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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.
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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.
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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.
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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
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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.
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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).
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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
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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.
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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.
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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.
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• 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
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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
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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.
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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
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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
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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.
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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.
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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.
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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.
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Alpha Financial Management