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MANAGED ASSETS PROGRAM BROCHURE - MARCH 30, 2026
Level Four Advisory Services (CRD 134086), brochure dated March 30, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
FORM ADV PART 2A APPENDIX 1 – MANAGED ASSETS PROGRAM
WRAP FEE BROCHURE
Item 1 – Cover Page
Level Four Advisory Services, LLC
12400 Coit Road, Suite 700
Dallas, TX 75251
866-834-1040
http://www.levelfouradvisors.com
Date of Brochure: March 30, 2026
This brochure provides information about the qualifications and investment advisory business practices of Level Four
Advisory Services, LLC. If you have any questions about the contents of this brochure, please contact us at 866-834-1040.
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.
Additional information about our investment advisory business is also available on the Internet at www.adviserinfo.sec.gov.
You can view our information on this website by searching for “Level Four Advisory Services, LLC.” You can also search
using the Firm’s CRD number. The CRD number for the Firm is 134086.
Registration as an investment adviser does not imply a certain level of skill or training.
Item 2 – Material Changes
Since filing the firm’s most recent amendment to this brochure on March 28, 2025, we have made the following changes:
Item 6 – Portfolio Manager Selection and Evaluation. This section has been updated to reflect firm assets under
management as of 12/31/2025.
We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure brochures within
120 days after our fiscal year ends. Our fiscal year ends on December 31, so you will receive the summary of material
changes, if any, no later than April 30 each year. At that time, we will also offer a copy of the most current disclosure
brochure. We may also provide other ongoing disclosure information about material changes as necessary.
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TABLE OF CONTENTS
Investment Strategies
A. Method of Analysis
B.
C. Risk of Loss
Accounting Services
Level Four Financial Services, LLC
Level Four Business Solutions, LLC
Other Registered Investment Advisory Services
Insurance Activities
Carr, Riggs & Ingram, L.L.C.
Financial Planning and Non-Investment Consulting/Implementation Services.
Code of Ethics Summary
Affiliate and Employee Personal Securities Transactions Disclosure
Client Referrals and Other Compensation
Financial Information
Item 1 – Cover Page……………………………………………………………………………………………………………1
Item 2 – Material Changes ........................................................................................................................................... 2
Item 4 – Advisory Business .......................................................................................................................................... 5
Description of the Program sponsored by Level Four Advisory Services, LLC .......................................................................................................... 6
Administrative Services Provided by SS&C Black Diamond Wealth Platform ......................................................................................................... 7
Suitability ............................................................................................................................................................................................................................................ 7
Brokerage, Clearing and Custody ........................................................................................................................................................................................ 7
Aggregation of Client Orders ...................................................................................................................................................................................................... 8
Trading Error Policy ........................................................................................................................................................................................................................ 9
Custody ................................................................................................................................................................................................................................................ 9
Program Fees ............................................................................................................................................................................................................................... 10
Item 5 – Account Requirements and Types of Clients ............................................................................................... 11
Opening an Account .................................................................................................................................................................................................................... 11
Termination of Services .............................................................................................................................................................................................................. 11
Minimum Account Size ............................................................................................................................................................................................................... 11
Types of Clients ............................................................................................................................................................................................................................. 12
Item 6 – Portfolio Manager Selection and Evaluation ................................................................................................ 12
Methods of Analysis, Investment Strategies and Risk of Loss ...................................................................................................................................... 12
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Voting Client Securities .............................................................................................................................................................................................................. 15
General Description of Primary Advisory Services ........................................................................................................................................................... 16
Participation in Wrap Fee Programs ..................................................................................................................................................................................... 16
Performance-Based Fees and Side-By-Side Management ............................................................................................................................................ 17
Client Assets Managed by Level Four Advisory Services, LLC ...................................................................................................................................... 17
Item 7 – Client Information Provided to Portfolio Managers ...................................................................................... 17
Item 8 – Client Contact with Portfolio Managers ........................................................................................................ 17
Item 9 – Additional Information .................................................................................................................................. 17
Account Reviews and Reviewers ............................................................................................................................................................................................. 17
Statements and Reports ............................................................................................................................................................................................................. 18
Disciplinary Information ............................................................................................................................................................................................................ 18
Other Financial Industry Activities and Affiliations ......................................................................................................................................................... 18
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Miscellaneous ................................................................................................................................................................................................................................. 20
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CUSTOMER PRIVACY POLICY ................................................................................................................................ 23
BUSINESS CONTINUITY PLAN DISCLOSURE ....................................................................................................... 27
Firm-Only Disruptions ................................................................................................................................................................................................................ 27
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Disruptions that Affect a Single Building ............................................................................................................................................................................ 27
Disruptions that Affect the Entire City or Business District .......................................................................................................................................... 27
Disruptions that Affect the Entire North Texas Region .................................................................................................................................................. 27
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Item 4 – Advisory Business
Level Four Advisory Services, LLC, (referred to as “LFAS”, the “Firm”, “us” and “we” in this document) is an investment
adviser registered with the United States Securities and Exchange Commission (“SEC”) and has developed and sponsors
the Managed Assets Program (referred to as the “Program”).
