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ALPHA SOLUTIONS INVESTMENT ADVISORS, LLC
REGISTERED INVESTMENT ADVISORS
400 Oyster Point Blvd., Suite 407, South San Francisco, CA 94080
415-882-7088 https://asiadvisors.com
ADV II
FIRM BROCHURE
ITEM 1 – Cover Page
information about Alpha Solutions Investment Advisors
This brochure provides information about the qualifications and business practices of Alpha Solutions Investment Advisors (hereinafter “Alpha Solutions”
or “Alpha” or “firm” or “we” or “our”). If you have any questions about the contents of this brochure, please contact us at 415-882-7088 or to
anthony@asiadvisors.com. Additional
is also available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for Alpha Solutions
Investment Advisors is 156541. SEC number is 801-124857
The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state
securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of skill or training.
Brochure Rule: Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at the time it enters into an
advisory contract with the client. The rule does not require advisors to deliver brochures to certain advisory clients receiving only impersonal investment
advice or to clients that are investment companies registered under the Investment Company Act of 1940 (“Company Act”). Annual Delivery – Advisors
must annually provide to each client to whom they must deliver a brochure either (a) a copy of the current (updated) brochure that includes or is
accompanied by the summary of material changes; or (b) a summary of material changes that includes an offer to provide a copy of the current
brochure. As proposed each adviser must make this annual delivery no later than 120 days after the end of its fiscal year. Advisors may deliver a
brochure and summary of material changes or summary of material changes, along with an offer to provide the brochure to clients electronically in
accordance with the Commission’s guidelines regarding electronic delivery of information.
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September 2025
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
ITEM 2 – Material Changes
This Section will be updated with a summary of material changes since the previous
release of the Firm Brochure.
ADV Part 2A (Firm Brochure)
Anthony Sam original co-founder and 50% owner of Membership Interest in Alpha Solutions Investment Advisors, LLC has
acquired co-founder, John Lui’s 50% Membership Interest in the company effective December 31, 2024. Effective January
01, 2025 Arthur Sam acquired 5% Membership Interest in Alpha Solutions Investment Advisors, LLC.
ADV Part 2A (Appendix 1, Wrap Fee Program Brochure) – We do not offer or sponsor Wrap Fee Programs. There have
been no material changes made to this Form since the previous release.
ADV Part 2B (Brochure Supplement) – There have been no material changes made to this Form since the previous release.
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
ITEM 3 - TABLE OF CONTENTS
Item 1 -
Cover Page
i
Item 2 -
Material Changes
i
Item 3 -
Table of Contents
1
Item 4 -
Advisory Business
2
Item 5 -
Fees and Compensation
2
Item 6 -
Performance-based Fees and Side-by-Side Management
4
Item 7 -
Types of Clients
4
Item 8 -
Methods of Analysis, Investment Strategies, and Risk of Loss
4
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
10
Item 12 - Brokerage Practices
11
Item 13 - Review of Accounts
12
Item 14 - Client Referrals and Other Compensation
12
Item 15 - Custody
13
Item 16 - Investment Discretion
13
Item 17 - Voting Client Securities
14
Item 18 - Financial Information
14
Item 19 - Requirements for State Registered Investment Advisors
14
Item 20 - Additional Information
14
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
ITEM 4 – Advisory Business
A. General Description of Advisory Firm. Alpha Solutions Investment Advisors, LLC (“Alpha”) is a California limited
liability company founded in 2010. Alpha is licensed as a Registered Investment Advisor (“RIA”) with the Securities
and Exchange Commission (“SEC”).
As a Registered Investment Advisor, under Federal and State laws, we are a fiduciary and must make full disclosure
to our clients of all material facts relating to our advisory relationship. Our duty as a fiduciary to our clients
includes the following:
• We must act in what we reasonably believe to be in the client’s best interests, and in the event of a conflict of
interest, we must place the client’s interest before our own.
• We must seek to avoid conflicts of interests with our clients, and at a minimum, make full disclosure of all
material conflicts of interest between our clients that could affect the advisory relationship.
• Obligations to disclose to you all material conflicts between your interests and our interests – transparency.
•
If we, or our affiliates receive additional compensation from you or a third-party as a result of our relationship
with you, we must disclose that to you.
• We must obtain your informed consent before engaging in a transaction with you for our own account or that
of an affiliate or another client when we act in an advisory capacity.
• We must treat you and our other advisory clients fairly and equitably and cannot unfairly advantage one client
•
to the disadvantage of another.
The investment decisions or recommendations we make for you must be suitable and appropriate for you and
consistent with your investment objectives and goals and any restrictions you have placed on us.
As a fiduciary, we must always seek to avoid conflicts of interest with our clients, and at a minimum, make full
disclosure of conflicts of interest between us and our clients that could affect the advisory relationship. This
obligation includes that we disclose all material conflicts of interests under CCR Section 260,238(k) regarding the
firm, its principals, representatives or any of its employees, which could be reasonably expected to impair the
rendering of unbiased and objective advice. Also, as a fiduciary, we will in each and every investment decision,
have our clients’ best interest as the utmost priority and concern.
B. Description of Advisory Services. We provide continuous customized wealth management solutions on a
discretionary basis tailored to the specific needs of each client. Our investment management services are
provided to meet the investment goals, risk tolerances and other specified guidelines of our clients. We construct
and manage portfolios containing a diversified allocation from all major asset classes which may include domestic
and foreign stocks/equities, fixed income, exchange traded funds (“ETFs”), exchange traded real estate investment
trusts (“REITs”), Master Limited Partnerships (“MLPs”) and preferred stock. We typically do not include mutual
funds in a client’s portfolio unless the client already owns them. We also provide investment advice on cash
management, currency hedging, asset allocation, and alternative asset classes such as real estate and private
equity.
When meeting with a new client, we take great care in learning of their financial objectives, risk tolerances and
investment goals, guidelines and restrictions in order to develop a thorough understanding of the client’s financial
landscape and needs. Throughout the relationship we continue to monitor the requirements of the client and
modify or reconfigure our investment management decisions accordingly. We manage client portfolios on a
discretionary basis, this means our clients grant a limited power of attorney to us to supervise and manage the
account, place buy/sell trades within accounts. Our discretionary authority is limited to only the buying/selling of
assets within the specified portfolio. Clients may place reasonable restrictions on our investment discretion, (for
example, some clients have asked not to sell certain securities where the client has a particularly low tax basis,
others have requested to not purchase securities of companies that produce tobacco products.) As of September
16, 2025 our discretionary assets under management (“AUM”) totaled $361,856,043.15, in addition our assets
under advisement (“AUA”) totaled $2,053,338.34. In addition to our personalized asset management solutions, we
also provide in-depth and comprehensive financial planning services on a limited basis. The firm may or may not
charge additional fees for financial planning, which may also include retirement planning and estate planning.
ITEM 5 – Fees and Compensation
Alpha Solutions is a fee-only registered investment advisor. As a fee-only advisor we do NOT receive commissions or
compensation of any nature from the purchase or sale of securities for our clients, thereby avoiding a potential conflict
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of interests with our clients. Alpha Solutions’ fees are agreed upon in advance and in writing. Fees are negotiable and
can vary based upon factors such as the overall complexity of a client’s financial affairs, the types of investments, the
number of investing entities, and the extent to which other financial or consulting services are incorporated.
We calculate asset-based fees due based on the market value of each account at the close of, or during, the prior
quarter (market values are provided by the custodian or Broker-dealer). In the case of assets that are not priced daily,
we will use the most recent prices or valuations provided by the custodian or Broker-dealer. Market values used in the
calculation of fees may not always exactly match the ending value of the quarter ending statement as these market
values may also include pending accrued interest, dividends and other income and expenses for the account.
