering into an agreement with an Independent Manager, the client
will be provided with the Independent Manager’s Form ADV 2A.
Termination of Agreement
Either the client or Alpha Financial can terminate the engagement at any time
by notifying the other party, in writing. Upon termination, Alpha’s Financial’s
earned but unpaid fees will be billed on a pro rata basis for the portion of the
quarter that services were provided prior to termination.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/
Implementation Services. To the extent requested by the client, Alpha
Financial will generally provide financial planning and related consulting
services regarding matters such as tax and estate planning, insurance, etc.
Alpha Financial will generally provide such consulting services inclusive of its
advisory fee set forth at Item 5 below (exceptions could occur based upon
assets under management, extraordinary matters, special projects, stand-
alone planning engagements, etc. for which Alpha Financial may charge a
separate or additional fee). Please Note. Alpha Financial believes that it is
important for the client to address financial planning issues on an ongoing
basis. Alpha Financial’s advisory fee, as set forth at Item 5 below, will remain
the same regardless of whether or not the client determines to address financial
planning issues with Alpha Financial. Please Also Note: Alpha Financial does
not serve as an attorney, accountant, or insurance agent, and no portion of our
services should be construed as same. Accordingly, Alpha Financial does not
prepare legal documents, prepare tax returns, or sell insurance products. To
the extent requested by a client, we may recommend the services of other
professionals for non-investment implementation purpose (i.e., attorneys,
accountants, insurance, etc.). The client is not under any obligation to engage
any such professional(s). The client retains absolute discretion over all such
implementation decisions and is free to accept or reject any recommendation
from Alpha Financial and/or its representatives. If the client engages any
- 3 -
Alpha Financial Advisors, LLC
professional (i.e., attorney, accountant, insurance agent, etc.), recommended
or otherwise, and a dispute arises thereafter relative to such engagement, the
client agrees to seek recourse exclusively from the engaged professional. At
all times, the engaged licensed professional[s] (i.e. attorney, accountant,
insurance agent, etc.), and not Alpha Financial, shall be responsible for the
quality and competency of the services provided.
interest
if Alpha Financial will earn new (or
increase
Please Note: Retirement Rollovers-Potential for Conflict of Interest: A
client or prospective client leaving an employer typically has four options
regarding an existing retirement plan (and may engage in a combination of
these options): (i) leave the money in the former employer’s plan, if permitted,
(ii) roll over the assets to the new employer’s plan, if one is available and
rollovers are permitted, (iii) roll over to an Individual Retirement Account
(“IRA”), or (iv) cash out the account value (which could, depending upon the
client’s age, result in adverse tax consequences). If Alpha Financial
recommends that a client roll over their retirement plan assets into an account
to be managed by Alpha Financial, such a recommendation creates a conflict
its current)
of
compensation as a result of the rollover. If Alpha Financial provides a
recommendation as to whether a client should engage in a rollover or not
(whether it is from an employer’s plan or an existing IRA), Alpha Financial is
acting as a fiduciary 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. No client is under any obligation
to roll over retirement plan assets to an account managed by Alpha
Financial, whether it is from an employer’s plan or an existing IRA. Alpha
Financial’s Chief Compliance Officer, Ann Reilley, remains available to
address any questions that a client or prospective client may have
regarding the potential for conflict of interest presented by such rollover
recommendation.
Allocation to Mutual Funds and Exchange Traded Funds: Many mutual
funds and exchange traded funds are available directly to the public. Therefore,
a prospective client can obtain many of the funds that may be utilized by Alpha
Financial independent of engaging Alpha Financial as an investment adviser.
However, if a prospective client determines to do so, he/she will not receive the
Alpha Financial’s initial and ongoing investment advisory services. Please
Note-Use of DFA Mutual Funds: Alpha Financial utilizes some mutual funds
issued by Dimensional Fund Advisors (“DFA”) in client portfolios. DFA mutual
funds are generally only available through registered investment advisors.
Thus, if a client terminates Alpha Financial’s services, and does not transition
to another adviser who utilizes DFA mutual funds, restrictions regarding
additional purchases of, or reallocation among other DFA funds will generally
apply. In addition, Alpha Financial representatives may be invited to DFA
sponsored events on a gratis or discounted basis-see Item 12. Alpha
- 4 -
Alpha Financial Advisors, LLC
Financial’s Chief Compliance Officer, Ann Reilley, remains available to
address any questions that a client or prospective client may have
regarding the above.
Schwab. As discussed below at Item 12 below, when requested to
recommend a broker-dealer/custodian for client accounts, Alpha Financial
generally recommends that Schwab serve as the broker-dealer/custodian for
client investment management assets. Broker-dealers such as Schwab charge
brokerage commissions, transaction, and/or other type fees for effecting certain
types of securities transactions (i.e., including transaction fees for certain
mutual funds, and mark-ups and mark-downs charged for fixed income
transactions, etc.). The types of securities for which transaction fees,
commissions, and/or other type fees (as well as the amount of those fees) shall
differ depending upon the broker-dealer/custodian (while certain custodians,
including Schwab do not currently charge fees on individual equity transactions,
others do). These fees/charges are in addition to Alpha Financial’s investment
advisory fee at Item 5 below. Alpha Financial does not receive any portion of
these fees/charges. ANY QUESTIONS: Alpha Financial’s Chief Compliance
Officer, Ann Reilley, remains available to address any questions that a
client or prospective client may have regarding the above.