The Program is a wrap-fee program. Only investment advisor representatives of LFAS may serve as portfolio managers in
the Program. Therefore, participants in the Program must be advisory clients of LFAS. The following bullets provide basic
background regarding our Firm.
The Firm has been registered as an investment adviser since July 2005.
•
The Firm is owned and controlled by Level Four Group. Level Four Group is a holding company and the 100%
•
owner of LFAS. Level Four Group is owned and operated by Carr, Riggs & Ingram Capital, L.L.C., a Delaware
limited liability company. Carr, Riggs & Ingram Capital, L.L.C. is 100% owned by Carr, Riggs & Ingram, L.L.C., an
Alabama limited liability company. No individuals own more than 25% of Carr, Riggs & Ingram, L.L.C.
• We provide fee-only investment advisory services through LFAS. The nature and extent of the specific services
provided to clients, including you, will always depend on each client’s financial status, objectives and needs, time
horizons, concerns, expectations and risk tolerance.
LFAS Advisory Representatives and LFAS branch offices may use marketing names or other names that are held
•
out to the public. Such names are known as “doing business as” names. The purpose of using a name other than
LFAS is for the Advisory Representative to create a brand that is specific to the Advisory Representative and/or
branch but separate from LFAS. While LFAS allows its Advisory Representatives to use a name other than LFAS,
the Advisory Representative must disclose on advertising and client correspondence that securities are offered
through Level Four Financial, LLC and advisory services are offered through LFAS.
LFAS provides investment advisory services other than the Program described in this brochure including services through
other wrap-fee programs. A description of all fee-based investment advisory services provided by LFAS is available in the
LFAS Disclosure Brochure (Form ADV Part 2A) and the applicable wrap fee program brochure. Any of these wrap fee
program brochures are available upon request by contacting LFAS at 866-834-1040. Some LFAS’ Advisory Representatives
may also provide securities advice as registered representatives of Level Four Financial Services, LLC, (“LFF”) a FINRA and
SIPC member. In their separate capacity as registered representatives of LFF, LFAS’ Advisory Representatives may charge
commissions on a per-transaction basis when implementing their advice on behalf of clients (see Item 9 of this brochure
for more details). LFAS and LFF are affiliated entities as described herein.
When making the determination of whether one of the advisory programs available through LFAS is appropriate for their
needs, clients should bear in mind that fee-based accounts, when compared with commission-based accounts, often result
in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during
periods when trading activity is lower, such arrangements may result in a higher annual cost for transactions. Thus,
depending on a number of factors, the total cost for transactions under a fee account versus a commission account can
vary significantly. Some such factors are account size, amount of turnover, type and quantities of securities purchased or
sold, commission rates and the client’s tax situation.
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Clients should have a conversation with their Advisory Representative and read this brochure carefully as it explains, in
detail, the Program.
Description of the Program sponsored by Level Four Advisory Services, LLC
Under the Program, LFAS provides investment supervisory services defined as giving continuous investment advice to a
client and making investments for the client based on the individual needs of the client. As the sponsor, LFAS provides its
clients with a range of investment advisory services through the Program. These services may include:
Identification of appropriate investments and investment vehicles suitable given the client’s goals;
Evaluation of investments meeting style and allocation criteria;
• Assessment of the client’s investment needs and objectives;
• Development of an asset allocation strategy designed to meet the client’s objectives;
• Recommendations on suitable style allocations;
•
•
• Review of client accounts to ensure adherence to policy guidelines and asset allocation;
• Recommendations for account rebalancing, if necessary;
• Online and paper reporting of client account(s) performance and progress; and
•
Fully integrated back-office support systems to advisers, including custody, trade execution, and confirmation and
statement generation, through Fidelity and Charles Schwab & Co, Inc. (“Schwab”).
LFAS will provide the client some or all of the above referenced investment advisory services. Though all of the above
referenced services may be offered, services offered are based on the type of account.
