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Alpha Omega Financial Advisory, Inc.
dba
Alpha Omega Financial
17353 Hampton Falls Terrace
Bradenton, FL 34202
Mailing Address:
29 Manor Springs Court
Glen Arm, MD 21057-9500
Telephone: (410) 592-8936
Facsimile: (410) 203-3113
billc@alphaomegafinancial.net
February 09, 2026
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Alpha Omega
Financial. If you have any questions about the contents of this brochure, please contact us at (410)
592-8936 or via e-mail at billc@alphaomegafinancial.net. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about Alpha Omega Financial is also available on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Alpha Omega Financial is 314289.
Alpha Omega Financial is a registered investment adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of
skill or training.
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Item 2 Summary of Material Changes
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure,
the adviser is required to notify you and provide you with a description of the material changes.
Since our the filing of our last Annual Updating Amendment dated February 05, 2025 we have no
material changes to our Brochure to report.
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Item 3 Table of Contents
Item 1 Cover Page
Item 2 Summary of Material Changes
Item 3 Table of Contents
Item 4 Advisory Business
Item 5 Fees and Compensation
Item 6 Performance-Based Fees and Side-By-Side Management
Item 7 Types of Clients
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16 Investment Discretion
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State-Registered Advisers
Item 20 Additional Information
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Item 4 Advisory Business
Description of Services and Fees
Alpha Omega Financial was originally formed in 2011 as a limited liability corporation. We reorganized
as an S-Corporation in May 2024 under the laws of the State of Florida. Alpha Omega Financial is
a registered investment adviser based in Bradenton, Florida. We have been providing investment
advisory services since 2011. William Carambelas is our principal owner. Currently, we offer the
following investment advisory services, which are personalized to each individual client:
• Financial Planning Services
• Portfolio Management Services
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we", "our" and "us" refer to Alpha Omega
Financial and the words "you", "your" and "client" refer to you as either a client or prospective client of
our firm. Also, you may see the term Associated Person throughout this brochure. As used in this
brochure, our Associated Persons are our firm's officers, employees, and all individuals providing
investment advice on behalf of our firm.
We us the terms "we" and "our" throughout this disclosure brochure to refer to Alpha Omega
Financial. The use of these terms is not intended to imply that there is more than one individual
associated with this firm.
Financial Planning Services
We offer broad-based, comprehensive, and, occasionally, modular financial planning services.
Financial planning will typically involve providing a variety of advisory services to clients regarding the
management of their financial resources based upon an analysis of their individual needs. If you retain
our firm for financial planning services, we will meet with you to gather information about your financial
circumstances and objectives. We may also use financial planning software to determine your current
financial position and to define and quantify your long-term goals and objectives. Once we review and
analyze the information you provide to our firm and the data derived from our financial planning
software, we will deliver a written plan to you, designed to help you achieve your stated financial goals
and objectives.
Depending on your requirements, and the agreement you enter into with us, our written evaluation and
recommendations may include financial planning topics such as: creation of a net worth statement,
budget/cash flow analysis; education funding planning; retirement income planning; investment
planning, portfolio review or other accumulation needs, allocation of qualified plans; income tax review;
estate planning; survivor or disability income needs, long term care needs, other insurance needs,
business planning, and charitable planning.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to our firm. You must promptly notify our firm if your financial
situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to
act on any of our recommendations, you are not obligated to implement the financial plan through any
of our other investment advisory services. Moreover, you may act on our recommendations by placing
securities transactions with any brokerage firm.
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You may terminate the financial planning agreement by providing written notice to our firm. You will
incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-
paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees.
Portfolio Management Services
We offer discretionary and non-discretionary portfolio management services. Our investment advice is
tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio
management services, we will meet with you to determine your investment objectives, risk tolerance,
and other relevant information (the "suitability information") at the beginning of our advisory
relationship. We will use the suitability information we gather to develop a strategy that enables our
firm to give you continuous and focused investment advice and/or to make investments on your behalf.