Our fees are billed and payable in arrears, at the end of each calendar quarter clients will receive an invoice for
management fees prorated from the appropriate annual rate, calculated as a percentage of total assets under
management for each portfolio/account. Our clients can either elect to authorize quarterly fees be paid by automatic
direct deduction from their account or they can pay for fees due upon receipt of an invoice. If the quarterly fees are
deducted from the account, the custodian or Broker-dealer shall indicate the deduction on the following month’s
statement in which the fees are deducted. With either payment method selected, we will always send a quarterly
statement that will indicate how our fees were calculated. We will NOT request payment of fees in advance. In
accordance with CCS Section 260,238(j), it should be noted that similar advisor services may (or may not) be available
from other registered (or unregistered) investment advisors or other sources for similar or lower fees.
ADVISORY FEE SCHEDULE (annual rate, based on market value of assets under management):
Assets Under Management
First $2 million (ie., amount up to $2 million)
Next
Next
Next
$3 million (ie., amount over $2 million up to $5 million)
$5 million (ie., amount over $5 million up to $10 million)
$10 million (ie., amount over $10 million up to $20 million)
Amount above $20 million
Annualized Fee
1.25%
1.00%
0.75%
0.60%
0.50%
Note: The fee percentages are applied according to each asset level increment. For example, an account of
$10,000,000 would pay an annualized fee of 1.25% on the first $2 million, plus 1% on the next $3 million, plus 0.75%
on the remaining $5 million, for an annual total Fee of $92,500.
A minimum annual fee of $5,000 may be imposed on each account. The minimum fee may be waived or reduced at
our discretion. We also reserve the right to adjust fees for accounts depending on the size and type of account and the
services to be rendered. In some cases, negotiation of fees may result in different fees being charged for similar
services and may be less than the stated fee schedule.
The Fees for our services as described above are completely separate and unrelated from “other costs” that a client
may incur through: brokerage/transaction commissions, custodian account fees, fees related to foreign ADR stocks,
taxes related to foreign stocks, ETF expenses and or mutual fund sales charges or expenses in connection with our
advisory services. We do not charge, collect nor benefit from these “other costs”. We encourage our clients to obtain
a complete schedule of fees from their custodian/brokerage firm. Alpha Solutions Investment Advisors is not affiliated
with any specific custodian, broker/dealer or agent.
Our investment management services will commence on the date the client signs the Investment Management
Agreement (“IMA”). Fees will be calculated on a prorated basis, using the actual number of days in the calendar
quarter that the IMA becomes effective. This IMA may be terminated by either Alpha Solutions Investment Advisors or
the client at any time – the party requesting termination must provide the other party written notice. If an IMA is
terminated before the end of a quarter or a billing period, the client will be responsible for any unpaid services
calculated on a pro rata basis upon the number of days in the billing period up to the termination of the IMA.
CONSULTING FEES SCHEDULE
Alpha’s Consulting Fee usually are provided only upon request when services are needed outside the scope of our
standard wealth management service and will be determined on the nature of the services being provided and the
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complexity of each client’s circumstances. All fees are agreed upon prior to entering into a Consulting Services
Agreement with any client. The fee for such services is charged on an hourly basis at a rate of $500 per hour. Clients
will be notified before work is performed and fee is assessed. Generally, Consulting Fees are due and payable upon
completion of the services. There is no minimum fee for Consulting Services.
ITEM 6 – Performance-Based Fees and Side-By-Side Management
We do not charge performance-based fees nor do we supervise any persons that manage accounts that charge
performance-based fees. It is in our view that there exists a conflict of interest in performance-based fees as the
incentive to favor or take additional risk on these accounts would create a possible conflict.
ITEM 7 – Types of Clients
We provide services to the following types of clients:
Individuals
Families
Trusts
Pensions
Businesses/Companies
Foundations
Non-Profit Organizations
Retirement plans
Home Owner Associations
Our minimum assets under management (AUM) requirements for opening and maintaining an account are
$500,000.00. We may at our discretion, waive or modify the minimum AUM requirements.
ITEM 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Alpha Solutions Investment Advisors uses both fundamental and technical analysis to determine when to buy and sell
securities for our clients.
Fundamental analysis is the process of determining the intrinsic value of a security using many factors using a
company’s financial statements - such as sales growth, profit margin trends, cash flow generation, asset/liability ratios
to see if the figures currently are reflected in the valuation of the security that we want to buy or sell. For example: we
may buy a security if we determine that the fundamental trends which we analyze as being favorable have not yet
been reflected in the current stock price. Conversely, we may sell a security if we feel that the fundamentals have
been overly valued in the current price. It should be stressed that the accurate and timely analysis of fundamental
factors alone will not guarantee the appreciation of a security, nor would it avoid the risk of principal loss.
Fundamental analysis does not attempt to anticipate general market movements. This presents a potential risk, as the
price of a security can move up or down along with the overall market regardless of the economic and financial factors
considered in evaluating a security
Technical analysis involves the analysis of past market movements and the application of that analysis to the present
in an attempt to recognize recurring patterns of investor behavior and to predict future price movement. Charting and
cyclical analysis are types of technical analysis that we use. Charting involves the review of charts of market and
security activity in an attempt to identify when the market is moving up or down and to predict how long the trend
may last and when that trend might reverse. Cyclical analysis involves measuring the movements of a particular
security relative to the overall market in an attempt to predict the price movement of the security. Technical analysis
does not consider the underlying financial conditions of a security. This presents a risk in that a poorly-managed or
financially unsound investment may underperform regardless of market movement.
Using both fundamental and technical analysis, we develop many investment ideas internally through our Investment
Committee. The Committee analyzes and discusses economic conditions, demographic and macro trends, global
market conditions, and specific investment ideas and opportunities in all asset sectors. These discussions lead the
Committee to develop target asset allocation guidelines for all asset sectors and to strategically alter them over the
course of market and business cycles.
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Risk of Loss - There are inherent risks to investing in securities, including but not limited to:
Management Risks: Alpha applies its investment techniques and risk analyses in making investment decisions or
recommendations for its clients, but there can be no guarantee that they will produce the desired results. In addition,
there is no guarantee that a strategy based on historical information will produce the desired results in the future and,
if market dynamics change, the effectiveness of the strategy may be limited. Each strategy runs the risk that
investment techniques will fail to produce the desired results. There also can be no assurance that all of the key
personnel will continue to be associated with the firm for any length of time.
Investment Risks: Investments in securities, including ETFs and mutual funds and the securities that they in turn invest
in involve various risks, including those summarized below. In addition, each ETF and mutual fund has its own
investment style, which may involve risks different from those described below. Clients and prospective clients should
be aware that investing in securities involves risk of loss that clients should be prepared to bear.
Mutual Fund and/or ETF analysis: In cases where a client already owns a mutual fund or ETF, we look at the
experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has
demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the
underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying
investments held in other fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to
determine if they are continuing to follow their stated investment strategy.
A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee
future results. A manager who has been successful may not be able to replicate that success in the future. In addition,
as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may
purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that
a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the
holding(s) less suitable for the client’s portfolio.