Portfolio Activity. Alpha Financial has a fiduciary duty to provide services
consistent with the client’s best interest. As part of its investment advisory
services, Alpha Financial will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including,
but not limited to, investment performance, market conditions, fund manager
tenure, style drift, regular re-balancing and/or a change in the client’s
investment objective. Based upon these factors, there may be extended
periods of time when Alpha Financial determines that changes to a client’s
portfolio are neither necessary nor prudent. Clients nonetheless remain subject
to the fees described in Item 5 below during periods of account inactivity.
ERISA PLAN and 401(k) INDIVIDUAL ENGAGEMENTS:
Trustee Directed Plans. Alpha Financial may be engaged to provide
discretionary investment advisory services to ERISA retirement plans,
whereby Alpha Financial shall manage Plan assets consistent with the
investment objective designated by the Plan trustees. In such
engagements, Alpha Financial will serve as an investment fiduciary as
that term is defined under The Employee Retirement Income Security
Act of 1974 (“ERISA”). Alpha Financial will generally provide services on
an “assets under management” fee basis per the terms and conditions
of an Investment Advisory Agreement between the Plan and Alpha
Financial.
- 5 -
Alpha Financial Advisors, LLC
Client Retirement Plan Assets. Alpha Financial provides investment
advisory services relative to retirement plan assets including 401(k),
403b and 457 Plans offered by the client’s employer held at Plan
custodian. Alpha Financial allocates (or recommends that the client
allocate) the retirement account assets among the investment options
available on the 401(k) platform. Alpha Financial’s ability shall be limited
to the allocation of the assets among the investment alternatives
available through the plan. Alpha Financial will not receive any
communications directly from the plan sponsor or custodian, and it shall
remain the client’s exclusive obligation to notify Alpha Financial of any
changes in investment alternatives, restrictions, etc. pertaining to the
retirement account. Unless expressly indicated to the client in writing,
Alpha Financial shall include the client’s retirement plan assets as
assets under management for purposes of calculating the advisory fee.
Please Note: Non-Discretionary Service Limitations. Clients that
determine to engage Alpha Financial on a non-discretionary investment
advisory basis must be willing to accept that Alpha Financial cannot
effect any account transactions without obtaining prior consent to any
such transaction(s) from the client. Thus, in the event that Alpha
Financial would like to make a transaction for a client’s account, and
client is unavailable, Alpha Financial will be unable to effect the account
transaction (as it would for its discretionary clients) without first obtaining
the client’s consent.
Please Note: Cash Positions. Alpha Financial continues to treat cash
as an asset class. As such, unless determined to the contrary by Alpha
Financial, all cash positions (money markets, etc.) shall continue to be
included as part of assets under management for purposes of
calculating Alpha Financial’s advisory fee. At any specific point in time,
depending upon perceived or anticipated market conditions/events
(there being no guarantee
that such anticipated market
conditions/events will occur), Alpha Financial may maintain cash
positions for defensive purposes. In addition, while assets are
maintained in cash, such amounts could miss market advances.
Depending upon current yields, at any point in time, Alpha Financial’s
advisory fee could exceed the interest paid by the client’s money market
fund. ANY QUESTIONS: Alpha Financial’s Chief Compliance
Officer, Ann Reilley, remains available to address any questions
that a client or prospective may have regarding the above fee
billing practice.
Borrowing Against Assets/Risks. A client who has a need to borrow money
could determine to do so by using:
Margin-The account custodian or broker-dealer lends money to the client.
The custodian charges the client interest for the right to borrow money, and
- 6 -
Alpha Financial Advisors, LLC
uses the assets in the client’s brokerage account as collateral. Alpha does
not recommend the use of margin; and,
Pledged Assets Loan- In consideration for a lender (i.e., a bank, etc.) to
make a loan to the client, the client pledges its investment assets held at
the account custodian as collateral;
These above-described collateralized loans are generally utilized because they
typically provide more favorable interest rates than standard commercial loans.
These types of collateralized loans can assist with a pending home purchase,
permit the retirement of more expensive debt, or enable borrowing in lieu of
liquidating existing account positions and incurring capital gains taxes.
However, such loans are not without potential material risk to the client’s
investment assets. The lender (i.e., custodian, bank, etc.) will have recourse
against the client’s investment assets in the event of loan default or if the assets
fall below a certain level. For this reason, Alpha Financial does not recommend
such borrowing unless it is for specific short-term purposes (i.e., a bridge loan
to purchase a new residence). Alpha Financial does not recommend such
borrowing for investment purposes (i.e., to invest borrowed funds in the
market). Regardless, if the client was to determine to utilize margin or a pledged
assets loan, the following economic benefits would inure to Alpha Financial:
by taking the loan rather than liquidating assets in the client’s account,
Alpha Financial continues to earn a fee on such Account assets; and,
if the client invests any portion of the loan proceeds in an account to be
managed by Alpha Financial, Alpha Financial will receive an advisory fee
on the invested amount; and,
if Alpha Financial’s advisory fee is based upon the higher margined account
value, Alpha Financial will earn a correspondingly higher advisory fee. This
could provide Alpha Financial with a disincentive to encourage the client to
discontinue the use of margin. Alpha does not recommend the use of
margin.