LFAS shall obtain from client’s information to determine each individual client’s financial situation and investment
objectives. Accounts are managed on the basis of each client’s financial situation and investment objectives. Clients are
instructed to notify LFAS whether the client’s financial situation or investment objectives have changed, or if the client
wants to impose and/or modify any reasonable restrictions on the management of accounts managed under Program. At
least annually, LFAS shall contact individual clients to determine whether their financial situation or investment objectives
have changed, or if the client wants to impose and/or modify any reasonable restrictions on the management of accounts
managed. LFAS shall be reasonably available to consult with individual clients relative to the status of their accounts.
Clients shall have the ability to impose reasonable restrictions on the management of their accounts, including the ability
to instruct LFAS not to purchase certain securities. Clients’ beneficial interest in a security does not represent an undivided
interest in all the securities held by the custodian but rather represents a direct and beneficial interest in the securities
which comprise the account. A separate account is maintained for each client with the custodian and clients retain right of
ownership of the Account (e.g. right to withdraw securities or cash, exercise or delegate proxy voting, and receive
transaction confirmations).
All accounts opened through the Program must be established and held at Fidelity Institutional Wealth Services a Fidelity
affiliated broker/dealer, member FINRA/SIPC (“Fidelity”), or Charles Schwab & Co., Inc. (“Schwab”) Fidelity, Schwab and
LFAS are not affiliated companies. In addition to serving as the broker/dealer, Fidelity and Schwab maintain physical
custody of Program accounts.
Upon establishment of a Program account, LFAS will be granted trading authorization on the client’s account. Accounts
managed through Program are typically done so on a discretionary basis. However, upon a client’s request, LFAS will
manage Program accounts on a non-discretionary basis. Clients must provide LFAS written authorization to manage
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accounts on a discretionary basis. This authority will allow LFAS to determine the type of securities and the number of
securities that can be bought or sold for the client portfolio without obtaining the client’s consent for each transaction.
LFAS or a related person does not act as a principal (buys securities for itself or sells securities it owns to any client) in
Program. LFAS or a related person does not affect transactions in which client securities are sold to or bought from a
brokerage (commission-only) client.
Administrative Services Provided by SS&C Black Diamond Wealth Platform
LFAS has contracted with SS&C Black Diamond Wealth Platform (referred to as “Black Diamond”) to utilize its technology
platforms to support data reconciliation, performance reporting, fee calculation and billing, research, client database
maintenance, quarterly performance evaluations, payable reports, web site administration, models, trading platforms, and
other functions related to the administrative tasks of managing Program accounts. Due to this arrangement, Black
Diamond will have access to client accounts, but Black Diamond will not serve as an investment adviser to Program clients.
LFAS and Black Diamond are non-affiliated companies. LFAS compensates Black Diamond on a basis point fee basis with
account minimum and maximum charges per account. The fee paid to Black Diamond does not result in an increase to the
overall fee charged by LFAS relative to other advisory programs available through LFAS.
Suitability
LFAS will assist clients in determining their objective(s), investment strategy, and investment suitability, prior and
subsequent to opening a Program account. Clients must advise LFAS of any changes in their investment objective(s)
and/or financial situation.
LFAS’ services are always provided based on the individual needs of the individual client. Clients are given the ability to
impose restrictions on their accounts including specific investment selections and sectors.
When managing client accounts through the Program, we will generally manage a client’s account in accordance with one
or more models developed by our Investment Committee. However, the determination to use a particular model or
models is always based on each client’s individual investment goals, objectives and mandates. More information about
our models and strategies is provided at Item 6.
Brokerage, Clearing and Custody
Fidelity Brokerage Services, LLC (“Fidelity”), and Charles Schwab & Co., Inc. (“Schwab”) serve as broker/dealers and
qualified custodians for all accounts established through the Program. LFAS’ recommendation of Fidelity, and Schwab is
based primarily on minimizing client fees and expenses, but also on past experiences, as well as offerings or services.
Fidelity, and Schwab provide benefits and services that LFAS or clients may require or find valuable such as online access.
Transactions costs charged by Fidelity, and Schwab may be higher than those charged by other broker/dealers in return
for those products and services provided by Fidelity and Schwab.
Expense and fee structures of various broker/dealers are periodically reviewed by LFAS to ensure Program accounts are
receiving best execution. Accordingly, while LFAS will consider competitive rates, it may not necessarily obtain the lowest
possible rates for client account transactions. Therefore, the overall services provided by Fidelity and Schwab are
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evaluated to determine best execution. Fidelity, and Schwab have a wide range of available securities products for which
LFAS performs due diligence prior to selection.