As part of our portfolio management services, we may customize an investment portfolio for you in
accordance with your risk tolerance and investing objectives. We may also invest your assets using a
predefined strategy, or we may invest your assets according to one or more model portfolios
developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio,
we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as
required by changes in market conditions and in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow our firm to
determine the specific securities, and the amount of securities, to be purchased or sold for your
account without your approval prior to each transaction. Discretionary authority is typically granted by
the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization
forms. You may limit our discretionary authority (for example, limiting the types of securities that can be
purchased or sold for your account) by providing our firm with your restrictions and guidelines in
writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval
prior to executing any transactions on behalf of your account.
At our discretion, we may combine the account values of family members living in the same household
to determine the applicable advisory fee. For example, we may combine account values for you and
your minor children, joint accounts with your spouse, and other types of related accounts. Combining
account values may increase the asset total, which may result in your paying a reduced advisory fee
based on the available breakpoints in our fee schedule stated above.
We will deduct our fee directly from your account through the qualified custodian holding your funds
and securities. We will deduct our advisory fee only when the following requirements are met:
• You provide our firm with written authorization permitting the fees to be paid directly from your
account held by the qualified custodian.
• We send you an invoice showing the amount of the fee, the value of the assets on which the
fee is based, and the specific manner in which the fee was calculated.
• The qualified custodian agrees to send you a statement, at least quarterly, indicating all
amounts dispersed from your account including the amount of the advisory fee paid directly to
our firm.
You may terminate the portfolio management agreement upon 30-days' written notice to our firm. You
will incur a pro rata charge for services rendered prior to the termination of the portfolio management
agreement, which means you will incur advisory fees only in proportion to the number of days in the
quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you
will receive a prorated refund of those fees.
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We encourage you to reconcile our invoices with the statement(s) you receive from the qualified
custodian. If you find any inconsistent information between our invoice and the statement(s) you
receive from the qualified custodian please call our main office number located on the cover page of
this brochure.
Wrap Fee Program(s)
Our firm does not participate in any wrap fee programs.
Types of Investments
We recommend all types of securities and we do not necessarily recommend one particular type of
security over another since each client has different needs and different tolerance for risk. Each type of
security has its own unique set of risks associated with it and it would not be possible to list here all of
the specific risks of every type of investment. Even within the same type of investment, risks can vary
widely. However, in very general terms, the higher the anticipated return of an investment, the higher
the risk of loss.
You may request that we refrain from investing in particular securities or certain types of securities.
You must provide these restrictions to our firm in writing.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule's provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from an ERISA account to an account that we
manage or provide investment advice to, because the assets increase our Assets Under Management
and, in turn, our advisory fees. In contrast, we normally receive less, or no, compensation if assets
remain in the current plan or are rolled over to another Company's plan in which you may participate.
Assets Under Management
As of December 31, 2025, we provide continuous management services for $186,968,599 in client
assets on a discretionary basis, and $0 in client assets on a non-discretionary basis. We also
manage $1,380,938 in client assets on a non-continuous basis.
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Item 5 Fees and Compensation
For Financial Planning Services we charge a fixed fee for financial planning services, which is
negotiable depending on the scope and complexity of the plan, your situation, and your financial
objectives. An estimate of the total time/cost will be determined at the start of the advisory relationship.
In limited circumstances, the cost/time could potentially exceed the initial estimate. In such cases, we
will notify you and request that you approve the additional fee.
We may, in our discretion, require that you pay a portion of the fee in advance with the remaining
portion due upon the completion of the services rendered. In such case, the specific portion will be
negotiated and based on the anticipated amount of time required to prepare the financial plan. In all
other cases, fees are due upon completion of services. We do not require prepayment of a fee more
than six months in advance and in excess of $1,200.
Our fee for portfolio management services is based on a percentage of your assets we manage and
also depends on the character of those assets as either (1) Directly Managed by us (where we have
the ability to initiate transactions directly with the custodian on either a discretionary or non-
discretionary basis) or (2) Not Directly Managed by us (where we can only advise you as to what
transactions to place but where you must initiate those transactions with the custodian yourself). Some
examples of accounts that are not directly managed by us are 401(k) accounts, 403(b) accounts, and
certain variable annuity sub-accounts.