ETF General Risks: ETFs in which the strategies may invest involve certain inherent risks generally associated with
investments in a portfolio of underlying securities, including the risk that the general level of the underlying security
prices may decline, thereby adversely affecting the value of each unit of the ETF. Moreover, an ETF may not fully
replicate the performance of its benchmark index because of the temporary unavailability of certain securities in the
secondary market or discrepancies between the ETF and the benchmark index with respect to the weighting of
securities or the number of securities held. Investing in ETFs carries the risk of capital loss. ETFs are not guaranteed or
insured by the FDIC or any other government agency. You can lose money investing in ETFs. ETFs in which the
strategies invest have their own fees and expenses as set forth in the ETF prospectuses. These fees and expenses lower
investment returns. Although ETFs themselves are generally classified as equities, the underlying holdings of ETFs can
include a variety of asset classes, including but not limited to equities, bonds, foreign currencies, physical commodities,
and derivatives. A full disclosure of the specific risks of ETFs is located in the respective prospectus of each fund. ETFs
may have exposure to derivative instruments, such as futures contracts, forward contracts, options, and swaps. There
is a risk that a derivative may not perform as expected. The main risk with derivatives is that some types can amplify a
gain or loss, potentially earning or losing substantially more money than the actual cost of the derivative; or that the
counterparty may fail to honor its contract terms, causing a loss for the ETF. Use of these instruments may also involve
certain costs and risks such as liquidity risk, interest rate risk, market risk, credit risk, management risk, and the risk
that an ETF could not close out a position when it would be most advantageous to do so.
Mutual Fund Risks: Mutual fund managers may base investment decisions for funds on historical information. There is
no guarantee that a strategy based on historical information will produce the desired results in the future. In addition,
if market dynamics change, the effectiveness of that kind of strategy may be limited. Either of these risks may cause
the investment strategy of a particular fund to underperform its benchmark or similar funds. Mutual funds in which
the strategies invest have their own fees and expenses as set forth in the fund prospectuses. These fees and expenses
lower investment returns. Mutual funds may have exposure to derivative instruments, such as futures contracts,
forward contracts, options, and swaps. There is a risk that a derivative may not perform as expected. The main risk of
derivatives is that some types of derivatives can amplify a gain or loss, potentially earning or losing substantially more
money than the actual cost of the derivative, or that the counterparty may fail to honor its contract terms, causing a
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loss for the fund. Use of these instruments may also involve certain costs and risks such as liquidity risk, interest rate
risk, market risk, credit risk, management risk, and the risk that a fund could not close out a position when it would be
most advantageous to do so. The value of mutual funds can be impacted by the movement of large positions in and
out of a particular fund. Alpha does not normally recommend/purchase mutual funds for our clients.
Market/Systemic Risks: Equity, fixed income, and other global capital markets rise and fall daily. The performance of
client investments is, to varying degrees, tied to these markets. When markets fall, the value of a client’s investments
will fluctuate, which means a client could lose money.
Asset Allocation/Strategy/Diversification Risks: Asset allocation decisions may result in more portfolio concentration
in a certain asset class or classes, which could reduce overall return if the concentrated assets underperform
expectations. The more aggressive the strategy selected, the more likely the portfolio will contain larger weights in
riskier asset classes, such as equities. The asset classes in which the strategies seek investment exposure can perform
differently from each other at any given time (as well as over the long term), so the strategy will be affected by its
allocation among the various asset classes. Depending on market conditions there may be times where diversified
strategies perform worse than less diversified strategies.
Geographic Concentration Risk: Portfolios concentrated in any one geographic region can be more susceptible to that
region’s political and economic risk. For example, a portfolio that is concentrated in the United States will be more
susceptible to the United States’ political and economic risk, as compared to a more globally diversified portfolio.
Trading/Liquidity Risks A particular investment may be difficult to purchase or sell or may become difficult to sell after
being purchased for a client account. Alpha may be unable to sell securities on behalf of a client at an advantageous
time and/or price due to then-existing trading market conditions. Large Investment Risks Clients may collectively
account for a large portion of the assets in certain ETFs or mutual funds. A decision by Alpha to buy or sell some or all
of a particular ETF or mutual fund where clients hold a significant portion of such may negatively impact the value of
that security.
Counterparty Risks: There may be a risk of an executing broker failing to deliver securities, Alpha will attempt to
mitigate trading counterparty risk through reviewing the broker’s track record. To the degree client accounts hold an
ETN, there is exposure to the credit risk of the issuer. ETFs may have some “product” or “structural” risk associated
with underlying derivatives, as they will sometimes provide market exposure through indirect means, like futures,
options, and forward contracts.
Custodian Risks: Schwab is a member of the Securities Investor Protection Corporation (“SIPC”). SIPC offers protection
of up to $500,000, including a $250,000 limit for cash, if a SIPC member brokerage firm fails. SIPC covers most
securities such as stocks, bonds, ETFs, and mutual funds, but does not protect against market loss.
Tax Risks: Clients should consult a professional tax advisor for help with their unique situations.
Underlying Securities Risk
Equity-Related Risks - General Risks: The prices of equity securities, including the value of ETFs or mutual funds that
invest in them, will rise and fall. These price movements may result from factors affecting individual companies,
industries, or the securities market as a whole. Individual companies may report poor results or be negatively affected
by industry and/or economic trends and developments. The prices of securities issued by such companies may suffer a
decline in response. In addition, the equity market tends to move in cycles, which may cause stock prices to fall over
short or extended periods of time.
Large- and Mid-Cap Risks: Large- and/or mid-cap U.S. stocks, along with mutual funds and ETFs that focus on large-
and/or mid-cap segments of the U.S. stock market bear the risk that they tend to go in and out of favor based on
market and economic conditions. However, stocks of mid-cap companies tend to be more volatile than those of
large-cap companies because mid-cap companies tend to be more susceptible to adverse business or economic events
than larger, more established companies. During a period when the large- and mid-cap segment of U.S. stocks falls
behind other types of investments—bonds or small-cap stocks, for instance—the performance of the portion of the
investment strategies invested in large- and/or mid-cap stocks may lag the performance of these other investments.
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Small-Cap and International Risks: Historically, small-cap and international stocks have been riskier than large- and
mid-cap U.S. stocks (also see “Foreign Investment-Related Risks” section below for additional information). During a
period when small-cap and/or international stocks fall behind other types of investments - large- and mid-cap U.S.
stocks, for instance - the performance of the portion of the investment strategies invested in small-cap or international
stocks may lag the performance of these other investments.
Fixed Income–Related Risks - General Risks: Bond markets rise and fall daily, and fixed income investments, which
generally also include instruments with variable or floating rates (including cash and cash-like investments), are subject
to various risks. As with any investment whose performance is tied to bond markets, the value of a fixed income
investment, ETF, or mutual fund will fluctuate, which means that the client could lose money.
Interest Rate Risks: When interest rates rise, bond prices usually fall, and with them the value of an ETF or mutual fund
holding the bonds. A decline in interest rates generally causes bond prices to rise, and with them potentially the value
of a bond fund or ETF, but could also hurt the performance of an ETF or mutual fund by lowering its yield (which could
increase reinvestment risk). The longer the duration of the investments held by an ETF or mutual fund, the more
sensitive to interest rate movements its value is likely to be.
Credit Risks: A decline in the credit quality of a fixed income investment could cause the value of a fixed income
security, ETF, or mutual fund to fall. The security, ETF, or mutual fund could lose value if the issuer or guarantor of an
investment fails to make timely principal or interest payments or otherwise honor its obligations. The emphasis of a
fixed income strategy on quality and preservation of capital also could cause a security, ETF, or mutual fund to
underperform certain other types of bond investments, particularly those that take greater maturity and credit risks.
High Yield Risks: Investments in ETFs or mutual funds that hold high yield securities and unrated securities of similar
credit quality (sometimes called junk bonds) are subject to greater levels of credit and liquidity risks. High yield
securities and the ETFs or mutual funds that invest in them may be considered speculative.
Government Securities Risks: Many U.S. government securities are not backed by the full faith and credit of the United
States government, which means they are neither issued nor guaranteed by the U.S. Treasury. Certain issuers of
securities, such as the Federal Home Loan Banks (“FHLB”), maintain limited lines of credit with the U.S. Treasury.