It should be noted that Program accounts may or may not be charged a separate fee for transactions executed by Fidelity,
and Schwab. It is the discretion of the Advisory Representative after consultation with the client to determine if the client’s
Program account will be charged for all transactions or if the transaction fees will be included in the overall management
fee charged by LFAS. The firm does not charge clients higher advisory fees based upon trading activity, but the firm does
have an incentive to limited trading activity in client account(s) because we are charged for executed trades. When clients
are charged on a per transaction basis, the transaction fee will appear on the client’s individual account statement from
Fidelity or Schwab.
LFAS may elect to execute trades for fixed income securities (i.e. bonds) through bond broker-dealers in order to obtain a
better price for the client and then have the bonds delivered into/from the client's Fidelity or Schwab brokerage account.
This practice is enabled through the Fidelity or Schwab Trade Away service. This is the only case in which LFAS selects a
broker/dealer to be used without specific client consent. Fidelity and Schwab charge the client a service fee per order
entered at an executing broker/dealer by LFAS. The Trade Away Service Fee will be charged to the client’s account.
While there will not be a direct linkage between the investment advice provided by LFAS and Fidelity, or Schwab economic
benefits may be received that would not be received if LFAS did not use these services to implement the investment
advice provided. These benefits may include, but not necessarily be limited to: receipt of duplicate client confirmations
and bundled duplicate statements; access to a trading desk; the ability to have investment advisory fees deducted directly
from client accounts; access to an electronic communications network for client order entry and account information;
receipt of compliance publications; and access to mutual funds that generally require significantly higher minimum initial
investments or are generally only available to institutional investors.
Aggregation of Client Orders
Depending upon who has investment discretion, the firm, the Manager or your financial advisor may execute aggregate
trades for more than one client’s account (“block trades”) and execute as a single trade in order to provide fair and
equitable prices among managed client accounts. If affiliated asset management firm, Level Four Capital Management
(“LFCM”) is utilized for sub-advisory services, trades will be aggregated by LFCM for trading purposes. All clients will
receive equal treatment when LFAS and its Advisory Representatives perform block trades for managed accounts.
Securities purchased or sold using block trades will then be allocated in a fair and equitable manner to all client accounts
involved in the block trade. If for any reason the entire block trade cannot be completed on the day the trade is placed,
client accounts will receive an equal pro-rata portion of the securities traded. If a block transaction is effected, you will
receive the average price of all transactions effected to fill the order. As a result, the average price received by any
individual client may be higher or lower than the price that an individual client may have received had the transaction
been effected for the client independently from the block transaction. LFAS will keep records of all block trades executed
and the allocations for each client account that participates in the block trade. LFAS and its Advisory Representatives will
not receive additional compensation as a result of block trading.
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Trading Error Policy
Based on industry practice and SEC guidance to broker-dealers, a trade error under this policy is defined as including:
Inaccurate transmission or execution of any term of an order including, but not limited to: price; number of shares
•
or other unit of trading; identification of the security; identification of the account for which securities are
purchased or sold; short sales that were instead sold long or vice versa; or the execution of an order on the wrong
side of a market;
• Unauthorized (because of misunderstanding or mistake) or unintended purchase, sale or allocation of securities,
or the failure to follow specific client instructions; and
Incorrect entry of data into relevant systems, including reliance on incorrect cash positions, withdrawals or
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securities positions reflected in an account.
LFAS has implemented procedures designed to prevent trade errors; however, trade errors in client accounts cannot
always be avoided. Consistent with its fiduciary duty, it is the policy of LFAS to correct trade errors in a manner that is in
the best interest of the client. In cases where the client causes the trade error, the client will be responsible for any loss
resulting from the correction. In all situations where the client does not cause the trade error, the client will be made
whole and any loss resulting from the trade error will be absorbed by LFAS if the error was caused by the Firm. If the error
is caused by the broker-dealer, the broker-dealer will be responsible for covering all trade error costs. LFAS will never
benefit or profit from trade errors. Gains from trade errors, whether caused by the client or Firm are generally retained by
the custodian.
Custody
Custody, as it applies to investment advisers, has been defined by regulators as having access or control over client funds
and/or securities. In other words, custody is not limited to physically holding client funds and securities. If an investment
adviser has the ability to access or control client funds or securities, the investment adviser is deemed to have custody and
must ensure proper procedures are implemented.