Our fee for portfolio management services is set forth in the following fee schedule:
Assets Under Management
$ 0 - $ 249,999
$ 250,000 - $ 499,999
$ 500,000 - $ 999,999
$1,000,000 - $3,499,999
$3,500,000 - $4,999,999
$5,000,000 and Above
Annual Fee For Accounts
Directly Managed By Us
1.40%
1.20%
1.10%
1.00%
0.90%
Negotiable
Annual Fee For Accounts
Not Directly Managed By Us *
0.70 - 1.40%
0.60 -1.20%
0.55 - 1.10%
0.50 - 1.00%
0.50 - 0.90%
Negotiable
*Depending upon the mix of directly held assets and those not directly held by us, we may, in our
discretion, charge a higher (or lower) rate for those assets not directly held with us. Final rates will be
determined by the adviser, and approved by the client, after review of the composition of a client's total
portfolio. By way of clarification, assets that are directly managed by us are generally not aggregated
with assets that are not managed directly by us for purposes of meeting the breakpoints listed above.
Although we may use margin on occasion, the fees we charge are based on the net asset value of
your account and we do not include the margin or credit line in that valuation.
Our annual portfolio management fee is billed and payable quarterly in advance based on the value of
your account on the last day of the previous quarter. Where deposits to client(s)' account(s) exceed
$100,000 per deposit (i.e, in a single lump sum transaction) and are made prior to end of a quarter, we
may, in our sole discretion, charge a pro rated fee on the additional funds, based on the fee schedule
above, for the remaining days in the quarter that we will manage those funds. In such cases, we would
send you an interim quarterly billing statement. Where withdrawls from client(s)' account(s) exceed
$100,000 per withdrawal (i.e, in a single lump sum transaction) and are made prior to end of a quarter,
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we will refund the unearned portion of the quarterly advisory fee calculated on the withdrawn
funds and the remaining days in the quarter. In no event will any additional fee or refund be charged,
or due, on deposits or withdrawals of less than $100,000.
In the event of a full termination of your portfolio management or financial planning agreement (made
in accordance with the termination provisions provided therein), you will receive a prorated refund of
any pre-paid advisory fees that we have not yet earned.
In the event that the client has accounts that are not directly managed by us in addition to accounts
that we directly manage, the total quarterly fee for all accounts may be deducted from the account(s),
designated by the client, that we directly manage. In the alternative, we can bill the client directly for
our fees on accounts that we do not directly manage.
If the portfolio management agreement is executed at any time other than the first day of a calendar
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
proportion to the number of days in the quarter for which you are a client. Our advisory fee is
negotiable, depending on individual client circumstances.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. We will recommend "no-load" funds. The fees that you pay
to our firm for investment advisory services are separate and distinct from the fees and expenses
charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their
shareholders. These fees will generally include a management fee and other fund expenses. You may
also incur transaction charges and/or brokerage fees when purchasing or selling securities. These
charges and fees are typically imposed by the broker-dealer or custodian through whom your account
transactions are executed. We do not share in any portion of the brokerage fees/transaction charges
imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should
review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For
information on our brokerage practices, please refer to the Brokerage Practices section of this
brochure.
Item 6 Performance-Based Fees and Side-By-Side Management
We do not accept performance-based fees or participate in side-by-side management. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. Side-by-side management refers to the practice of managing accounts that are charged
performance-based fees while at the same time managing accounts that are not charged performance-
based fees. Our fees are calculated as described in the Fees and Compensation section above, and
are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in
your advisory account.
Item 7 Types of Clients
We offer investment advisory services to individuals, trusts, estates, charitable organizations,
corporations, and other business entities.
In general, we require a minimum of $500,000 to open and maintain an advisory account. At our
discretion, we may waive this minimum account size. For example, we may waive the minimum if you
appear to have significant potential for increasing your assets under our management. We may also
combine account values for you and your minor children, joint accounts with your spouse, and other
types of related accounts to meet the stated minimum.
