Overview

Assets Under Management: $109 million
Headquarters: SAVANNAH, GA
High-Net-Worth Clients: 35
Average Client Assets: $2.2 million

Frequently Asked Questions

ALPHA FINANCIAL MANAGEMENT, INC. charges 1.00% on the first $1 million, 0.75% on the next $2 million, 0.50% on the next $3 million, 0.25% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #125800), ALPHA FINANCIAL MANAGEMENT, INC. is subject to fiduciary duty under federal law.

ALPHA FINANCIAL MANAGEMENT, INC. is headquartered in SAVANNAH, GA.

ALPHA FINANCIAL MANAGEMENT, INC. serves 35 high-net-worth clients according to their SEC filing dated April 16, 2026. View client details ↓

According to their SEC Form ADV, ALPHA FINANCIAL MANAGEMENT, INC. offers financial planning and portfolio management for individuals. View all service details ↓

ALPHA FINANCIAL MANAGEMENT, INC. manages $109 million in client assets according to their SEC filing dated April 16, 2026.

According to their SEC Form ADV, ALPHA FINANCIAL MANAGEMENT, INC. serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $2,000,000 0.75%
$2,000,001 $3,000,000 0.50%
$3,000,001 and above 0.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $27,500 0.55%
$10 million $40,000 0.40%
$50 million $140,000 0.28%
$100 million $265,000 0.26%

Clients

Number of High-Net-Worth Clients: 35
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 71.58%
Average Client Assets: $2.2 million
Total Client Accounts: 543
Discretionary Accounts: 543
Minimum Account Size: None

Regulatory Filings

CRD Number: 125800
Filing ID: 2095675
Last Filing Date: 2026-04-16 16:27:44

Form ADV Documents

Primary Brochure: ADV PART 2A (2026-04-16)