LFAS does not take physical custody of your funds or securities. However, LFAS is deemed to have custody of client funds
and securities whenever LFAS is given the authority to have fees deducted directly from client accounts or if LFAS
facilitates or executes your requests for third party standing letters of authorization that enable LFAS to change the timing
of the amount of the transfer upon your request. Additionally, due to the fact in certain circumstances such as when
clients of LFAS are referred for the provision of trust services, a related party, Preferred Legacy Trust, will be acting as a
qualified custodian for client assets, LFAS is deemed to have custody for such clients. While related, LFAS and Preferred
Legacy Trust remain operationally independent. It should be noted that authorization to trade in client accounts is not
deemed by regulators to be custody.
LFAS has established procedures to ensure all client funds and securities are held at a qualified custodian (e.g. Fidelity,
Schwab and other independent qualified custodians) in a separate account for each client under that client’s name.
Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore
are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained.
Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent
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representative, at least quarterly. When clients have questions about their account statements, they should contact LFAS
or the qualified custodian preparing the statement.
Program Fees
The annual investment advisory fee charged to Program accounts will generally not exceed 2.5% of the assets held in the
account on an annual basis. The annual fee is negotiable with the client depending on the market value of the account,
asset types, the client’s financial situation and trading activity. Fee waivers or discounts may be offered to family members
and friends of associated persons of LFAS which are not available to other clients.
The annual fee shall be divided and payable monthly in advance through a direct debit in the client account. Fees are
based on the account's asset value as of the last business day of the prior month and are based upon actual days/365.
New accounts are billed twice at the beginning of the month following funding date – once in arrears from funding date
through the end of the month and once in advance for the next month billing. The firm utilizes Black Diamond for the
calculation of fees and LFAS is responsible for debiting all fees from client accounts. Clients must provide Schwab or
Fidelity written authorization to debit advisory fees from their accounts and pay such fees to LFAS. In the event of
termination, the Firm will refund the prorated portion of the Advisory Fee for the remainder of the month in which the
account is terminated.
Clients may open a Non-Wrap or Wrap Fee account. In a non-wrap account, in addition to the investment advisory fee,
the client will pay certain transaction charges to defray the costs associated with trade execution. These costs are set out
and determined Schwab or Fidelity. In a Wrap Fee account, the client does not pay transaction charges associated with
trade execution.
Clients may incur certain charges imposed by third parties other than LFAS in connection with investments made through
the account, including but not limited to fees and expenses imposed directly by a mutual fund, index fund, or exchange
trades fund which are disclosed in the fund’s prospectus (i.e. fund management fees and other fund expenses), mark-ups
and mark-downs, spreads paid to market makers, fee (such as a commission or markup) for trades executed away from
the custodian at another broker-dealer, wire transfer fees and other fees and taxes on brokerage accounts and securities
transactions, as well as fees by a retirement plan sponsor. Management fees charged by LFAS (which include transaction
and execution fees charged) are separate and distinct from the fees and expenses charged by investment company
securities that may be recommended to clients. A description of these fees and expenses are available in each investment
company security’s prospectus. LFAS and its Advisory Representatives do not retain any portion of these “other” fees. The
only compensation earned by LFAS is the investment advisory fee described above.
The Program may cost the client more or less than if the assets were held in a traditional brokerage account. In a
traditional brokerage account, the client is charged commissions for each transaction, and the representative has no duty
to provide ongoing advice with respect to the account. If the client plans to follow a buy and hold investment strategy for
the account or does not wish to purchase ongoing investment advice or management services, the client should consider
opening a brokerage account rather than a Program account.
Research and Other Soft Dollar Benefits
LFAS’s primary objective in broker-dealer selection is to comply with its duty to obtain the best execution for clients. Best
execution does not necessarily mean the lowest commission, but instead involves consideration of many factors, listed
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above. A statutory “safe harbor” allows broker-dealers to be paid with commission dollars, also referred to as soft dollars,
in exchange for statistical research and information. Soft dollar transactions generally cause clients to pay a commission
rate higher than would be charged for execution of the trade only.
At times, LFAS may select a broker-dealer that charges a commission in excess of that which another broker-dealer may
have charged for executing the same transaction. LFAS is not obligated to simply choose the broker-dealer with the
lowest commission rate if, within reasonable judgment, we believe the total cost or proceeds may be less favorable for the
client that what may be obtained by a broker-dealer offering soft dollar services.
Research related products and services provided by the broker-dealer may include both proprietary and third-party
research covering analysis and pricing, trading markets, legislative developments, economic and financial trends, and
research or analytical computer software utilized in the investment management process.
LFAS is able to obtain such products and services through the use of Soft Dollars which reduces the need for LFAS to
produce the same research through hard dollars. Thus, the use of soft dollars can provide economic benefits to Level Four
Advisory Services and its clients.