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Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
We will use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
• Fundamental Analysis - involves analyzing individual companies and their industry groups,
such as a company's financial statements, details regarding the company's product line, the
experience and expertise of the company's management, and the outlook for the company's
industry. The resulting data is used to measure the true value of the company's stock compared
to the current market value.
• Technical Analysis - involves studying past price patterns and trends in the financial markets
to predict the direction of both the overall market and specific stocks.
• Charting Analysis - involves the gathering and processing of price and volume information for
a particular security. This price and volume information is analyzed using mathematical
equations. The resulting data is then applied to graphing charts, which is used to predict future
price movements based on price patterns and trends.
• Long Term Purchases - securities purchased with the expectation that the value of those
securities will grow over a relatively long period of time, generally greater than one year.
• Short Term Purchases - securities purchased with the expectation that they will be sold within
a relatively short period of time, generally less than one year, to take advantage of the
securities' short-term price fluctuations.
• Options: Options are complex securities that involve risks and are not suitable for everyone.
Option trading can be speculative in nature and carry substantial risk of loss. It is generally
recommended that you only invest in options with risk capital . However, there are some
strategies that can be employed to minimize the risk of options trading and, in some cases,
options trading can be used as a hedge against risk. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or
before a certain date (the "expiration date"), the obligation is with the seller. The two types of
options are calls and puts: A call gives the holder the right to buy an asset at a certain price
within a specific period of time. Buyers of calls hope that the stock will increase substantially
before the option expires. A put gives the holder the right to sell an asset at a certain price
within a specific period of time. Buyers of puts hope that the price of the stock will fall before the
option expires.
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined objectives,
risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
Client assets are advised using:
Fundamental Analysis - The risk of fundamental analysis is that information obtained may be
incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis
for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis
may not result in favorable performance.
Charting and Technical Analysis - The risk of market timing based on technical analysis is that
charts may not accurately predict future price movements. Current prices of securities may reflect all
information known about the security and day to day changes in market prices of securities may follow
random patterns and may not be predictable with any reliable degree of accuracy.
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Cyclical Analysis - Economic/business cycles may not be predictable and may have many
fluctuations between long term expansions and contractions. The lengths of economic cycles may be
difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting
economic trends and consequently the changing value of securities that would be affected by these
changing trends.
Our strategies and investments may have unique and significant tax implications. Although tax
efficiency is an important factor that we consider for those clients that are not in one of our model
portfolios, we emphasize that we are not CPA's. Regardless of your account size, or any other factors,
we strongly recommend that you consult with a tax professional regarding the investing of your assets.
As a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis
of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the
FIFO (First-In First-Out) accounting method for calculating the cost basis of your investments. You are
responsible for contacting your tax advisor to determine if this accounting method is the right choice for
you. If your tax advisor believes another accounting method is more advantageous, please provide
written notice to our firm immediately and we will alert your account custodian of your individually
selected accounting method. Please note that decisions about cost basis accounting methods will
need to be made before trades settle, as the cost basis method cannot be changed after settlement.
Portfolio Design and Management Methodology:
Asset Allocation - We utilize a broad and comprehensive set of asset classes and subclasses to
construct your allocation models including, but not necessarily limited to: US, Foreign, and Emerging
Market Equities; Fixed Income (such as Municipal bonds, Investment grade corporate bonds, Hi Yield
bonds, Emerging market bonds, Mortgage Backed Securities, Floating Rate bonds, Treasury Bonds);
Other Income producing assets (such as Preferred Shares, Convertible Shares, Real Estate
Investment Trusts (publicly traded), Utility holdings Master Limited Partnerships (publicly traded)); and,
Commodities (such as Energy, Precious Metals, Agriculture, Commodity Indices). We utilize individual
stocks, ETF's and mutual funds to gain exposure to Commodities. We do not purchase Commodity
Futures.