Please Note: The Client must accept the above risks and potential
corresponding consequences associated with the use of margin or a pledged
assets loan.
Client Obligations. In performing our services, Alpha Financial shall not be
required to verify any information received from the client or from the client’s
other professionals, and is expressly authorized to rely thereon. Moreover, it
remains each client’s responsibility to promptly notify Alpha Financial if there is
ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/evaluating/revising our previous recommendations and/or
services.
Investment Risk. Different types of investments involve varying degrees of
risk, and it should not be assumed that future performance of any specific
- 7 -
Alpha Financial Advisors, LLC
investment or investment strategy (including the investments and/or investment
strategies recommended or undertaken by Alpha Financial) will be profitable or
equal any specific performance level(s).
Cybersecurity Risk. The information technology systems and networks that
Alpha Financial and its third-party service providers use to provide services to
Alpha Financial’s clients employ various controls that are designed to prevent
cybersecurity incidents stemming from intentional or unintentional actions that
could cause significant interruptions in Alpha Financial’s operations and/or
result in the unauthorized acquisition or use of clients’ confidential or non-public
personal information. Clients and Alpha Financial are nonetheless subject to
the risk of cybersecurity incidents that could ultimately cause them to incur
financial losses and/or other adverse consequences. Although Alpha Financial
has established processes to reduce the risk of cybersecurity incidents, there
is no guarantee that these efforts will always be successful, especially
considering that Alpha Financial does not control the cybersecurity measures
and policies employed by third-party service providers, issuers of securities,
broker-dealers, qualified custodians, governmental and other regulatory
authorities, exchanges and other financial market operators and providers.
Client Privacy and Confidentiality. Alpha Financial maintains policies and
procedures designed to help protect the confidentiality and security of client
nonpublic personal information (“NPPI”). NPPI includes, but is not limited to,
social security numbers, credit or debit card numbers, state identification card
numbers, driver’s license number and account numbers. Alpha Financial
maintains administrative, technical, and physical safeguards designed to
protect such information from unauthorized access, use, loss, or destruction.
These safeguards include controls relating to data access, information security,
and incident response, and are reviewed to address changes in risk and
business. Client information may be disclosed in response to regulatory
requests, legal obligations, or as otherwise permitted by law, and any such
disclosure is made in accordance with applicable privacy and confidentiality
requirements. Alpha Financial may engage non-affiliated service providers in
connection with providing advisory services, and such providers may have
access to client NPPI, as necessary, to perform their functions. These service
providers represent to Alpha Financial that they maintain safeguards designed
to protect client information from unauthorized access or use and that they will
provide notice to Alpha Financial in the event of a cybersecurity incident
involving client information. While Alpha Financial maintains policies and
procedures designed to protect client information, such measures cannot
eliminate all risk. Upon becoming aware of a data breach involving a client’s
NPPI, Alpha Financial will notify clients of such breach as may be required by
applicable state and federal laws.
Artificial Intelligence. Alpha Financial may use certain Artificial Intelligence
(“AI”) tools in connection with its investment advisory services. Alpha Financial
has adopted an AI Policy that governs the appropriate use of AI tools to ensure
that Alpha Financial and its employees abide by their fiduciary duty and comply
- 8 -
Alpha Financial Advisors, LLC
with all applicable regulations. AI tools are not used by Alpha Financial as a
substitute for professional judgment by Alpha Financial or its employees, and
all AI generated output is reviewed by Alpha Financial for accuracy. All
investment decisions and recommendations are made and approved by Alpha
Financial. The use of AI tools does not guarantee the accuracy of analyses or
the success of any investment strategy. Clients should not assume that reliance
on AI tools results in better performance or reduces risk. AI tools involve
limitations and risks that Alpha Financial monitors and manages. These risks
include, but are not limited to, data security concerns, potential inaccuracies,
and possible algorithmic biases. To mitigate these risks, Alpha Financial has
implemented controls such as pre-approval requirements for AI tools,
restrictions on providing nonpublic personal information to public AI systems,
vendor due diligence, review of AI-generated materials, and employee training
on appropriate AI usage.
Item 5: Fees and Compensation
Financial Planning and Investment Advisory Services
Alpha Financial’s Financial Planning and Investment Advisory Services
combine financial planning services with ongoing investment management to
clients based upon the client’s unique circumstances and needs.
Financial planning services may include assistance with setting short and long
term financial goals, cash flow analysis, assessing the investment risk that may
be prudent for the client’s portfolio, assisting the client in analyzing the client’s
investment asset allocation, planning for college and retirement expenses,
insurance planning, and assistance with estate planning needs. Generally, the
services provided include:
- Development and implementation of an investment objective and related
investment allocation, which may thereafter be amended from time to time if
and when the client’s circumstances change.
- Monthly or quarterly statements sent to the client directly from the
corresponding custodians, brokers, banks, mutual funds, partnership sponsors,
and/or insurance companies which hold the client’s investments. In an effort to
reduce the use of natural resources and reduce the opportunity for identity theft,
we encourage the use of electronic delivery of these documents through a
secure online interface.
- Portfolio Reviews and Rebalancing of the portfolio, for the assets held under
management, on an as-needed basis.