Research products and services may be useful in servicing some or all of the Advisor and its affiliates’ client accounts but
may not be used by the Advisor in servicing the actual client accounts whose commission dollars generated and provided
such research. Due to custodian restrictions, not all clients will be part of the soft dollar arrangement or pay for these
services.
LFAS periodically reviews performance of broker-dealers and the items previously discussed to other broker-dealers to
ensure that we are providing clients with the best execution available for those services.
Item 5 – Account Requirements and Types of Clients
Opening an Account
To become a Program participant, an Investment Advisory Agreement and Investor Risk Tolerance Questionnaire between
the client and LFAS must be executed. In addition, the client will be required to establish a brokerage account through
Schwab or Fidelity.
Termination of Services
Program services may be canceled at any time, by any of the parties, for any reason upon receipt of written notice to the
other party. Services will be terminated without penalty, and the client shall receive a pro-rated refund based on the
amount of time remaining in the final quarter. Specific termination provisions are contained in the Investment Advisory
Agreement.
Minimum Account Size
LFAS requires a minimum account size of $40,000 to open a Program account. Exceptions to this minimum may be
granted at the discretion of LFAS.
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Types of Clients
LFAS generally provides investment advice to the following types of clients:
Individuals
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• Pension and profit-sharing plans
Trusts and estates
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• Corporations or business entities other than those listed above
Item 6 – Portfolio Manager Selection and Evaluation
The Program does not allow Advisory Representatives or clients to utilize portfolio managers that are not associated with
LFAS. In other words, the only portfolio managers selected for managing client assets in the Program are Advisory
Representatives of LFAS who may in turn engage the sub-advisory asset management services of affiliated investment
advisor, Level Four Capital Management, LLC (“LFCM”). Therefore, conflicts of interest present in other wrap-fee programs
that make available both affiliated and unaffiliated portfolio managers are not present in this Program. Because the
Program does not provide for a multitude of outside portfolio managers, LFAS does not have procedures designed to
select outside portfolio managers. Most of the items required by this item of the Wrap Fee Program Brochure instructions
do not apply to LFAS. Items that do apply are answered below.
Methods of Analysis, Investment Strategies and Risk of Loss
Depending on the client’s individual needs, investment recommendations will primarily be made in no-load mutual funds,
load-waived mutual funds, and Exchange Traded Funds (ETFs). Other investments may include, but are not necessarily
limited to stocks, bonds, and unit investment trusts. It is not LFAS’ typical investment strategy to attempt to time the
market, but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our
expectations of market behavior. LFAS’ Advisory Representatives are responsible for communicating with his/her client
and gathering all client information.
LFAS’ Advisory Representatives use various methods of analysis and investment strategies. Methods and strategies will
vary based on the LFAS Advisory Representative providing advice. Models and strategies used by one Advisory
Representative may be different than strategies used by other Advisory Representatives. Some LFAS Advisory
Representatives may use just one method or strategy while other Advisory Representatives may rely on multiple. LFAS
does not require or mandate a particular investment strategy be implemented by its Advisory Representatives. Further,
LFAS has no requirements for using a particular analysis method and LFAS Advisory Representatives are provided flexibility
(subject to LFAS supervision and compliance requirements) when developing their investment strategies.
Although LFAS Advisory Representatives have the ability to develop and implement their own investment strategies and
methods of analysis, Advisory Representatives may elect to have their accounts managed in accordance with the strategies
and methods of analysis developed by the LFAS Investment Committee. In these situations, the Investment Committee
will be responsible for actively determining investment recommendations and implementing such recommendations.
Numerous model portfolios are developed by the LFAS Investment Committee at any one time, but generally speaking,
portfolios will be designed based on the following objectives:
• Current Income,
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• Balanced,
• Growth & Income,
• Growth, and
• Aggressive Growth
The following sections provide brief descriptions of some of the more common methods of analysis and investment
strategies that are used by LFAS.
A. Method of Analysis
Charting - The set of techniques used in technical analysis in which charts are used to plot price movements,
volume, settlement prices, open interest, and other indicators, in order to anticipate future price movements. Users
of these techniques, called chartists, believe that past trends in these indicators can be used to extrapolate future
trends.
Cyclical - Analyzes the investments sensitive to business cycles and whose performance is strongly tied to the
overall economy. For example, cyclical companies tend to make products or provide services that are in lower
demand during downturns in the economy and higher demand during upswings. Examples include the automobile,
steel, and housing industries. The stock price of a cyclical company will often rise just before an economic upturn
begins, and fall just before a downturn begins. Investors in cyclical stocks try to make the largest gains by buying
the stock at the bottom of a business cycle, just before a turnaround begins.