Securities issued by other issuers, such as the Federal Farm Credit Banks Funding Corporation (“FFCB”), are supported
solely by the credit of the issuer. There can be no assurance that the U.S. government will provide financial support to
securities of its agencies and instrumentalities if it is not obligated to do so under law.
Bank Loans: Investments in ETFs or mutual funds that hold bank loans are typically below investment grade credit
quality and may be subject to more credit risk, including the risk of nonpayment of principal or interest. Most bank
loans are floating rate, whose interest rates are tied to LIBOR or another short-term reference rate, so substantial
increases in interest rates may make it more difficult for issuers to service their debt and cause an increase in loan
defaults. Bank loans are typically secured by collateral posted by the issuer, or guarantees of its affiliates, the value of
which may decline and be insufficient to cover repayment of the loan. Many loans are relatively illiquid or are subject
to restrictions on resale and may be difficult to value, which could have an adverse impact on the ability of the ETF or
mutual fund to respond to changing market dynamics. Loans are also subject to maturity extension risk and
prepayment risk.
State and Regional Risks: To the extent that a security, ETF, or mutual fund invests in securities from a given state or
geographic region, its value and performance could be affected by local, state, and regional factors, including erosion
of the tax base and changes in the economic climate. National governmental actions, such as the elimination of
tax-exempt status, also could affect performance. In addition, an ETF or mutual fund may be more sensitive to adverse
economic, business, or political developments if a substantial portion of it is invested in municipal securities that are
financing similar projects.
Foreign Risks: Investments in ETFs or mutual funds that hold securities of foreign issuers or securities with credit or
liquidity enhancements provided by foreign entities may involve certain risks such as adverse changes in foreign
economic, political, regulatory, and other conditions; differing accounting, auditing, financial reporting, and legal
standards and practices; differing securities market structures; and higher transaction costs. In addition, sovereign risk,
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or the risk that a government may become unwilling or unable to meet its loan obligations or guarantees, could
increase the credit risk of financial institutions connected to that particular country.
Foreign Investment–Related Risks - General Risks: Investments in securities of foreign issuers or ETFs or mutual funds
that hold securities of foreign issuers may involve certain risks that are greater than those associated with investments
in securities of U.S. issuers. These include risks of adverse changes in foreign economic, political, regulatory, and other
conditions; changes in currency exchange rates or exchange control regulations (including limitations on currency
movements and exchanges); differing accounting, auditing, financial reporting, foreign taxes, and legal standards and
practices; differing securities market structures; differing trading and settlement practices; ownership restrictions; and
higher transaction costs.
Emerging Markets Risks: These and other risks (e.g., nationalization, expropriation, or other confiscation of assets of
foreign issuers) are greater for those securities, ETFs, or mutual funds investing in companies tied economically to
emerging countries, the economies of which tend to be more volatile than the economies of developed countries.
Frontier Markets Risks: The risks associated with investing in securities, ETFs, or mutual funds that hold foreign or
emerging markets generally are magnified in frontier markets, also known as “next emerging” markets. Some frontier
markets may operate
in politically unstable regions of the world and may be subject to additional
geopolitical/disruption of markets risks.
Geopolitical/Disruption of Markets Risks: Geopolitical events may adversely affect global economies and markets and
thereby decrease the value of and/or the ease of trading those securities, ETFs, or mutual funds invested in those
affected markets. Those events as well as other changes in foreign and domestic economic and political conditions
could adversely affect the value of the strategy’s investments.
Currency Risks: Fluctuations in exchange rates may adversely affect the value of ETFs or mutual funds that hold foreign
currency holdings and investments denominated in foreign currencies.
Risks Related to Other Asset Classes
Commodities Risks: Commodities involve unique risks that may be distinct from those that affect stocks and bonds,
including but not limited to worldwide supply and demand factors, weather conditions, currency movements, and
international government policies regarding commodity reserves and choice of currency for commodity pricing.
Commodities investments may also involve unique risks inherent to investing in derivatives which may include basis,
roll, liquidity, and regulatory risks. A detailed explanation of the risks is available in the prospectus of the respective
commodity fund. Commodity pools may be subject to different regulatory requirements than traditional funds
governed by the Investment Company Act of 1940.
Hard Assets Risks: The production and distribution of hard assets, such as precious metals, oil and gas, real estate,
and/or agricultural commodities may be affected by geopolitical and environmental factors and are cyclical in nature.
During periods of economic or financial instability, hard asset securities and other instruments may be subject to broad
price fluctuations, reflecting volatility of energy and basic materials prices and possible instability of supply of various
hard assets. Hard asset securities, hard asset companies, and other instruments may also experience greater price
fluctuations than the relevant hard asset. Therefore, the return on hard asset securities may deviate from that of the
hard asset itself.
Real Estate Risks: Real estate–related investments (and the ETFs or mutual funds that hold them) may be adversely
affected by factors affecting the real estate industry, which may include changes in interest rates and social and
economic trends. Real Estate Investment Trusts (“REITs”) may also be subject to the risk of fluctuations in income from
underlying real estate assets, poor performance by the REIT’s manager, prepayments and defaults by borrowers,
adverse changes in tax laws, and, with respect to U.S. REITs, their failure to qualify for the special tax treatment
granted to REITs under the Internal Revenue Code of 1986 and/or to maintain exempt status under the Investment
Company Act of 1940.
Risks for all forms of analysis: Our securities analysis methods rely on the assumption that the companies whose
securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of
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information about these securities, are providing accurate and unbiased data. While we are alert to indications that
data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading
information.
Other risks may include inflation, in which the appreciation in the security does not keep pace with the general cost of
living, or opportunity risk in which appreciation in other securities exceed that of the investment one chooses.
Limitations of Disclosure: The foregoing list of risks does not purport to be a complete enumeration or explanation of
the risks involved in Alpha’s Strategies. As the strategies develop and change over time, clients and investors may be
subject to additional and different risk factors. No assurance can be made that profits will be achieved or that
substantial losses will not be incurred.
INVESTMENT STRATEGIES
We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs
of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other
considerations:
Long-term purchases: We purchase securities with the idea of holding them in the client's account for a year or longer.
Typically we employ this strategy when:
• we believe the securities to be currently undervalued, and/or
• we want exposure to a particular asset class over time, regardless of the current projection
for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take
advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security
may decline sharply in value before we make the decision to sell.
Short-term purchases: Alpha may for specific clients and on certain occasions employ the use of short-term trading
strategies. When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short
time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result
in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price
swing not materialize; we are then left with the option of having a long-term investment in a security that was
designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent
trading than does a longer-term strategy, and may result in increased brokerage and other transaction-related costs, as
well as less favorable tax treatment of short-term capital gains.
Stop loss Orders: Alpha may at times employ the use of stop loss orders on certain stocks in a clients’ portfolio in an
effort to mitigate significant losses. These stop loss orders are placed on shares of companies the firm believes would
lose value in difficult economic conditions. Stop loss orders may not be placed on certain companies in the consumer
staples, healthcare and utility sectors given that they have historically fared better in difficult economic climates.
Though stop loss orders can be effective in a market falling at a normal pace, they can pose a risk if markets or
individual stocks fell dramatically within a very short period of time. Once a stop loss order is executed a market order
is sent to the exchange to sell the shares at the current market price. The actual sale price, in a fast moving market,
may be less or more than the stop loss order price. Clients may direct Alpha not to employ the use of stop loss orders.
Selling Stock Short: Alpha rarely employs any strategies of selling stocks short.
Asset Allocation: In implementing our clients’ investment strategy, we begin by attempting to identify an appropriate
ratio of equities, fixed-income and cash (i.e. “asset allocation”) suitable to the client’s investment goals and risk
tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security,
industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due
to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals.