- Personal consultations on the services provided throughout the year. We
believe it is important to meet at least two times per year and generally, more
in the first year of our work with a client.
- 9 -
Alpha Financial Advisors, LLC
Financial Planning and Investment Advisory Services Fees
The annualized fee for investment management services is calculated
according to the following schedule:
Assets under management
Annual fee
First $1,000,000
Additional assets above $1,000,000 but less than $3,000,000
Additional assets above $3,000,000
1.00%*
0.50%
0.35%
*A minimum quarterly fee of $1,875 applies to new clients, subject to Item 7
below.
related accounts, account composition, complexity of
to be rendered, grandfathered
Fee Dispersion. Alpha Financial, in its discretion, may charge a lesser
investment advisory fee, charge a flat fee, waive its fee entirely, or charge fee
on a different interval, based upon certain criteria (i.e. anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be
the
managed,
engagement, anticipated services
fee
schedules, employees and family members, courtesy accounts, competition,
negotiations with client, etc.). Please Note: As result of the above, similarly
situated clients could pay different fees. In addition, similar advisory services
may be available from other investment advisers for similar or lower
fees. Please Also Note: In the event that the client is subject to an annual
minimum fee, the client could pay a higher percentage fee than referenced
above. ANY QUESTIONS: Alpha Financial’s Chief Compliance Officer, Ann
Reilley, remains available to address any questions that a client or prospective
client may have regarding advisory fees.
Fee Billing
Financial Planning and Investment Advisory Services investment management
fees are billed quarterly, in arrears, meaning that we invoice you after the three-
month billing period has ended. Payment in full is expected upon invoice
presentation. Fees are usually deducted from a designated client account to
facilitate billing. The client must consent in advance to direct debiting of their
investment account.
New clients are billed pro-rata for the partial quarter.
General Fee Information
Custodians may charge transaction fees on purchases or sales of certain
mutual funds and exchange-traded funds. These transaction charges are
usually small and incidental to the purchase or sale of a security. Alpha
Financial believes the selection of the security is more important than the
nominal fee that the custodian charges to buy or sell the security.
- 10 -
Alpha Financial Advisors, LLC
All fees paid to Alpha Financial for investment management services are
separate and distinct from the fees and expenses charged by mutual funds
and/or ETF’s to their shareholders. The funds’ fees and expenses are
described in each fund’s prospectus and will generally include a management
fee, other fund expenses, and a possible distribution fee. The client should
review both the fees charged by the funds and our fees to fully understand the
total amount of fees to be paid by the client and to thereby evaluate the advisory
services being provided.
Alpha Financial is deemed to be a fiduciary to advisory clients that are
employee benefit plans or individual retirement accounts (IRAs) pursuant to the
Employee Retirement Income and Securities Act (“ERISA”), and regulations
under the Internal Revenue Code of 1986 (the “Code”). As such, Alpha
Financial is subject to specific duties and obligations that include among other
things, restrictions concerning certain forms of compensation. To avoid
engaging in prohibited transactions, Alpha Financial only charges fees for
investment advice about products to which our firm or any related persons do
not receive any commissions or 12b-1 fees.
Independent Manager Fees
As noted in Item 4, Alpha Financial may manage a portion of a client’s
investment portfolio through Independent Managers. To avoid conflicts of
interest, Alpha Financial does not receive compensation from Independent
Managers and earns only its advisory fee as described above. While
Independent Managers typically do not offer fee discounts, they may have
breakpoint schedules that reduce fees as assets under management increase.
The terms of such fee arrangements are included in the Independent
Manager’s disclosure brochure and applicable contract[s] with the Independent
Manager. The total blended fee, including Alpha Financial’s fee and the
Independent Manager’s fee, will not exceed 1.50% annually.
Past Due Accounts and Termination of Agreement
Alpha Financial reserves the right to stop work on any account that is more
than 120 days overdue. In addition, Alpha Financial reserves the right to
terminate any financial planning engagement where a client has willfully
concealed or has refused to provide pertinent information about financial
situations when necessary and appropriate, in Alpha Financial’s judgment, to
providing proper financial advice. The amount to be refunded will be the fee
actually paid less the portion of that fee earned to the date of termination.
Item 6: Performance-Based Fees
Alpha Financial does not charge performance-based fees. Alpha Financial
does not receive any fees from any parties except our clients.
- 11 -
Alpha Financial Advisors, LLC
Item 7: Types of Clients
Description
Alpha Financial provides advisory services to the following types of clients: high
net worth individuals, pension and profit sharing plans, and trusts.
Client relationships vary in scope and length of service.
Account Minimums
The minimum investment management relationship size is $750,000 of assets
under management, which equates to a minimum annual fee of $7,500.
Alpha Financial has the discretion to waive the minimum investment
management relationship size or corresponding minimum annual
fee.
Accounts of less than $750,000 may be set up when the client and the advisor
anticipate the client will add additional funds to the accounts bringing the total
to $750,000 within a reasonable time. Other exceptions will apply to employees
of Alpha Financial and their relatives, or relatives of existing clients.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
Alpha Financial employs fundamental analysis and analysis of economic,
market, industry, firm, and product cycles and trends to evaluate investments
and manage portfolios.