Risk Management - Our primary approach to managing portfolio risk is to properly set the overall
allocation risk level in the portfolio based upon a client's risk tolerance. This allocation risk is defined
as the ratio of more volatile assets, such as Stocks, as compared to less volatile assets such as Bonds
and Cash. We attempt to manage the portfolio risk by monitoring the volatility of the individual
securities in the portfolio as well as the overall portfolio volatility. Additionally, where you hold a large
position in a particular security, we will attempt to manage the risk involved by recommending
structured disposition plans and/or utilizing options. We will also monitor the credit markets in order to
manage fixed income market risks (i.e., interest rate risk, credit, and duration risk factors) so we may
advantageously position your assets in various fixed income subsectors. In addition, while we
generally sell positions down, as may be called for by changed market conditions or portfolio
rebalancing, at times we may use hedging techniques to optimize tax efficiency for currently held
assets. For example, to minimize realized capital gains, especially those that are short term in nature.
Other - We focus on minimizing portfolio expenses by using low cost exchange traded funds,
institutional class mutual funds as well as individual equities to gain exposure to desired asset classes.
The use of no load, non institutional class, shares may also be included in those portfolios utilizing
open end mutual funds..
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Tax efficiency - We may review your current and prior year tax returns to understand your income tax
situation including, for example, your marginal tax bracket, Schedule D carry-forwards, state income
taxes, etc. In both the initial portfolio design and when rebalancing, we will evaluate the tradeoff
between tax efficiency and optimizing the portfolio design before implementing trade decisions. We will
seek to realize long term gains versus short term gains when possible. We will also focus on tax
efficient placement of assets in both qualified (tax deferred retirement) and non-qualified account
types.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.
We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past
performance is in no way an indication of future performance.
Recommendation of Particular Types of Securities
As disclosed under the Advisory Business section in this Brochure, we recommend all types of
securities and we do not necessarily recommend one particular type of security over another since
each client has different needs and different tolerance for risk. Each type of security has its own unique
set of risks associated with it and it would not be possible to list here all of the specific risks of every
type of investment. Even within the same type of investment, risks can vary widely. However, in very
general terms, the higher the anticipated return of an investment, the higher the risk of loss.
Item 9 Disciplinary Information
We are required to disclose the facts of any legal or disciplinary events that are material to a client's
evaluation of our advisory business or the integrity of our management. We do not have any required
disclosures under this item.
Item 10 Other Financial Industry Activities and Affiliations
We have not provided information on other financial industry activities and affiliations because we do
not have any relationship or arrangement that is material to our advisory business or to our clients with
any of the types of entities listed below.
1. broker-dealer, municipal securities dealer, or government securities dealer or broker.
2. investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or "hedge fund," and
offshore fund).
3. other investment adviser or financial planner.
4. futures commission merchant, commodity pool operator, or commodity trading advisor.
5. banking or thrift institution.
6. accountant or accounting firm.
7. lawyer or law firm.
8. insurance company or agency.
9. pension consultant.
10.real estate broker or dealer.
11.sponsor or syndicator of limited partnerships.
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Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our
goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties
of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere
strictly to these guidelines. Our Code of Ethics also requires that certain persons associated with our
firm submit reports of their personal account holdings and transactions to a qualified representative of
our firm who will review these reports on a periodic basis. Persons associated with our firm are also
required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written
policies reasonably designed to prevent the misuse or dissemination of material, non-public
information about you or your account holdings by persons associated with our firm.
Clients or prospective clients may obtain a copy of our Code of Ethics by contacting us at the
telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any of our Associated Persons has any material financial interest in client
transactions beyond the provision of investment advisory services as disclosed in this brochure.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because
we have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To mitigate this conflict of interest, it is our policy that neither our Associated Persons nor we
shall have priority over your account in the purchase or sale of securities.