Margin: We do not use margin transactions as an investment strategy. However, we may recommend, where
appropriate, that a client establish a margin account with the client’s broker. In this situation, if we are selling one stock
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and purchasing another stock with the proceeds, we can use the margin account to make certain that you are not left
out of the purchase if we have difficulty completing the sale.
RISK OF LOSS
Securities investments are not guaranteed and you may lose money on your investments. All investors should be
prepared to bear these risks. We ask that you work with us to help us understand your overall tolerance for risk.
ITEM 9 – Disciplinary Information
Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that
would be material in your evaluation of us. Alpha Solutions Investment Advisors, the firm and its principals’ and
employees have NO past or pending disciplinary or legal events to report.
ITEM 10 – Other Financial Industry Activities and Affiliations
Alpha Solutions Investment Advisors is not registered, nor do we have a pending application as a securities
broker-dealer. We are also not registered and do not have an application pending as a futures commission merchant,
commodity pool operator, or commodity trading advisor.
ITEM 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
We are committed to the highest standards of moral and ethical conduct based on the fundamental principles of
transparency, integrity, honesty and trust. The standards set forth within our Code of Conduct and Ethics (“CCE”) are
an essential ingredient not only for the success of Alpha Solutions Investment Advisors and its subsidiaries and
affiliates, but also to maintain the trust and confidence of clients.
There is a long-standing recognition of the potential conflicts of interest that may arise in connection with the personal
trading activities of investment personnel and their clients. Federal and state securities laws govern the conduct of
individuals associated with investment advisers and registered investment companies. Such entities are required to
adopt a Code of Ethics containing provisions designed to prevent improper personal trading by their personnel. The
Alpha Solutions Investment Advisors - CCE applies to all partners, directors, officers, employees and any and all “Access
Persons”.
We permit our employees to engage in personal securities transactions, but to avoid any potential conflicts of interests
involving personal trades, we have adopted specific rules within our CCE to address issues such as insider trading, front
running, shadowing and selling away. We have a significant responsibility and an explicit fiduciary duty which requires
our employees to act solely for the benefit of our clients. It is also in the best interest of Alpha Solutions Investment
Advisors as a professional advisory organization to avoid potential conflicts of interest, or even the appearance of such
conflicts. If there are any occasions when potential conflict exists – it must be clearly and promptly disclosed to the
client, and if such conflict is serious in nature to the clients’ best interest, Alpha Solutions Investment Advisors and its
employees should abstain from further action. Our long-term business interests are best served by the strict and
absolute adherence to the principle that “clients’ interests come first”.
Because of the nature of our business, employees may at times be exposed to information which constitutes “inside
information” or material, non-public information. Federal securities law prohibits the use of such information for
financial benefit. Our goal is to impose restrictions whenever possible consistent with protecting our clients and Alpha
Solutions Investment Advisors from the damage that could result from a violation of the securities laws or from real or
apparent conflicts of interest. While it is impossible to define all situations which might pose such a risk, our CCE is
designed to address those circumstances where such risks are likely to arise. A copy of our Code of Conduct and Ethics
is available at no charge upon request.
ITEM 12 – Brokerage Practices
As previously addressed, Alpha Solutions Investment Advisors has no affiliation with a securities broker/dealer. Our
clients have full discretion in selecting a broker/dealer/custodian for their transactions and determining the
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reasonableness of the fees/commissions they may encounter. In certain circumstances, if we are asked by a client to
recommend a broker/dealer/custodian – having best execution is the primary factor that we focus on in choosing a
broker. “Soft Dollar Benefits” (research or other products or services from a broker/dealer) at times creates a conflict
of interest with the interest of a client. We do not engage in any types of “soft dollar” activities for research, products
or other services. Our firm is not affiliated or associated with any broker-dealer firm and we do not receive any
incentive/compensation or client referrals from any brokers we select.
Alpha typically uses the brokerage and platform services of Schwab Institutional, a division of Charles Schwab & Co.,
Inc. ("Schwab") for its advisory accounts. Schwab is a FINRA-member broker-dealer and SIPC member. Schwab provides
Alpha with access to their institutional trading and custody services. There is no direct link between our firm's use of
these brokerage and platform services and the investment advice we give to our clients. However, we receive
non-economic benefits through our participation in this platform that are typically not available to Schwab retail
investors. These platform services are not contingent upon our firm committing to Schwab any specific amount of
business (assets in custody or trading commissions). Schwab’s brokerage services include the execution of securities
transactions, custody, research, and access to mutual funds and other investments that are otherwise generally
available only to institutional investors or would require a significantly higher minimum initial investment.
For our client accounts maintained in their custody, Schwab generally does not charge separately for custody services
but are compensated by account holders through commissions and other transaction-related fees for securities trades
that are executed through them or that settle into the accounts. Schwab also makes available other products and
services that benefit Alpha but may not directly benefit our clients’ accounts. Many of these products and services may
be used to service all or some substantial number of our client accounts, including accounts not maintained at Schwab.
These products and services that assist us in managing and administering our clients’ accounts include software and
other technology that:
• provide access to client account data (such as trade confirmations and account statements);
•
facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide research, pricing and other market data;
•
•
facilitate payment of our fees from clients’ accounts; and
assist with back-office functions, recordkeeping and client reporting.
Schwab also offers other services intended to help us manage and further develop our business enterprise. These
services may include:
compliance, legal and business consulting;
•
• publications and conferences on practice management and business succession; and
SUMMARY OF TRADE AGGREGATION POLICY
Alpha may (but is not obligated to) aggregate (i.e., block) trades where possible and when advantageous to clients. This
blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client
accounts. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average
share price. Alpha may typically aggregate trades among clients whose accounts can be traded at a given broker.
Alpha’s block trading policy and procedures are as follows:
1. Trades may be aggregated where it is more timely, efficient and equitable to those clients participating in a
trade in the same security.
2. Transactions for any client account may not be aggregated for execution if the practice is prohibited by or
inconsistent with the client's advisory agreement with Alpha, or our firm's order allocation policy.
3. The portfolio manager must determine that the purchase or sale of the particular security involved is
appropriate for the client and consistent with the client's investment objectives and with any investment
guidelines or restrictions applicable to the client's account.
4. The portfolio manager must reasonably believe that the order aggregation will enable Alpha to seek best
execution for each client participating in the aggregated order. This requires a good faith judgment at the time
the order is placed for the execution. It does not mean that the determination made in advance of the
transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best
execution includes the duty to seek the best quality of execution, as well as the best net price.
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5. Aggregated (block) trades are sent as market orders (not limit orders) and are always filled regardless of price.
However, adjustments to the allocations may be made due to tax consideration, to avoid having odd amounts
of shares held in any client account.
7.
8.
6. Generally, each client that participates in the aggregated order must do so at the average price for all separate
transactions made to fill the order. Each participating account has its own set commission costs based on their
arrangement with their broker. Transaction costs may be charged as a fixed, per-trade fee or a fee based on
the number of shares traded for each client (depending upon the individual client’s agreement with the
applicable custodian/broker).
In daily trading, a group of client trades are entered into a blotter, based on a position size determined by
client assets and tactical weight. For example, a client with $1M assets under management (AUM) who is 80%
stock will have $20,000 positions (based on 40 positions per portfolio). Once most or all of that day’s trades
are entered, the “like” trades (same position, same broker) are merged together and sent to each respective
broker as a block trade in our master account. Once the trade fills, the pre-allocation file, created when the
trades are merged, is audited to ensure that no negative balances have been created. On the rare occasion
that this occurs, the smallest number of shares required to cover the negative balance may be moved from
the negative account(s) to a different client account where the small amount will not substantially affect the
receiving client’s asset allocation. Where possible, we attempt to move the shares into another account
owned by the same client. Once this audit is complete, the allocation file is sent to the broker to allocate.