The main sources of information include financial newspapers and magazines,
inspections of corporate activities, research materials prepared by others,
corporate rating services, annual reports, prospectuses, filings with the
Securities and Exchange Commission, and company press releases.
Other sources of information that Alpha Financial may use include Morningstar
Premium mutual fund information, Schwab’s stock research, Standard & Poor’s
Stock research, and the World Wide Web.
Investment Strategies
The primary investment strategy used on client accounts is strategic asset
allocation utilizing mutual funds and exchange-traded funds to build a broadly
diversified portfolio. Portfolios are generally globally diversified to control the
risk associated with traditional markets.
Alpha Financial continually adapts its investment strategies to market
conditions and individual client needs. The investment strategies used to
implement any investment advice given to clients include long term purchases
(securities held at least a year) and short term purchases (securities sold within
a year). Alpha Financial does not make short sales or engage in margin
transactions for clients except in special circumstances and at a client’s specific
request. It occasionally executes option transactions at the request of clients,
- 12 -
Alpha Financial Advisors, LLC
but does not employ options or other derivatives in accounts over which it has
discretionary investment authority.
The investment strategy for a specific client is based upon the objectives stated
by the client during consultations. The client may change these objectives at
any time. Alpha Financial executes an Investment Objective Confirmation
Letter that documents each client’s investment objective and desired
investment strategy.
Risk of Loss
All investment programs have certain risks that are borne by the investor. Our
investment approach constantly keeps the risk of loss in mind. Investors face
the following investment risks:
Interest-rate Risk: Fluctuations in interest rates may cause investment
prices to fluctuate. For example, when interest rates rise, yields on
existing bonds become less attractive, causing their market values to
decline.
Market Risk: The price of a security, bond, or mutual fund may drop in
reaction to tangible and intangible events and conditions. This type of
risk is caused by external factors independent of a security’s particular
underlying circumstances. For example, political, economic and social
conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar today will
not buy as much as a dollar next year, because purchasing power is
eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the
value of the dollar against the currency of the investment’s originating
country. This is also referred to as exchange rate risk.
Reinvestment Risk: This is the risk that future proceeds from
investments may have to be reinvested at a potentially lower rate of
return (i.e. interest rate). This primarily relates to fixed income
securities.
Business Risk: These risks are associated with a particular industry or
a particular company within an industry. For example, oil-drilling
companies depend on finding oil and then refining it, a lengthy process,
before they can generate a profit. They carry a higher risk of profitability
than an electric company, which generates its income from a steady
stream of customers who buy electricity no matter what the economic
environment is like.
Liquidity Risk: Liquidity is the ability to readily convert an investment
into cash. Generally, assets are more liquid if many traders are
interested in a standardized product. For example, Treasury Bills are
highly liquid, while real estate properties are not.
- 13 -
Alpha Financial Advisors, LLC
Financial Risk: Excessive borrowing to finance a business’ operations
increases the risk of profitability, because the company must meet the
terms of its obligations in good times and bad. During periods of
financial stress, the inability to meet loan obligations may result in
bankruptcy and/or a declining market value.
Item 9: Disciplinary Information
Alpha Financial and management personnel have no disciplinary events to
disclose.
Item 10: Other Financial Industry Activities and Affiliations
Alpha Financial and our related persons are not engaged in any other financial
industry activities and have no other industry affiliations.
Item 11: Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading
Code of Ethics
fairness, suitability,
The employees of Alpha Financial have committed to a Code of Ethics and
Fiduciary Oath as outlined by the National Association of Personal Financial
Advisors (NAPFA). The key points are: putting clients’ interests first, objectivity,
confidentiality, competence,
integrity and honesty,
regulatory compliance, full disclosure and professionalism. CFP® designees
are also held to a Code of Ethics as outlined by the CFP® Board of Standards.
Among other things, our Code of Ethics includes requirements to submit
holdings reports for “reportable securities” by access persons as defined under
Rule 204A-1 when applicable. It also includes rules to protect against any
conflicts of interest and to safeguard clients’ personal information. Alpha
Financial will provide a copy of the Code of Ethics to any client or prospective
client upon request.
Participation or Interest in Client Transactions
Alpha Financial and its employees may buy or sell securities that are also held
by clients. Employees may not trade their own securities ahead of client trades.
Employees comply with the provisions of the Alpha Financial Policies and
Procedures Manual.
Personal Trading
All personal trades made by employees are reviewed quarterly by the Chief
Compliance Officer of Alpha Financial, Ann Reilley. These reviews ensure that
the personal trading of employees does not affect the markets, and that Alpha
Financial clients receive preferential treatment.
- 14 -
Alpha Financial Advisors, LLC
Item 12: Brokerage Practices
Brokerage Practices
In the event that the client requests that Alpha Financial recommend a broker-
dealer/custodian for execution and/or custodial services, Alpha Financial
generally recommends that investment accounts be maintained at Charles
Schwab & Co., Inc. (“Schwab”). Prior to engaging Alpha Financial to provide
investment management services, the client will be required to enter into a
formal Investment Advisory Agreement with Alpha Financial setting forth the
terms and conditions under which Alpha Financial shall advise on the client's
assets, and a separate custodial/clearing agreement with each designated
broker-dealer/custodian.