Fundamental - A method of evaluating a security by attempting to measure its intrinsic value by examining related
economic, financial and other qualitative and quantitative factors. Fundamental analysts attempt to study
everything that can affect the security's value, including macroeconomic factors (like the overall economy and
industry conditions) and individually specific factors (like the financial condition and management of companies).
The end goal of performing fundamental analysis is to produce a value that an investor can compare with the
security's current price in hopes of figuring out what sort of position to take with that security (underpriced = buy,
overpriced = sell or short). This method of security analysis is considered to be the opposite of technical analysis.
Fundamental analysis is about using real data to evaluate a security's value. Although most analysts use
fundamental analysis to value stocks, this method of valuation can be used for just about any type of security.
Technical - A method of evaluating securities by analyzing statistics generated by market activity, such as past
prices and volume. Technical analysts do not attempt to measure a security's intrinsic value but instead use charts
and other tools to identify patterns that can suggest future activity. Technical analysts believe that the historical
performance of stocks and markets are indications of future performance.
B. Investment Strategies
LFAS’ primary method of analysis or strategy is Strategic Asset Allocation which calls for setting target allocations
and then periodically rebalancing the portfolio back to those targets as investment returns skew the original asset
allocation percentages. The concept is akin to a “buy and hold” strategy, rather than an active trading approach. Of
course, the strategic asset allocation targets may change over time as the client’s goals and needs change and as
the time horizon for major events such as retirement and college funding grow shorter. Some of the risks involved
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with using this method include having an inappropriate risk tolerance given the client’s goals and objectives,
investing in assets that may be too conservative or too aggressive for the client’s stated risk tolerance, not properly
re-balancing the portfolio to maintain the integrity of the strategic asset allocation.
In addition to strategic asset allocation, we may also use Tactical Asset Allocation which allows for a range of
percentages in each asset class (such as Stocks = 40-50%). These are minimum and maximum acceptable
percentages that permit the investor to take advantage of market conditions within these parameters. Thus, a
minor form of market timing is possible, since the investor can move to the higher end of the range when stocks
are expected to do better and to the lower end when the economic outlook is bleak. Similar risks described under
strategic asset allocation are associated with tactical asset allocation.
We also use the following general investment strategies when managing accounts.
Long-term purchases - Investments held at least a year.
•
Short-term purchases - Investments sold within a year.
•
Trading - Investments sold within 30 days.
•
C. Risk of Loss
LFAS primarily recommends mutual funds to meet the needs of its clients, although exchange traded funds, stocks
and bonds may also be used. A mutual fund’s investment objective and its holdings are influential factors in
determining how risky a fund is. Mutual funds face risks based on the investments they hold. For example, a bond
fund faces interest rate risk and income risk. Similarly, an equity sector fund is at risk that its price will decline due
to developments in its industry. Overall market risk is defined as the possibility that stock or bond fund prices
overall will decline over short or even extended periods. Finally, principal risk, or the possibility that an investment
will go down in value, or “lose money,” from the original or invested amount, is a risk faced by investors.
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients (including you) should never assume that future performance of any specific investment or
investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds) involves
risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. Clients
and prospective clients should be prepared to bear investment loss including loss of original principal.
Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee, or even
imply that our services and methods of analysis can or will predict future results, successfully identify market tops
or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks
associated when investing in securities through our investment management program. The following are some
additional risks clients need to be aware of.
ETF and Mutual Fund Risk – When LFAS invests in an ETF or mutual fund for a client, the client will bear
•
additional expenses based on its pro rata share of the ETF’s or mutual fund’s operating expenses, including
the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities the ETF or mutual fund holds. Clients may also incur brokerage
costs when purchasing ETFs.
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• Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting
in a decrease in the value of client investments. This is also referred to as systemic risk.
Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to
•
volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If
you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed
to greater risk than if you held preferred stocks and debt obligations of the issuer.
• Company Risk. When investing in stock positions, there is always a certain level of company or
industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can
be reduced through appropriate diversification. There is the risk that the company will perform poorly or
have its value reduced based on factors specific to the company or its industry. For example, if a company’s
employees go on strike or the company receives unfavorable media attention for its actions, the value of the
company may be reduced.
Fixed Income Risk. When investing in bonds, there is the risk that issuer will default on the bond and be
•
unable to make payments. Further, individuals who depend on set amounts of periodically paid income face
the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments
that face the same inflation risk.