Item 12 Brokerage Practices
The custodian and brokers we use - Charles Schwab (Schwab)
We do not maintain custody of your assets that we manage or on which we advise, although we may
be deemed to have custody of your assets if you give us authority to withdraw assets from your
account (see Item 15—Custody, below). Your assets must be maintained in an account at a "qualified
custodian," generally a broker-dealer or bank. We require that our clients use Charles Schwab & Co.,
Inc. (Schwab), a registered broker-dealer, member SIPC, as the qualified custodian, when investing in
the Adviser's model portfolios.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your
assets in a brokerage account and buy and sell securities when we instruct them to. While
we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will
open your account with Schwab by entering into an account agreement directly with them. Conflicts of
interest associated with this arrangement are described below as well as in Item 14 (Client referrals
and other compensation). You should consider these conflicts of interest when selecting your
custodian.
We do not open the account for you, although we may assist you in doing so. Not all advisors require
their clients to use a particular broker-dealer or other custodian selected by the advisor. However, we
require that all trades be executed through Schwab.
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How we select brokers/custodians
We seek to use Schwab, a custodian/broker that will hold your assets and execute transactions. When
considering whether the terms that Schwab provides are, overall, most advantageous to you when
compared with other available providers and their services, we take into account a wide range of
factors, including:
• Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
• Capability to execute, clear, and settle trades (buy and sell securities for your account)
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
• Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
("ETFs"), etc.)
• Availability of investment research and tools that assist us in making investment decisions
• Quality of services
• Competitiveness of the price of those services (commission rates, margin interest rates, other
fees, etc.) and willingness to negotiate the prices
• Reputation, financial strength, security and stability
• Prior service to us and our clients
• Services delivered or paid for by Schwab
• Availability of other products and services that benefit us, as discussed below (see "Products
and services available to us from Schwab")
Your brokerage and custody costs
For our clients' accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and
ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by
earning interest on the un invested cash in your account in Schwab's Cash Features Program. Schwab
charges you a flat dollar amount as a "prime broker" or "trade away" fee for each trade that we have
executed by a different broker-dealer but where the securities bought or the funds from the securities
sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions
or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your
trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers.
Although we are not required to execute all trades through Schwab, we have determined that having
Schwab execute most trades is consistent with our duty to seek "best execution" of your trades. Best
execution means the most favorable terms for a transaction based on all relevant factors, including
those listed above (see "How we select brokers/custodians"). By using another broker or dealer you
may pay lower transaction costs.
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Products and services available to us from Schwab
Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like
us. They provide us and our clients with access to their institutional brokerage services (trading,
custody, reporting, and related services), many of which are not typically available to Schwab retail
customers. However, certain retail investors may be able to get institutional brokerage services from
Schwab without going through us.
Schwab also makes available various support services. Some of those services help us manage or
administer our clients' accounts, while others help us manage and grow our business. Schwab's
support services are generally available on an unsolicited basis (we don't have to request them) and at
no charge to us. Following is a more detailed description of Schwab's support services:
Services that benefit you. Schwab's institutional brokerage services include access to a broad range
of investment products, execution of securities transactions, and custody of client assets.
The investment products available through Schwab include some to which we might not otherwise
have access or that would require a significantly higher minimum initial investment by our
clients. Schwab's services described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and
services that benefit us but do not directly benefit you or your account. These products and services
assist us in managing and administering our clients' accounts and operating our firm. They include
investment research, both Schwab's own and that of third parties. We use this research to service all
or a substantial number of our clients' accounts, including accounts not maintained at Schwab. In
addition to investment research, Schwab also makes available software and other technology that:
• Provide access to client account data (such as duplicate trade confirmations and account
statements)
• Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
• Provide pricing and other market data
• Facilitate payment of our fees from our clients' accounts
• Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us manage
and further develop our business enterprise. These services include:
• Educational conferences and events
• Consulting on technology and business needs
• Consulting on legal and related compliance needs
• Publications and conferences on practice management and business succession
• Access to employee benefits providers, human capital consultants, and insurance providers
• Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays
all or a part of a third party's fees. Schwab also provides us with other benefits, such as occasional
business entertainment of our personnel. If you did not maintain your account with Schwab, we would
be required to pay for these services from our own resources.