Trading in this manner ensures that all included clients receive the identical fill price per share. Fill price may
vary among brokers.
In the rare event that Alpha buys or sells a security that lacks sufficient volume to efficiently sell a block of
stock at the current market price, block orders will be executed in phases and possibly over days in an effort
to obtain the best pricing. This can result in segments of clients getting different pricing for securities. We use
several methods to achieve the goal of best pricing in a manner that does not favor one client over another
which may include: 1) random selection of accounts; 2) client tactical weighting considerations (ie. group by
client stock exposure requirements); 3) accounts taxable status; or 4) alphabetical order.
9. No client or account will be favored over another.
TRADE ERROR POLICY
Alpha requires that its personnel carefully implement investment management decisions. It is the Firm’s policy to
identify and correct trade errors as soon as possible without creating disadvantage to the client. When this occurs, the
Firm may place a correcting trade with the broker-dealer which has custody of the account. To the extent that the
trading error results in any gain, the profit shall remain in the client’s account, and any losses resulting from the Firm’s
trade errors shall be promptly reimbursed to the client’s account. Nevertheless, if a trade error occurs, it is Alpha’s
policy that the error be corrected as soon as possible and in such a manner that the affected client is not
disadvantaged and bears no loss. Alpha’s policy prohibits its staff from requesting a broker-dealer to accept financial
responsibility for a trade error caused by Alpha’s personnel in exchange for the promise of future compensation
through commissions.
ITEM 13 – Review of Accounts
The Alpha Investment Committee meets regularly and discusses current news and market conditions that assists them
in outlining potential risks and opportunities – all with our clients’ long term needs as the focal point. While the
underlying securities within client accounts are continually monitored, these accounts are reviewed on at least an
annual basis. Each account is reviewed every 12 months to determine if the account is within the parameters of the
Investment Policy Statement. Our client accounts are reviewed in the context of each client's stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's
individual circumstances, or the market, political or economic environment. Account reviews would typically be
performed by Alpha Portfolio Managers and Relationship Managers that generally focus on the client’s personal
financial situation, liquidity needs, and comfort with risk level; a review of account restrictions; an overview of the
client’s current portfolio; and questions the client may have on their account and strategies. Anthony Sam the Chief
Compliance Officer also conducts this review at least annually.
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In addition to the monthly statements and confirmations of transactions that clients may receive or electronically
download from their broker-dealer/custodian, we may, upon request by the client, provide quarterly reports
summarizing account performance, balances and holdings.
ITEM 14 – Client Referrals and Other Compensation
Alpha Solutions Investment Advisors does not pay any fees for client referrals. Alpha Solutions Investment Advisors
may at certain times receive compensation under the following circumstances:
a. Non-advisory fees associated with business and management consulting services.
b. Solicitors/Introduction fees associated with the introduction of non-clients to select financial services
firms.
ITEM 15 – Custody
Alpha will not take custody of client cash, bank accounts, or securities. A qualified unaffiliated custodian such as
banks, brokerage firms, investment companies and mutual fund companies will be approved and chosen by the client
to maintain their respective cash, bank accounts and securities. The client will receive account statements directly
from their service provider, typically on a monthly or quarterly basis or as account transactions occur. It is the client’s
responsibility to carefully review these statements.
Alpha can access many client accounts through the firm’s ability to debit quarterly advisory fees. For this reason, Alpha
is considered to have limited custody of client assets. As part of this billing process, the client's custodian is advised of
the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required
to send to the client a statement showing all transactions within the account during the reporting period. Because the
custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their
custodial statements to verify the accuracy of the calculation, among other things. Clients should compare those
statements to any account information or quarterly reports provided by Alpha and contact us directly if they believe
that there may be an error in their statements.
Alpha may also be considered to have custody of client assets on a limited basis, because we accept and process
Standing Letters of Authorization from our clients which allows us to facilitate the transfer of funds to other accounts
owned by the clients or to third parties identified and approved by our clients. At all times we intend to comply with
the SEC’s No-Action Letter Dated 02/21/2017 to avoid the surprise audit requirements of the SEC’s Custody Rule.
We will not ask for, nor accept, any of our clients account access information, such as username and/or password. We
will not act as a trustee for, nor have full power of attorney over a client account.
ITEM 16 – Investment Discretion
Clients retain our services to provide discretionary portfolio management services. Where we have been provided
investment discretion, we place trades in a client’s account without obtaining specific client permission prior to each
trade. Our discretionary authority includes the ability to do the following at any time without contacting the client:
• Determine the types of securities to buy or sell; and/or
• Determine the amounts of the securities to buy or sell
Clients give us discretionary authority when they sign a discretionary advisory agreement and limited power of
attorney with our firm, and may limit this authority by giving us written instructions. Clients may also
change/amend/cancel such limitations by once again providing us with written instructions. Reasonable restrictions
on our investment discretion can be imposed by the client through the Investment Policy Statement as long as the
restrictions fit within our investment strategies.
ITEM 17 – Voting Client Securities
Alpha Solution Investment Advisors does not vote on client securities. The client will directly receive their proxies and
other solicitations directly from the custodian or transfer agent for their investments, and it is the client's responsibility
to vote the proxies for any and or all securities in their portfolio. Our clients can contact us with questions about a
particular solicitation - a reasonable amount of time to research and analyze the specific situation should be allocated
prior to specific reply dates.
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ITEM 18 – Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $500 per client more than six months in
advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm that
maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is
reasonably likely to impair our ability to meet our contractual obligations. Alpha has no additional financial
circumstances to report and has never been the subject of a bankruptcy petition. Due to the nature of the services that
we provide to our clients, an audited balance sheet is not required, nor included in this disclosure document. Alpha
Solutions Investment Advisors does not have any financial conditions that require further disclosure.
ITEM 19 – Requirements for State Registered Investment Advisors
Alpha Solutions Investment Advisors is registered with the Securities and Exchange Commission (“SEC”), therefore, this
ITEM 19 is not applicable.
ITEM 20 – Additional Information
Cybersecurity Risks and Incidents. Protecting the Firm, its employees and clients from cybercriminals is critical to
Alpha Solutions Investment Advisors. As part of the Firm’s Cyber Security policies and procedures and risk
management, the Firm has established and adopted the Alpha Cyber Security Policy which include elements such as:
Risk assessment; user security and access to protected data, network equipment and devices; protection of data;
threat and vulnerability management.
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Alpha Solutions Investment Advisors, LLC
REGISTERED INVESTMENT ADVISORS
Form ADV Part 2A
(Appendix 1, Wrap Fee Program Brochure)
Alpha Solutions Investment Advisors does not sponsor,
or participate in wrap fee programs
This brochure provides information about the qualifications and business practices of Alpha Solutions Investment Advisors. If you
have any questions about the contents of this brochure, please contact us at 415-882-7088 and/or email to
anthony@asiadvisors.com. Additional information about Alpha Solutions Investment Advisors is also available on the SEC’s website
at www.adviserinfo.sec.gov.
Disclaimer: The information in this brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or
by any state securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of skill or training.
Brochure Rule:
Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at the
time it enters into an advisory contract with the client. The rule does not require advisors to deliver brochures to certain advisory
clients receiving only impersonal investment advice or to clients that are investment companies registered under the Investment
Company Act of 1940 (“Company Act”). Annual Delivery – Advisors must annually provide to each client to whom they must deliver
a brochure either (a) a copy of the current (updated) brochure that includes or is accompanied by the summary of material changes;
or (b) a summary of material changes that includes an offer to provide a copy of the current brochure. As proposed each adviser
must make this annual delivery no later than 120 days after the end of its fiscal year. Advisors may deliver a brochure and summary
of material changes or summary of material changes, along with an offer to provide the brochure to clients electronically in
accordance with the Commission’s guidelines regarding electronic delivery of information.