View Document Text
Item 1 – Cover Page 7505 WATERS AVENUE, SUITE E-1 SAVANNAH GA 31406-3631 PHONE: 912.353.9343 Additional Location: 11175 Cicero Drive, Suite 100 Alpharetta, GA 30022 470-333-2158 110 Traders Cross, 1st Floor Okatie, SC 29909 WWW.ALPHA-SAV.COM Firm Brochure (Part 2A of Form ADV) This brochure provides information about the qualifications and business practices of Alpha Financial Management, Inc. If you have any questions about the contents of this brochure, please contact us at: 912.353.9343, or by email at: ADMIN@ALPHA-SAV.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. Registration with the State of Georgia or with any state securities authority as a registered investment adviser does not imply a certain level of skill or training. Additional information about Alpha is available on the SEC’s website at www.adviserinfo.sec.gov. The firm’s CRD number is 125800. April 16, 2026 Item 2 - Material Changes Material Changes On January 30, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have updated our fee schedule in item 5 and updated ownership and the CCO. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: 912.353.9343 or by email at: ADMIN@ALPHA-SAV.COM. ii Alpha Financial Management Item 3 - Table of Contents Item 1 – Cover Page ....................................................................................................... i Item 2 - Material Changes ............................................................................................. ii Item 3 - Table of Contents ........................................................................................... iii Item 4 - Advisory Business .......................................................................................... 1 Item 5 - Fees and Compensation ................................................................................. 3 Items 6 - Performance-Based Fees .............................................................................. 6 Item 7 - Types of Clients ............................................................................................... 6 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................... 7 Item 9 - Disciplinary Information ................................................................................ 10 Item 10 - Other Financial Industry Activities and Affiliations .................................. 10 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 ..................................................................................... 13 Item 14 - Client Referrals and Other Compensation ................................................. 14 Item 15 - Custody ........................................................................................................ 15 Item 16 - Investment Discretion ................................................................................. 15 Item 17 - Voting Client Securities............................................................................... 16 Item 18 - Financial Information .................................................................................. 17 Item 19 - Requirements for State-Registered Advisors . Error! Bookmark not defined. Privacy Notice ................................................................... Error! Bookmark not defined. Brochure Supplement (Part 2B of Form ADV) ................ Error! Bookmark not defined. MICHAEL C. DAYOUB, CFP® .................................... Error! Bookmark not defined. WAYNE R. JORDAN, CFP®........................................ Error! Bookmark not defined. MARY PETRONE JORDAN, CFP® ............................. Error! Bookmark not defined. iii Alpha Financial Management Item 4 - Advisory Business Firm Description ALPHA FINANCIAL MANAGEMENT, INC., (“Alpha”) was founded in 1994. Alpha provides personalized, confidential, wealth management to individuals and investment management to pension and profit sharing plans, trusts, estates, charitable organizations 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. Alpha is a fee-only wealth management and investment management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is a member of the National Association of Personal Financial Advisors (NAPFA®), the largest organization for fee-only financial advisors. The firm is not affiliated with entities that sell financial products or securities. No commissions in any form are accepted. No finder’s fees are accepted. Investment advice is an integral part of financial planning. In addition, Alpha advises clients regarding cash flow, college planning, retirement planning, tax planning, estate planning, risk management, debt planning, and charitable giving. Alpha does not act as a custodian of client assets. The client always maintains asset control. Alpha places trades for clients under a limited power of attorney. Principal Owners WAYNE JORDAN is a 50% stockholder. MARY JORDAN is a 50% stockholder. Types of Advisory Services Comprehensive Financial Planning Alpha provides comprehensive financial planning, which includes investment management, retirement planning, insurance planning, tax planning and estate planning. The “Discovery Meeting,” is complimentary and is considered an exploratory interview to determine the values, goals, relationships, assets, advisors, process, and interests for each prospective client. - 1 - Alpha Financial Management An Investment Plan is created to reflect the prospective client’s current situation, stated goals and objectives. An Advanced Plan is developed to prioritize key financial concerns beyond the client’s investments, such as estate planning, charitable giving, insurance, and tax mitigation. These areas are addressed with the support of the client and other professionals, including tax professionals, insurance agents, and attorneys. Alpha provides investment management that includes implementation of an investment strategy, monitoring results, and reporting to the client on a regular basis. An Investment Policy Statement is developed to accomplish the client’s objectives after reviewing short-term and long-range investment goals while taking into consideration asset allocation and diversification among