Our Interest in Schwab's Services
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The availability of these services from Schwab benefits us because we do not have to produce or
purchase them. We don't have to pay for Schwab's services. These services are not contingent upon
us committing any specific amount of business to Schwab in trading commissions or assets in
custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the
use of Schwab rather than making such a decision based exclusively on your interest in receiving the
best value in custody services and the most favorable execution of your transactions. This is a conflict
of interest. We believe, however, that taken in the aggregate, our selection of Schwab as custodian
and broker is in the best interests of our clients. Our selection is primarily supported by the scope,
quality, and price of Schwab's services (see "How we select brokers/ custodians") and not Schwab's
services that benefit only us.
Soft Dollar Benefits
We do not have any formal soft dollar arrangements with any broker-dealer.
Economic Benefits
As a registered investment adviser, we have access to the institutional platform of your account
custodian. As such, we will also have access to research products and services from your account
custodian and/or other brokerage firm. These products may include financial publications, information
about particular companies and industries, research software, and other products or services that
provide lawful and appropriate assistance to our firm in the performance of our investment decision-
making responsibilities. Such research products and services are provided to all investment advisers
that utilize the institutional services platforms of these firms, and are not considered to be paid for with
soft dollars. However, you should be aware that we may therefore have an incentive to select or
recommend Schwab based on our interest in receiving the research or other products or services,
rather than on receiving most favorable execution.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation,
such as brokerage services or research.
Directed Brokerage
We routinely recommend that you direct our firm to execute transactions through Schwab. As such, we
may be unable to achieve the most favorable execution of your transactions and you may pay higher
brokerage commissions than you might otherwise pay through another broker-dealer that offers the
same types of services. Not all advisers require their clients to direct brokerage.
Aggregated Trades
Transactions for each client generally will be effected independently, unless we decide to purchase or
sell the same securities for several clients at approximately the same time. We may, but are not
obligated to, combine multiple orders for shares of the same securities purchased for advisory
accounts we manage (this practice is commonly referred to as "aggregated trading"). We will then
distribute a portion of the shares to participating accounts in a fair and equitable manner. The
distribution of the shares purchased is typically proportionate to the size of the account, but it is not
based on account performance or the amount or structure of management fees. Subject to our
discretion regarding factual and market conditions, when we combine orders, each participating
account pays an average price per share for all transactions. Accounts owned by our firm or persons
associated with our firm may participate in aggregated trading with your accounts; however, they will
not be given preferential treatment.
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Item 13 Review of Accounts
Bill Carambelas, President of Alpha Omega Financial will monitor your accounts on a periodic basis
and will conduct account reviews at least quarterly, and usually weekly. the reviews are designed to
ensure the advisory services provided to you and that the portfolio mix are consistent with your stated
investment needs and objectives. Additional reviews may be conducted based on various
circumstances, including, but not limited to:
• contributions and withdrawals,
• year-end tax planning,
• market moving events,
• security specific events, and/or,
• changes in your risk/return objectives.
For those accounts that we directly manage we will provide you with additional or regular written
reports in conjunction with account reviews on a quarterly basis. Reports we provide to you will contain
relevant account and/or market-related information such as an inventory of account holdings and
account performance. You will receive trade confirmations and monthly or quarterly statements from
your account custodian(s). We do not provide additional or regular written reports for accounts that we
do not directly manage.
Bill Carambelas, President of our firm will review financial plans as needed, depending on the
arrangements made with you at the inception of your advisory relationship to ensure that the planning
advice and/or asset allocation recommendations made to you are consistent with your stated
investment needs and objectives. It is your responsibility to contact us when there are changes in your
circumstances. Changed circumstances may include, but are not limited to marriage, divorce, birth,
death, inheritance, lawsuit, retirement, job loss, and/or disability, among others. Where warranted, we
will provide you with updates to the financial plan in conjunction with the review. We recommend
meeting with you at least annually to review and update your plan if needed. Additional reviews will be
conducted upon your request. Such reviews and updates may be subject to our then current hourly
rate depending on the scope of the review. We will not provide regular written reports for financial
planning and consulting services. If you implement financial planning advice through a broker-dealer,
you will receive trade confirmations and monthly or quarterly statements from relevant custodians.