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Alpha Solutions Investment Advisors, LLC
REGISTERED INVESTMENT ADVISORS
Form ADV Part 2B
(Brochure Supplement)
Anthony Sam
CRD 5891496
information about Anthony Sam
This brochure supplement provides information about Anthony Sam that supplements the Alpha Solutions Investment Advisors
brochure. You should have received a copy of that brochure. Please contact Anthony Sam at 415-882-7088 and/or email to
anthony@asiadvisors.com if you did not receive Alpha Solutions Investment Advisors’ brochure or if you have any questions about
the contents of this supplement. Additional
is available on the SEC’s website at
www.adviserinfo.sec.gov.
Disclaimer: The information in this brochure has not been approved or verified by the Securities and Exchange Commission (SEC) or
by any state securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of skill or training.
Brochure Rule:
Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at the
time it enters into an advisory contract with the client. The rule does not require advisors to deliver brochures to certain advisory
clients receiving only impersonal investment advice or to clients that are investment companies registered under the Investment
Company Act of 1940 (“Company Act”). Annual Delivery – Advisors must annually provide to each client to whom they must deliver
a brochure either (a) a copy of the current (updated) brochure that includes or is accompanied by the summary of material changes;
or (b) a summary of material changes that includes an offer to provide a copy of the current brochure. As proposed each adviser
must make this annual delivery no later than 120 days after the end of its fiscal year. Advisors may deliver a brochure and summary
of material changes or summary of material changes, along with an offer to provide the brochure to clients electronically in
accordance with the Commission’s guidelines regarding electronic delivery of information.
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Anthony Sam
Item 1 – Cover Page
See previous page.
Item 2 – Educational Background and Business Experience
Anthony Sam was born in 1958 and has successfully passed the Series 65 test to be an Investment Advisor
Representative and is the C.E.O. and founder of Alpha Solutions Investment Advisors, LLC. Mr. Sam has always been an
entrepreneur. He has been involved with start-up businesses in fields of consumer electronics, medical devices,
telecommunications, real estate, education, brewery, advertising, marketing, import/export and automotive related
industries. Mr. Sam also held the position as Chief Financial Officer of xtronx, inc. an outdoor advertising company that
managed Digital Video Billboards in Times Square NYC for CBS Television and Macy’s. Mr. Sam attended San Francisco
State College in San Francisco Ca. but left prior to achieving a degree to pursue entrepreneurial business interests.
Item 3 – Disciplinary Information
Anthony Sam has not been nor is currently the subject of any reportable legal or disciplinary event.
Item 4 – Other Business Activities
Mr. Sam is not registered, nor does he have a pending application to register, as a broker-dealer, registered
representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”),
commodity trading advisor (“CTA”), or an associated person of an FCM, CPO or CTA.
Mr. Sam currently holds a position as a member of the Board of Directors for the following companies:
xtronx, inc, (advertising)
WSJ Management, LLC, (real estate)
Valstock Management, LLC, (real estate)
Quantlux Technologies, LLC, (algorithmic trading platform)
Item 5 – Additional Compensation
Mr. Sam has no reportable “Additional Compensation”.
Item 6 – Supervision
Anthony Sam will be supervised by Robert Moses, Jr. who can be reached at 215-259-8398. Mr. Sam and Mr. Moses will
conduct annual meetings to review existing client activities and compliance related issues.
Item 7 – Requirements for State-Registered Advisers
Anthony Sam has no material facts to disclose regarding events listed in Item 3 of Part 2B (Disciplinary Information)
and has not been the subject of a bankruptcy petition.
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Alpha Solutions Investment Advisors, LLC
REGISTERED INVESTMENT ADVISORS
Form ADV Part 2B
(Brochure Supplement)
Robert N. Moses, Jr. CFA
CRD # 1870775
This brochure supplement provides information about Robert Moses, Jr. that supplements the Alpha Solutions Investment
Advisors brochure. You should have received a copy of that brochure. Please contact Anthony Sam at 415-882-7088 and/or
email to anthony@asiadvisors.com if you did not receive Alpha Solutions Investment Advisors’ brochure or if you have any
questions about the contents of this supplement. Additional information about Robert Moses, Jr. is available on the SEC’s
website at www.adviserinfo.sec.gov.
Disclaimer: The information in this brochure has not been approved or verified by the Securities and Exchange Commission
(SEC) or by any state securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of
skill or training.
Brochure Rule:
Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at
the time it enters into an advisory contract with the client. The rule does not require advisors to deliver brochures to certain
advisory clients receiving only impersonal investment advice or to clients that are investment companies registered under the
Investment Company Act of 1940 (“Company Act”). Annual Delivery – Advisors must annually provide tow each client to whom
they must deliver a brochure either (a) a copy of the current (updated) brochure that includes or is accompanied by the
summary of material changes; or (b) a summary of material changes that includes an offer to provide a copy of the current
brochure. As proposed each adviser must make this annual delivery no later than 120 days after the end of its fiscal year.
Advisors may deliver a brochure and summary of material changes or summary of material changes, along with an offer to
provide the brochure to clients electronically in accordance with the Commission’s guidelines regarding electronic delivery of
information.
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©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Robert N. Moses Jr. CFA
Item 1 – Cover Page
See previous page.
Item 2 – Educational Background and Business Experience
Robert is a highly qualified and success driven investment professional. He has served as a senior analyst at
BlackRock, Inc, (formerly Merrill Lynch Investment Managers - MLIM) for a product with $9 billion in equity assets.
Robert also worked as a research analyst for MLIM’s separate accounts business, where he provided in-depth
coverage of the healthcare and financial sectors. Before joining MLIM in 1998, Robert spent five years in the
Investment Research Department at The Bank of New York where he covered the healthcare and financial sectors.
He began his career as a Senior Associate with AMAS Securities, Inc., eventually managing portfolios for high-net
worth individuals. Robert is a graduate of Carnegie Mellon University where he earned a B.S. in Managerial
Economics and was awarded the Chartered Financial Analyst designation in 1998.
The Chartered Financial Analyst® (CFA) credential is the most respected and recognized investment management
designation in the world. To earn the CFA charter candidates must pass each of three comprehensive six-hour
exams covering a broad range of practical portfolio management and advanced investment analysis skills, possess a
bachelor’s degree from an accredited institution (or have equivalent education or work experience), have 48
months of qualified work experience in the investment decision-making process, and become a regular member of
the CFA Institute plus join a local CFA member society. Charter holders are also obligated to adhere and attest
annual compliance to the CFA Institute’s Code of Ethics and Standards of Professional Conduct, considered by the
Institute to be the ethical benchmark for investment professionals around the globe.
Item 3 – Disciplinary Information
Robert N. Moses, Jr. has not been nor is currently the subject of any reportable legal or disciplinary event.
Item 4 – Other Business Activities
Mr. Moses is not registered, nor does he have a pending application to register, as a broker-dealer, registered
representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”),
commodity trading advisor (“CTA”), or an associated person of an FCM, CPO or CTA.
Item 5 – Additional Compensation
In addition to providing Investment Advice, Robert N. Moses, Jr. is also involved in the following business activities:
•
ShopRite of Hunterdon County – 40 hours per week CGO Coordinator
Item 6 – Supervision
Robert N. Moses, Jr. will be supervised by Anthony Sam who can be reached at 702-350-2038. Mr. Moses and Mr.
Sam will conduct annual meetings to review existing client activities and compliance related issues.