several asset classes. Alpha primarily offers advice on the following types of investments: mutual funds, exchange-traded funds (“ETFs”) and securities held within variable annuities. Clients may impose restrictions on investing in certain securities or types of securities. Investment Advice: Alpha provides investment advice for some clients who prefer to not engage in the comprehensive financial planning process. We still provide comprehensive financial planning for those clients, but not at the level of detail provided for our financial planning clients. These clients have negotiated a tiered or percent fee (described above) and acknowledge they are primarily receiving investment advice and the financial planning advice is ancillary to that investment advice. Retirement Rollovers-No Obligation/Conflict of Interest A client leaving an employer typically has four options (and may engage in a combination of these options): 1) leave the money in his former employer’s plan, if permitted, 2) roll over the assets to his/her new employer’s plan, if one is available and rollovers are permitted, 3) rollover to an Individual Retirement Account (IRA), or 4) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). Alpha may recommend an investor roll over plan assets to an IRA managed by Alpha. As a result, Alpha may earn an asset-based fee; however, a recommendation that a client or prospective client leave their plan assets with their old employer will result in no compensation. Alpha has an economic incentive to encourage an investor to roll plan assets into an IRA that Alpha will manage. There are various factors that Alpha may consider before recommending a rollover, including but not limited to: i) the investment options available in the plan versus the investment options available in an IRA, ii) fees and expenses in the - 2 - Alpha Financial Management plan versus the fees and expenses in an IRA, iii) the services and responsiveness of the plan’s investment professionals versus those of Alpha, iv) required minimum distributions and age considerations, and vi) employer stock tax consequences, if any. No client is under any obligation to roll over plan assets to an IRA managed by Alpha. As of December 31, 2025 Alpha manages $109,376,177 in assets under management; all on a discretionary basis. Item 5 - Fees and Compensation All fees will be billed quarterly in advance. If authorized by the client as provided in the Limited Power of Attorney portion of the Custodial application, we may submit invoices to the Custodian and instruct the Custodian to pay our fees to us directly from the Managed Portfolio. If the client has not given such direct payment authorization, fees will be payable by the client immediately upon receipt of any invoice. Alpha will provide the client with quarterly reports detailing the portfolio holdings, summarizing purchases, sales, contributions and withdrawals, and performance relative to the clients objectives and relevant indices. Alpha also encourages regular conferences to review the client’s portfolio performance, investment policy guidelines, strategies and constraints. The initial fee is predicated upon the facts known at the start of the engagement. These facts are determined by asking an extensive list of questions at the Discovery Meeting pertaining to Values, Goals, Assets, Relationships, Process, Interests, and Advisors. Alpha requests relevant documents regarding the financial situation (estate planning documents, brokerage statements, etc.) and reviews these documents during this meeting. Alpha bills one of two ways: 1. Alpha bills clients on assets under management according to the following fee schedule: 2. a. Assets Under Management First $1,000,000 Next $1,000,000 ($1M-2M) Next $1,000,000 ($2M-3M) Amounts over $3,000,001 Annual Management Fee 1.00% 0.75% 0.50% 0.25% b. - 3 - Alpha Financial Management 3. Alpha bills hourly for comprehensive financial planning advice to military families referred by ComPsych which is an Employee Assistance Program of the US Armed Services. ComPsych pays Alpha at an hourly rate. Alpha counts all hours spent with that client in person, on the phone, and preparing for meetings with that client. This billing method is only for ComPsych clients. We sometimes offer discounts to clients, depending on their needs, assets, and the work involved. Fee Billing Client Advisory Agreement and Investment Management Agreement fees are billed quarterly, in ADVANCE meaning that we invoice you BEFORE the three- month billing period has BEGUN. 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. Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating the firm’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), the firm may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, the firm 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, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when the firm determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by the firm will be profitable or equal any specific performance level(s). - 4 - Alpha Financial Management Refunds of Fees If a client relationship is terminated, the client will be refunded all fees paid in advance, adjusted for the number of days prior to termination. The portfolio value at the completion of the prior full billing period is used as the basis for the fee computation for the Client Advisory Agreement and Investment Management Agreement, adjusted for the number of days during the billing quarter prior to termination. Other Fees 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. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security. Custodians may charge a maintenance fee for holding client accounts. Expense Ratios Mutual funds generally charge a fee for their cost of operating the fund. The fee is called an expense ratio. None of that expense ratio is paid to Alpha. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Alpha chooses mutual funds with low expense ratios so clients don’t lose asset value to high mutual fund operation expenses. Past Due Accounts and Termination of Agreement Alpha reserves the right to stop work on any account that is more than 30 days overdue. In addition, Alpha reserves the right to terminate any Client Advisory Agreement and Investment Management Agreement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in Alpha’s judgment, to providing proper financial advice. Any unused portion of fees collected in advance will be refunded within 30 days. IRA Rollover Considerations As a normal extension of financial advice, we provide education or recommendations related to the rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice offers advantages and disadvantages, depending on desired investment options and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and - 5 - Alpha Financial Management retirement plans. The complexity of these choices may lead an investor to seek assistance from us. An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interests and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. Items 6 - Performance-Based Fees Sharing of Capital Gains Alpha’s fees are not based on a share of the capital gains or capital appreciation of managed securities. Alpha does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Item 7 - Types of Clients Description Alpha generally provides investment advice to individuals, pension and profit sharing plans, trusts, estates, or charitable organizations, corporations or business entities. Alpha also provides comprehensive financial planning for military families referred by ComPsych, which is an Employee Assistance Program of the US Armed Services. Client relationships vary in scope and length of service. Account Minimums Alpha does not have account minimums. Most clients have assets above $500,000 but Alpha does serve some clients who have lower net worth. - 6 - Alpha Financial Management Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis The main sources of information include research materials prepared by others, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Other sources of information that Alpha may use include Dimensional Fund Advisors market research, Charles Schwab & Company's Institutional service, Morningstar, and the World Wide Web. Alpha analyzes mutual funds recommended to clients based on the fund’s total operating expenses, portfolio turnover, investment objective and investment restrictions and limitations. Alpha typically recommends that clients invest in no- load institutional mutual funds advised by Dimensional Fund Advisors (DFA) and Charles Schwab & Company that have low operating expenses, low portfolio turnover, below-average capital gains distributions and a fundamental investment objective of investing in a particular asset class. DFA funds generally are available for investment only by clients of registered investment advisors, and all investments are subject to approval of the advisor. This means that you may not be able to make additional investments in DFA funds if you terminate your agreement with Alpha, except though another advisor authorized by DFA. Investment Strategies The primary investment strategy used on client accounts is strategic asset allocation utilizing a core and satellite approach. This means that we use passively-managed index funds or the Dimensional Funds as the core investments, and then add cash reserve strategies for short-term liquidity needs. Portfolios are globally diversified to control the risk associated with traditional markets. 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. Each client executes an Investment Policy Statement that documents their objectives and their desired investment strategy. Our investment philosophy is guided by the idea that markets are efficient. Securities are fairly priced and it is virtually impossible to pick individual winners. We do not incorporate day trading or market timing strategies in our investment recommendations. - 7 - Alpha Financial Management Risk of Loss Investing in securities involves risk of loss that an investor should be prepared to bear. 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 last 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. • 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. - 8 - Alpha Financial Management • Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate account assets in an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated positions in specific securities. Therefore, at times, an account may, or may be advised to, hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the account will be subject to greater volatility than a more sector diversified portfolio. Investments in issuers within an industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio will affect the overall value of the portfolio and will cause greater losses than it would in a portfolio that holds more diversified investments. • Environment, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain environmental, social and governance (ESG) investment criteria it may avoid purchasing certain securities for ESG reasons when it is otherwise economically advantageous to purchase those securities, or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold those securities. In general, the application of the portfolio’s ESG investment criteria may affect the portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the financial performance of the portfolio, positively or negatively, depending on whether these issuers, industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that such data reported by issuers or received from third-party sources may be subjective, or it may be objective in principle but not verified or reliable. • Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber- attacks and hacking by other computer users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to - 9 - Alpha Financial Management calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While our firm has established a business continuity plan and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks are also present for issuers of securities, investment companies and other investment advisers in which we invest, which could result in material adverse consequences for such entities and may cause a client's investment in such entities to lose value. • Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors will negatively impact investment returns. • Alpha primarily employs investment strategies that do not involve any significant or unusual risk other than domestic equity and international market risks. The risks associated with a particular strategy are provided to each client in advance of investing client accounts. Alpha will work with each client to determine their tolerance for risk as part of the portfolio construction process. Item 9 - Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Item 10 - Other Financial Industry Activities and Affiliations Other Financial Industry Activities and Affiliations None - 10 - Alpha Financial Management Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of Alpha have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Firm may own, purchase or sell same or similar securities as those of the Client. This is disclosed prior to the signing of the Financial Advisory and/or Investment Management Agreement. In addition, Firm uses best efforts to make sure that the terms of the Client's transactions involving such securities are at least as favorable as those which the Firm participates in. In the unlikely event that the interests of the Firm's account would happen to correspond with an advisory client's interests, full disclosure would be made to such client at once. Records will be maintained of all securities bought or sold by the Firm, and will be available for Client inspection upon request should it be determined by Firm that any potential conflict of interest may exist. It is the express policy of Firm that no person employed by Firm may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. As these situations may represent a conflict of interest, Firm has established the following restrictions in order to ensure its fiduciary responsibilities: 1) A director, officer or employee of Firm shall not buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No person of Firm shall prefer his or her own interest to that of the advisory client. 2) Firm maintains a list of all securities holdings for itself, and anyone associated with this advisory practice. These holdings are reviewed on a regular basis by Molly Jordan. 3) Firm requires that all individuals must act in accordance with all applicable federal and state regulations governing registered investment advisory practices. 4) Any individual not in observance of the above may be subject to termination. - 11 - Alpha Financial Management Firm has adopted a written supervisory procedures statement highlighting the steps which shall be taken to implement the firm wide policy. These materials are also distributed to all associated persons and other employees of Firm, are signed, dated and filed with insider trading compliance materials. There are provisions adopted for (1) restricting access to files, (2) providing continuing education, (3) restricting and/or monitoring trading on those securities of which Firm's employees, if any, may have non-public information, (4) requiring all of Firm's employees, if any, to conduct their trading through a specified broker or reporting all transactions promptly to Firm, and (5) monitoring the securities trading of the firm and its employees and associated persons. Participation or Interest in Client Transactions Alpha 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 Compliance Manual. Personal Trading The Chief Compliance Officer of Alpha is Molly Jordan trading reviews ensure that the personal trading of employee securities does not affect the markets, and that clients of the firm receive preferential treatment. Since most employee trades are small mutual fund trades or exchange-traded fund trades, the trades do not affect the securities markets. Item 12 - Brokerage Practices Selecting Brokerage Firms Alpha does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their need for such services. Alpha recommends custodians based on the proven integrity and financial responsibility of the firm and the best execution of orders at reasonable commission rates. Alpha recommends discount brokerage firms and trust companies (qualified custodians), such as Charles Schwab and National Advisors Trust. Schwab Institutional provides Alpha with access to its institutional trading and operations services, which are typically not available to Schwab retail investors. These services are available to independent investment advisers at no charge to them so long as a total of at least $10 million of the adviser’s clients’ account assets are maintained at Schwab Institutional. The $10 million minimum may give Alpha an incentive to recommend that clients maintain accounts with one of these Custodians, based on our interest in receiving these services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a - 12 - Alpha Financial Management potential conflict of interest. Alpha believes, however, that our selection of these Custodians is in the best interests of clients. Our selection is primarily supported by the scope, quality, and price of the services and not the services that benefit only us. As part of our fiduciary duty to clients, Alpha Financial Management endeavors at all times to put the interests of our clients first. Schwab Institutional services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional investors or would require significantly higher minimum initial investments. Schwab Institutional makes available to Alpha other products and services that benefit Alpha but may not directly benefit its clients’ accounts. Many of these products and services may be used to service all or some substantial member of Alpha’s accounts, including accounts not maintained at Schwab, and are made available at no cost or a reduced cost to Alpha. Schwab’s products and services that assist Alpha in managing and administering client’s accounts include software and other technology that (i) provide access to account data (such as trade confirmations and account statement); (ii) facilitate trade execution and allocate aggregated trade order for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of Alpha’s fees from its clients’ account; and (v) assist with back-office functions, recordkeeping and client reporting. Alpha DOES NOT receive fees or commissions from any of these arrangements. Best Execution Alpha reviews the execution of trades at each custodian each quarter. The review is documented in the Alpha Compliance Manual. Trading fees charged by the custodians are also reviewed on a quarterly basis. Alpha does not receive any portion of the trading fees. Soft Dollars Alpha does not have any soft dollar arrangements with any third parties. Order Aggregation Most trades are mutual funds or exchange-traded funds where trade aggregation does not garner any client benefit. Item 13 - Review of Accounts Periodic Reviews For Advisory Agreement clients, the Advanced Plan and Investment Plan are reviewed with clients during the Regular Progress Meetings, based on their - 13 - Alpha Financial Management frequency preferences for updates. Investment Policy Statements are reviewed on a periodic basis and may include semi-annual meetings. These reviews are performed by a member of the Investment Committee. Account reviews are performed more frequently when market conditions dictate. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's situation. Regular Reports Account reviewers are members of the firm'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 regarding their accounts. Wealth Management clients receive written annual updates. The written updates may include a net worth statement, portfolio statement, and a summary of objectives and progress towards meeting those objectives. Item 14 - Client Referrals and Other Compensation Incoming Referrals Alpha has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, NAPFA (National Association of Personal Financial Advisors) website referrals, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these referrals. Alpha is also referred clients from ComPsych, an employee assistance program of the US Armed Services. Alpha does not compensate ComPsych for those referrals. ComPsych pays Alpha at an hourly rate for the work performed. Referrals Out Alpha does not accept referral fees or any form of remuneration from other professionals when Alpha refers a prospect or client to them. - 14 - Alpha Financial Management Item 15 - Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record at least quarterly. If you are not receiving at least quarterly custodial account statements, please contact us at the number on the cover page of this brochure. Fee Deduction With a client’s consent, Alpha may be provided with the authority to seek deduction of Alpha’s advisory fee from a client’s accounts. The account custodian does not verify the accuracy of Alpha’s advisory fee calculation. Performance Reports Clients are urged to compare the annual account statements received directly from custodians with the annual investment reports provided by Alpha. Net Worth Statements Clients are provided net worth statements and net worth graphs that are generated from our client relationship management system or financial planning software program. Net worth statements contain approximations of bank account balances provided by the client, as well as the value of land and hard-to-price real estate. The net worth statements are used for long-term financial planning where the exact values of assets are not material to the financial planning tasks. Item 16 - Investment Discretion Discretionary Authority for Trading Alpha accepts discretionary authority to manage securities accounts on behalf of clients. Alpha 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. However, Alpha consults with the client prior to each trade to obtain concurrence if a blanket trading authorization has not been given. The client approves the custodian to be used. Alpha does not receive any portion of the transaction fees or commissions paid by the client to the custodian on trades. Discretionary trading authority facilitates placing trades in clients’ accounts on their behalf so that we may promptly implement the investment policy that has been approved in writing by the client. - 15 - Alpha Financial Management Clients who engage Alpha on a discretionary basis may, at any time, impose restrictions, in writing, on Alpha’s discretionary authority (i.e. limit the types/amounts of particular securities purchase for their account, exclude the ability to purchase securities with an inverse relationship to the market, limit or proscribe Alpha’s use of margin, etc.). Limited Power of Attorney A limited power of attorney is a trading authorization that permits Alpha to direct trades in client accounts. The client signs this authorization as indicated on the custodian’s account application. Item 17 - Voting Client Securities Proxy Votes Alpha does not vote proxies on securities. Clients are expected to vote their own proxies. When assistance on voting proxies is requested, Alpha will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Class Action Lawsuits From time to time, securities held in the account of clients will be subject of class action lawsuits. Alpha has no obligation to determine if securities held by the client are subject to a pending or resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, Alpha has no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients. However, in the unlikely event that Alpha receives any proxy materials of information regarding class action legal matters involving securities held in client accounts, including written or electronic proxy materials or notices of class action lawsuits, settlements, or verdicts affecting securities owned by a client, Alpha will forward all notices, proof of claim forms, and other materials, to the relevant client. Electronic mail is acceptable where appropriate, if the relevant client has authorized contact in this manner. - 16 - Alpha Financial Management Item 18 - Financial Information Financial Condition Alpha does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because Alpha does not serve as a custodian for client funds or securities, and does not require prepayment of fees of more than $600 per client and six months or more in advance. - 17 - Alpha Financial Management