Item 14 Client Referrals and Other Compensation
We do not receive any compensation from any third party in connection with providing investment
advice to you nor do we compensate any individual or firm for client referrals.
Item 15 Custody
As paying agent for our firm, your independent custodian will directly debit your account(s) for the
payment of our advisory fees. We do not have physical custody of any of your funds and/or securities.
Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified
custodian. You will receive account statements from the independent, qualified custodian(s) holding
your funds and securities at least quarterly. The account statements from your custodian(s) will
indicate the amount of our advisory fees deducted from your account(s) each billing period. You should
carefully review account statements for accuracy. We will also provide statements to you reflecting the
amount of advisory fee deducted from your account.
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You should compare our statements with the statements from your account custodian(s) to reconcile
the information reflected on each statement. If you have a question regarding your account statement,
or if you did not receive a statement from your custodian, please contact us immediately at the
telephone number on the cover page of this brochure.
Standing Letter of Authorization
Our firm, or persons associated with our firm, may effect electronic or ACH transfers from client
accounts to one or more third parties designated, in writing, by the client without obtaining written client
consent for each separate, individual transaction, as long as the client has provided us with written
authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An
adviser with authority to conduct such third party wire transfers on a client's behalf has access to the
client's assets, and therefore is considered to have custody of the client's assets in any related
accounts.
However, as long as we meet the following criteria, we are not required to obtain a surprise annual
audit, as we otherwise would be required to by reason of having custody:
1. You provide a written, signed instruction to the qualified custodian that includes the third party's
name and address or account number at a custodian;
2. You authorize us in writing to direct transfers to the third party either on a specified schedule or
from time to time;
3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a
transfer of funds notice to you promptly after each transfer;
4. You can terminate or change the instruction;
5. We have no authority or ability to designate or change the identity of the third party, the
address, or any other information about the third party;
6. We maintain records showing that the third party is not a related party to us nor located at the
same address as us; and
7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
We hereby confirm that we meet the above criteria.
Item 16 Investment Discretion
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement, a power of attorney, and/or trading authorization forms.
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or
industry should not exceed specified percentages of the value of the portfolio and/or restrictions or
prohibitions of transactions in the securities of a specific industry or security. Please refer to
the Advisory Business section in this brochure for more information on our discretionary management
services.
If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to
implement any advise provided by our firm on a non-discretionary basis.
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Item 17 Voting Client Securities
We will not vote proxies on behalf of your advisory accounts. We do not offer you any advice regarding
corporate actions and the exercise of your proxy voting rights. If you own shares of applicable
securities, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we were to receive any written or electronic proxy materials, we would forward them directly to
you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we
would forward any electronic solicitation to vote proxies.
Item 18 Financial Information
We are not required to provide a balance sheet or other financial information to our clients because we
do not require the prepayment of fees in excess of $1200 and six months or more in advance; we do
not take custody of client funds or securities; and, we do not have a financial condition that is
reasonably likely to impair our ability to meet our commitments to you. Moreover, we have never been
the subject of a bankruptcy petition.
Item 19 Requirements for State-Registered Advisers
We are a federally registered investment adviser; therefore, we are not required to respond to this
item.
Item 20 Additional Information
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated third parties,
except as permitted by law. In the course of servicing your account, we may share some information
with our service providers, such as transfer agents, custodians, broker-dealers, accountants,
consultants, and attorneys as well as with another registered investment adviser with whom we've
made arrangements for business continuity in the event of the death or disability of the owner of our
firm.
We restrict internal access to nonpublic personal information about you to employees, who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your nonpublic personal information and to
ensure our integrity and confidentiality. We will not sell information about you or your accounts to
anyone. We do not share your information unless it is required to process a transaction, at your
request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with
our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual
basis. Please contact our main office at the telephone number on the cover page of this brochure if you
have any questions regarding this policy.
Trade Errors
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In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in, had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a
trade error results in a profit, you will keep the profit.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you
are eligible to participate in class action settlements or litigation nor do we initiate or participate in
litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or
negligence by issuers of securities held by you.
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