Factors that Alpha Financial considers in recommending Schwab (or any other
broker-dealer/custodian to clients) include historical relationship with Alpha
financial strength, reputation, execution capabilities, pricing,
Financial,
research, and service. Although the transaction fees paid by Alpha Financial’s
clients shall comply with Alpha Financial’s duty to obtain best execution, a client
may pay a transaction fee that is higher than another qualified broker-dealer
might charge to effect the same transaction where Alpha Financial determines,
in good faith, that the transaction fee is reasonable. 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 custodian’s services, including the value of research
provided, execution capability,
transaction rates, and responsiveness.
Accordingly, although Alpha Financial will seek competitive rates, it may not
necessarily obtain the lowest possible rates for client account transactions.
Transaction fees charged by the designated broker-dealer/custodian are
exclusive of, and in addition to, Alpha Financial’s investment advisory fee.
Non-Soft Dollar Research and Benefits: Although not a material
consideration when determining whether to recommend that a client utilize the
services of a particular broker-dealer/custodian, Alpha Financial may receive
from Schwab (or another broker-dealer/custodian, investment manager,
platform or fund sponsor [including DFA], or vendor) without cost (and/or at a
discount) support services and/or products, certain of which assist Alpha
Financial to better monitor and service client accounts maintained at such
institutions. Included within the support services that may be obtained by Alpha
Financial may be investment-related research, pricing information and market
data, software and other technology that provide access to client account data,
compliance and/or practice management-related publications, discounted or
gratis consulting services, discounted and/or gratis attendance at conferences,
meetings, and other educational and/or social events, marketing support and/or
other products used by Alpha Financial in furtherance of its investment advisory
business operations.
Certain of the above support services and/or products assist Alpha Financial in
managing and administering client accounts. Others do not directly provide
- 15 -
Alpha Financial Advisors, LLC
such assistance, but rather assist Alpha Financial to manage and further
develop its business enterprise.
Alpha Financial’s clients do not pay more for investment transactions effected
and/or assets maintained at Schwab as a result of this arrangement. There is
no corresponding commitment made by Alpha Financial to Schwab, or any
other any entity to invest any specific amount or percentage of client assets in
any specific mutual funds, securities or other investment products as result of
the above arrangement.
Alpha Financial’s Chief Compliance Officer, Ann Reilley, remains
available to address any questions that a client or prospective client may
have regarding the above arrangements and the conflict of interest
presented.
Directed Brokerage. Alpha Financial recommends that its clients utilize the
brokerage and custodial services provided by Schwab. Alpha Financial does
not accept directed brokerage arrangements (but could make an exception, in
its sole discretion). A directed brokerage arrangement arises when a client
requires that account transactions be effected through a specific broker-
dealer/custodian, other than the one generally recommended by Alpha
Financial (i.e., Schwab). In such client directed arrangements, the client will
negotiate terms and arrangements for their account with that broker-dealer, and
Alpha Financial will not seek better execution services or prices from other
broker-dealers or be able to "batch" the client’s transactions for execution
through other broker-dealers with orders for other accounts managed by Alpha
Financial. As a result, a client may pay higher commissions or other transaction
costs or greater spreads, or receive less favorable net prices, on transactions
for the account than would otherwise be the case. Please Note: In the event
that the client directs Alpha Financial to effect securities transactions for the
client’s accounts through a specific broker-dealer, the client correspondingly
acknowledges that such direction may cause the accounts to incur higher
commissions or transaction costs than the accounts would otherwise incur had
the client determined to effect account transactions through alternative clearing
arrangements that may be available through Alpha Financial. Please Also
Note: Higher transaction costs adversely impact account performance. Please
Further Note: Transactions for directed accounts will generally be executed
following the execution of portfolio transactions for non-directed accounts.
Order Aggregation. Transactions for each client account generally will be
effected independently, unless Alpha Financial decides to purchase or sell the
same securities for several clients at approximately the same time. Alpha
Financial may (but is not obligated to) combine or “batch” such orders for
individual equity transactions (including ETFs) with the intention to obtain better
price execution, to negotiate more favorable commission rates, or to allocate
more equitably among Alpha Financial’s clients’ differences in prices and
commissions or other transaction costs that might have occurred had such
orders been placed independently. Under this procedure, transactions will be
averaged as to price and will be allocated among clients in proportion to the
- 16 -
Alpha Financial Advisors, LLC
purchase and sale orders placed for each client account on any given day. In
the event that Alpha Financial becomes aware that an employee seeks to trade
in the same security on the same day, the employee transaction will either be
included in the “batch” transaction or transacted after all discretionary client
transactions have been completed. Alpha Financial shall not receive any
additional compensation or remuneration as the result of such aggregation.
Item 13: Review of Accounts
Periodic Reviews
Alpha Financial performs account reviews at least quarterly using an automatic
portfolio rebalancing software solution with oversight by a lead member of its
Investment Committee, Ann Reilley, or H. Nick Barringer. Account reviews are
performed more frequently when market conditions dictate. One of Alpha
Financial’s investment adviser representatives conducts reviews of proposed
trades.
Review Triggers
Account reviews are performed more frequently when market conditions
dictate, or when a client’s objectives change. A review may be triggered by a
client request, changes in market conditions, new information about an
investment, changes in tax laws, or other important changes.