Item 7 – Requirements for State-Registered Advisers
Robert N. Moses, Jr. has no material facts to disclose regarding events listed in Item 3 of Part 2B (Disciplinary
Information) and has not been the subject of a bankruptcy petition.
September 2025
Form ADV Part 2B - Version 2025-09
Page | 4
©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Alpha Solutions Investment Advisors, LLC
REGISTERED INVESTMENT ADVISORS
Form ADV Part 2B
(Brochure Supplement)
Nathalie Botros Lai
CRD 8040034
This brochure supplement provides information about Nathalie Botros Lai that supplements the Alpha Solutions Investment
Advisors brochure. You should have received a copy of that brochure. Please contact Anthony Sam at 415-882-7088 and/or
email to anthony@asiadvisors.com if you did not receive Alpha Solutions Investment Advisors’ brochure or if you have any
questions about the contents of this supplement. Additional information about Robert Moses, Jr. is available on the SEC’s
website at www.adviserinfo.sec.gov.
Disclaimer: The information in this brochure has not been approved or verified by the Securities and Exchange Commission
(SEC) or by any state securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of
skill or training.
Brochure Rule:
Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at
the time it enters into an advisory contract with the client. The rule does not require advisors to deliver brochures to certain
advisory clients receiving only impersonal investment advice or to clients that are investment companies registered under the
Investment Company Act of 1940 (“Company Act”). Annual Delivery – Advisors must annually provide to each client to whom
they must deliver a brochure either (a) a copy of the current (updated) brochure that includes or is accompanied by the
summary of material changes; or (b) a summary of material changes that includes an offer to provide a copy of the current
brochure. As proposed each adviser must make this annual delivery no later than 120 days after the end of its fiscal year.
Advisors may deliver a brochure and summary of material changes or summary of material changes, along with an offer to
provide the brochure to clients electronically in accordance with the Commission’s guidelines regarding electronic delivery of
information.
September 2025
Form ADV Part 2B - Version 2025-09
Page | 5
©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Nathalie Botros Lai
Item 1 – Cover Page
See previous page.
Item 2 – Educational Background and Business Experience
Nathalie Botros Lai is a registered investment advisor with a unique and multifaceted background. She holds a
Bachelor of Science degree with a minor in Pre-Law from the University of the Pacific, a Doctorate of Dental
Surgery from the University of the Pacific Dugoni School of Dentistry, and earned her registration by successfully
completing the FINRA Series 65. Having lived across the country, Nathalie grew up in Chicago and has spent the
past eight years in San Francisco, gaining a broad perspective that informs her approach to investment advising.
Her passion for guiding individuals and families through the complexities of financial planning drives her
commitment to delivering thoughtful, strategic advice tailored to each client’s needs. With a foundation of rigorous
education and a dedication to excellence, Nathalie brings a professional and personalized touch to every aspect of
her work.
Item 3 – Disciplinary Information
Nathalie Botros Lai has not been nor is currently the subject of any reportable legal or disciplinary event.
Item 4 – Other Business Activities
Nathalie Botros Lai, is also a licensed general dentist practicing in San Francisco, California. Her dental practice is separate
from her investment advisory services and does not create a conflict of interest.
Item 5 – Additional Compensation
In addition to providing Investment Advice, Nathalie Botros Lai is also involved in the following business activities:
Nathalie Botros Lai receives compensation from her general dentistry practice in San Francisco, California. However,
she does not receive any additional compensation for providing investment advisory services beyond what is
disclosed in her Form ADV Part 2A.
Item 6 – Supervision
Nathalie Botros Lai will be supervised by Anthony Sam who can be reached at 702-350-2038. Mrs. Lai and Mr. Sam
will conduct annual meetings to review existing client activities and compliance related issues.
Item 7 – Requirements for State-Registered Advisers
Nathalie Botros Lai has no material facts to disclose regarding events listed in Item 3 of Part 2B (Disciplinary
Information) and has not been the subject of a bankruptcy petition.
September 2025
Form ADV Part 2B - Version 2025-09
Page | 6
©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Alpha Solutions Investment Advisors, LLC
REGISTERED INVESTMENT ADVISORS
Form ADV Part 2B
(Brochure Supplement)
Jordan Sam
CRD 8090096
This brochure supplement provides information about Jordan Sam that supplements the Alpha Solutions Investment Advisors
brochure. You should have received a copy of that brochure. Please contact Anthony Sam at 415-882-7088 and/or email to
anthony@asiadvisors.com if you did not receive Alpha Solutions Investment Advisors’ brochure or if you have any questions
about the contents of this supplement. Additional information about Jordan Sam is available on the SEC’s website at
www.adviserinfo.sec.gov.
Disclaimer: The information in this brochure has not been approved or verified by the Securities and Exchange Commission
(SEC) or by any state securities authority. Registration as a “Registered Investment Advisor” does not imply a certain level of
skill or training.
Brochure Rule:
Initial Delivery – Rule 204-3(b), as amended, requires an adviser to deliver a current brochure before or at
the time it enters into an advisory contract with the client. The rule does not require advisors to deliver brochures to certain
advisory clients receiving only impersonal investment advice or to clients that are investment companies registered under the
Investment Company Act of 1940 (“Company Act”). Annual Delivery – Advisors must annually provide to each client to whom
they must deliver a brochure either (a) a copy of the current (updated) brochure that includes or is accompanied by the
summary of material changes; or (b) a summary of material changes that includes an offer to provide a copy of the current
brochure. As proposed each adviser must make this annual delivery no later than 120 days after the end of its fiscal year.
Advisors may deliver a brochure and summary of material changes or summary of material changes, along with an offer to
provide the brochure to clients electronically in accordance with the Commission’s guidelines regarding electronic delivery of
information.
September 2025
Form ADV Part 2B - Version 2025-09
Page | 7
©2025 Alpha Solutions Investment Advisors, LLC All rights reserved
Jordan Sam
Item 1 – Cover Page
See previous page.
Item 2 – Educational Background and Business Experience
Jordan Sam is a registered investment advisor with a background that blends technical expertise and business
insight. He earned a Bachelor of Science degree in Computer Science with a concentration in Business Applications
from the University of California, Riverside, and earned his registration by successfully passing the FINRA Series 65
exam. With a foundation in data analysis, financial evaluation, and strategic decision-making, Jordan has
experience applying quantitative methods to support organizational goals. At UCR’s The Well, he led data and
metrics efforts to improve operational efficiency and resource management. He also served as a peer mentor at
the Bourns College of Engineering, helping students navigate academic and professional planning. Jordan brings an
analytical, detail-oriented approach to financial advising, with a strong commitment to helping clients make
informed, confident decisions about their financial futures
Item 3 – Disciplinary Information
Jordan Sam has not nor been currently the subject of any reportable legal or disciplinary event.
Item 4 – Other Business Activities
Jordan Sam is not registered, nor does he have a pending application to register, as a broker-dealer, registered
representative of a broker-dealer, futures commission merchant (“FCM”), commodity pool operator (“CPO”),
commodity trading advisor (“CTA”), or an associated person of an FCM, CPO or CTA.
Item 5 – Additional Compensation
Jordan Sam does not receive any additional compensation for providing investment advisory services beyond what
is disclosed in his Form ADV Part 2A.
Item 6 – Supervision
Jordan Sam will be supervised by Anthony Sam who can be reached at 702-350-2038. Jordan and Anthony will
conduct annual meetings to review existing client activities and compliance related issues.
Item 7 – Requirements for State-Registered Advisers
Jordan Sam has no material facts to disclose regarding events listed in Item 3 of Part 2B (Disciplinary Information)
and has not been the subject of a bankruptcy petition.
September 2025
Form ADV Part 2B - Version 2025-09
Page | 8
©2025 Alpha Solutions Investment Advisors, LLC All rights reserved