Regular Reports
Account reviewers are members of the Alpha Financial’s Investment
Committee. They are instructed to consider the client's current security
positions and the likelihood that the performance of each security will contribute
to the investment objectives of the client.
Clients receive periodic communications on a quarterly basis, and occasionally
more frequently. Client letters are typically transmitted via e-mail. Investment
Management clients receive annual or quarterly performance reports which are
typically posted electronically to their client portal.
Item 14: Client Referrals and Other Compensation
Incoming Referrals
Alpha Financial receives client referrals from current clients, estate planning
attorneys, accountants, employees, personal friends of employees and other
similar sources. Alpha Financial does not compensate individuals or entities
for prospective client introductions.
Referrals Out
Alpha Financial does not accept referral fees or any form of remuneration from
other professionals when a prospect or client is referred to them.
- 17 -
Alpha Financial Advisors, LLC
Other Compensation
As indicated at Item 12 above, Alpha Financial can receive from Schwab
without cost (and/or at a discount), support services and/or products. Alpha
Financial’s clients do not pay more for investment transactions effected and/or
assets maintained at Schwab as a result of this arrangement. There is no
corresponding commitment made by Alpha Financial to Schwab, or to any other
entity, to invest any specific amount or percentage of client assets in any
specific mutual funds, securities or other investment products as a result of the
above arrangements. Alpha Financial’s Chief Compliance Officer, Ann
Reilley, remains available to address any questions that a client or
prospective client may have regarding the above arrangements and the
corresponding conflicts of interest presented.
Item 15: Custody
Alpha Financial shall have the ability to deduct its advisory fee from the client’s
custodial account on a quarterly basis. Clients are provided with written
transaction confirmation notices, and a written summary account statement
directly from the custodian (i.e., Schwab, etc.) at least quarterly. Please Note:
To the extent that Alpha Financial provides clients with periodic account
statements or reports, the client is urged to compare any statement or report
provided by Alpha Financial with the account statements received from the
account custodian. Please Also Note: The account custodian does not verify
the accuracy of Alpha Financial’s advisory fee calculation.
In addition, certain clients have established asset transfer authorizations that
permit the qualified custodian to rely upon instructions from Alpha to transfer
client funds or securities to third parties. These arrangements are disclosed at
Item 9 of Part 1 of Form ADV. However, in accordance with the guidance
provided in the SEC’s February 21, 2017 Investment Adviser Association No-
Action Letter, the affected accounts are not subject to an annual surprise CPA
examination.
Alpha Financial maintains passwords for client retirement accounts requiring
disclosure at Item 9 of Part 1 of Form ADV. Password possession can result
in Alpha Financial having custody under Rule 206(4)-2 of the Advisers Act. Per
the Rule, having such custody requires Alpha Financial to undergo an annual
surprise CPA examination, and make a corresponding Form ADV-E filing with
the SEC, for as long as Alpha Financial engages in such practice. Beginning in
2022, Alpha Financial determined to submit all such passwords to an annual
surprise CPA examination for as long as Alpha Financial engages in such
practice.
ANY QUESTIONS: Alpha Financial’s Chief Compliance Officer,
Ann Reilley, remains available to address any questions that a client or
prospective client may have regarding custody-related issues.
- 18 -
Alpha Financial Advisors, LLC
Item 16: Investment Discretion
Discretionary Authority for Trading
Alpha Financial accepts discretionary authority to manage securities accounts
on behalf of clients. Alpha Financial has the authority to determine, without
obtaining specific client consent, the securities to be bought or sold, and the
amount of the securities to be bought or sold.
The client approves the custodian to be used and the transaction fees paid to
the custodian. Alpha Financial does not receive any portion of the transaction
fees paid by the client to the custodian on certain trades.
Discretionary trading authority facilitates placing trades in client accounts on
their behalf so that Alpha Financial may promptly implement the investment
policy guidelines that each Client has approved in writing.
Limited Power of Attorney
A limited power of attorney is a trading authorization for this purpose. Clients
sign a limited power of attorney so that Alpha Financial may execute trades on
the clients’ behalf.
Item 17: Voting Client Securities
Proxy Votes
Alpha Financial does not vote client proxies. Clients maintain exclusive
responsibility for: (1) directing the manner in which proxies solicited by issuers
of securities owned by the client shall be voted; and (2) making all elections,
decisions, and filings relative to any mergers, acquisitions, tender offers,
bankruptcy proceedings, class actions, or other type actions or events
pertaining to the client’s investment assets.
Clients will receive their proxies or other solicitations directly from their
custodian. Clients may contact Alpha Financial to discuss any questions they
may have with a particular solicitation.
Item 18: Financial Information
Financial Condition
Alpha Financial has not been the subject of a bankruptcy petition at any time
and does not have any financial impairment that will preclude Alpha Financial
from meeting contractual commitments to clients.
A balance sheet is not required to be provided in this brochure because Alpha
Financial does not serve as a custodian for client funds or securities, and does
not require or solicit prepayment of fees more than six months in advance of
services rendered. ANY QUESTIONS: Alpha Financial’s Chief Compliance
- 19 -
Alpha Financial Advisors, LLC
Officer, Ann Reilley, remains available to address any questions
regarding this Part 2A.
- 20 -
Alpha Financial Advisors, LLC
Business Continuity Plan & Information Security
General
Alpha Financial recognizes that one of the largest risks inherent in an
independent advisory firm is insuring the continuous operation of the firm
regardless of circumstances. On a day to day basis, this may include having
adequate computer support partners, backup procedures and data security. It
also can include contingency planning in the event of the death or disability of
a key employee(s), disaster recovery, information security protocol, etc. Alpha
Financial continuously monitors our technological platform for proper client
protection, and for potential improvements.
Disasters
In the event of a disaster (fire, power loss, flood, etc.) Alpha Financial has the
ability to access client related information in multiple ways remotely. Any
portfolio modifications that would need to take place can be done through either
calling the qualified custodian if internet access is not available, or by placing
trades from a remote location via the internet. Alpha Financial’s server resides
in a “cloud based” environment as a measure of protection against unforeseen
disasters. This comes with its own set of data security concerns, and Alpha
Financial attempts to practice strong and secure access procedures at all
times. Critical components required to operate Alpha Financial’s business
operations, are accessible remotely from the internet through a virtual private
network (“VPN”). Other than some historical client correspondence and data,
all email and critical systems reside in the cloud. Electronic files are backed up
daily and archived offsite in more than one location.
Record Retention
Alpha Financial complies with recordkeeping requirements set forth by the
SEC. As a paperless office, we do not anticipate a time when physical records
will be stored offsite. However, it is understood that if this is to occur, such
records must be maintained onsite for at least two years from the end of the
fiscal year in which the last change to that record occurred. A complete back-
up of information is maintained offsite in order to prevent permanent loss in the
event of a catastrophic event. As a paperless office, many items such as
legal documents and other pertinent client
statements, applications,
information first originates in paper form. When scanned into our computer
system, the paper copies are then placed and kept in a locked area awaiting
shredding.
Alternative Offices
Alpha Financial maintains no alternative office within the United States. The
only office location in the United States is the location noted on the cover page
of this document. In the event that our U.S. office is unavailable for an extended
period of time due to a disaster, employees are equipped to work remotely. It
- 21 -
Alpha Financial Advisors, LLC
is our intention to contact all clients within five days of a disaster that dictates
moving our office to an alternate remote workspace.
Information Security
Alpha Financial maintains an information security program to reduce the risk
that your personal and confidential information may be breached. We take
multiple steps to protect client data, to secure our office environment, and to
attempt to ensure client information is not placed at undue risk. We continue to
seek out new procedures that may improve our existing system.
Loss of Key Personnel
Alpha Financial utilizes a “team approach” to working with clients, so generally
a client will have a relationship with more than just one Alpha Financial Advisor
employee. This has been intentionally designed to provide redundancies in the
event that a key employee is not available, and we consider this to be a best
practice.
Privacy Notice
Alpha Financial Advisors, LLC (referred to as “Alpha Financial”) maintains
physical, electronic, and procedural safeguards that comply with federal
standards to protect its clients’ nonpublic personal information (“information”).
Through this policy and its underlying procedures, Alpha Financial attempts to
secure the confidentiality of customer records and information and protect
against anticipated threats or hazards to the security or integrity of customer
records and information.
It is the policy of Alpha Financial to restrict access to all current and former
clients’ information (i.e., information and records pertaining to personal
background, investment objectives, financial situation, tax information/returns,
investment holdings, account numbers, account balances, etc.) to those
employees and affiliated/nonaffiliated entities who need to know that
information in order to provide products or services in furtherance of the client's
engagement of Alpha Financial. In that regard, Alpha Financial may disclose
the client’s information: (1) to individuals and/or entities not affiliated with Alpha
Financial, including, but not limited to the client’s other professional advisors
and/or certain service providers that may be recommended or engaged by
Alpha Financial in furtherance of the client's engagement of Alpha Financial
(i.e., attorney, accountant, insurance agent, broker-dealer, investment adviser,
account custodian, record keeper, proxy management service provider, etc.);
(2) required to do so by judicial or regulatory process; or (3) otherwise permitted
to do so in accordance with the parameters of applicable federal and/or state
privacy regulations. The disclosure of information contained in any document
completed by the client for processing and/or transmittal by Alpha Financial to
facilitate
the commencement/continuation/termination of a business
relationship between the client and/or between Alpha Financial and a
nonaffiliated third party service provider (i.e., broker-dealer, investment
adviser, account custodian, record keeper, insurance company, etc.),
- 22 -
Alpha Financial Advisors, LLC
including, but not limited to, information contained in any document completed
and/or executed by the client in furtherance of the client's engagement of
Alpha Financial (i.e., advisory agreement, client information form, etc.), shall
be deemed as having been automatically authorized by the client with respect
to the corresponding nonaffiliated third party service provider.
Alpha Financial permits only authorized employees and affiliates who have
signed a copy of Alpha Financial’s Privacy Policy to have access to client
information. Employees violating Alpha Financial’s Privacy Policy will be
subject to Alpha Financial’s disciplinary process. Additionally, whenever Alpha
Financial hires other organizations to provide services to Alpha Financial’s
clients, Alpha Financial will require them to sign confidentiality agreements
and/or the Privacy Policy. ANY QUESTIONS: Alpha Financial’s Chief
Compliance Officer, Ann Reilley remains available to address any
questions regarding this Part 2A.
- 23 -
Alpha Financial Advisors, LLC