• Options Risk. Options on securities may be subject to greater fluctuations in value than an investment in the
underlying securities. Purchasing and writing put and call options are highly specialized activities and entail
greater than ordinary investment risks.
• Management Risk – Your investment with our Firm varies with the success and failure of our investment
strategies, research, analysis and determination of portfolio securities. If our investment strategies do not
produce the expected returns, the value of the investment may decrease.
Voting Client Securities
LFAS will not vote proxies on behalf of your account. While there are some investment advisers that will vote proxies and
other corporate decisions on behalf of their clients, we have determined that taking on the responsibility for voting client
securities does not add enough value to the services provided to clients to justify the additional compliance and
regulatory costs associated with voting client securities. Therefore, it is your responsibility to vote all proxies for securities
held in accounts managed by our Firm.
Clients will receive proxies directly from their custodian or transfer agent and such documents will not be delivered by our
Firm. In some instances, and at your specific request, your Advisory Representative may give recommendations or
clarifications based on your Advisory Representative’s understanding of the issues presented in the proxy materials. Your
Advisory Representative may also conduct additional research on proxy issues if necessary; however, you will be solely
responsible for all proxy voting decisions.
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General Description of Primary Advisory Services
Because Advisory Representatives serve as portfolio managers of the Program, the following is provided as brief
descriptions of LFAS’ primary services. Detailed descriptions of LFAS’ services other than the Program are provided in our
Disclosure Brochure.
LFAS’ Advisory Representative will conduct a complimentary initial meeting with the client for an information and data-
gathering session. At this initial meeting, the Advisory Representative will assist the client in determining the level of
financial planning services needed. If clients elect to continue with the financial planning process, the Advisory
Representative will hold as many meetings or telephone conferences as necessary to gather the documents, information,
goals and objectives needed to prepare the financial plan. Whether clients select a comprehensive or a modular plan, the
LFAS’ Advisory Representatives will meet with them to:
Identify financial goals and objectives;
•
• Collect and assess all relevant data;
Identify financial concerns and formulation of solutions; and
•
• Prepare a financial plan with specific recommendations for presentation to the client.
Financial Planning Services – LFAS also provides advisory services in the form of financial planning services. Financial
planning services do not involve the active management of client accounts but instead focuses on a client’s overall
financial situation. Financial planning can be described as helping individuals determine and set their long-term financial
goals, through investments, tax planning, asset allocation, risk management, retirement planning, and other areas. The role
of a financial planner is to find ways to help the client understand his/her overall financial situation and help the client set
financial objectives.
Asset Management Services – LFAS provides advisory services in the form of Asset Management Services through the
Program and other advisory programs and platforms. Asset Management Services involve providing clients with
continuous and on-going supervision over client accounts. This means that LFAS will continuously monitor a client’s
account and make trades in client accounts when necessary.
Outside Money Managers – In connection with other advisory programs offered through LFAS as detailed in the LFAS
Form ADV Part 2A LFAS provides advisory services by referring clients to outside, or unaffiliated, money managers that are
registered or exempt from registration as investment advisers. Third-party money managers are responsible for
continuously monitoring client accounts and making trades in client accounts when necessary.
Participation in Wrap Fee Programs
Our Advisory Representatives may provide asset management services through both wrap-fee programs and traditional
management programs including the Managed Assets Program. Under a wrap-fee program, advisory services and
transaction services are provided for one fee. This is different from traditional management programs whereby our
services are provided for a fee, but transaction services are billed to clients separately on a per-transaction basis. From a
management perspective, there is not a fundamental difference in the way our Advisory Representatives manage wrap-fee
accounts versus traditional management accounts. The only significant difference is the way in which transaction services
are paid.
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Performance-Based Fees and Side-By-Side Management
LFAS does not charge or accept performance-based fees. Regulators have defined performance-based fees as charging
fees based on a share of capital gains on or capital appreciation of the assets held within a client’s account.
Client Assets Managed by Level Four Advisory Services, LLC
The amount of client assets managed by LFAS totaled approximately $6,543,203,513 as of December 31, 2025.
$5,883,647,645 is managed on a discretionary basis and $659,555,868 is managed on a non-discretionary basis.
Item 7 – Client Information Provided to Portfolio Managers
Because only Advisory Representatives of LFAS serve as portfolio managers, Advisory Representatives or their assistants
are responsible for gathering all information provided by clients. In the event that LFCM is engaged to provide sub-
advisory services, Advisory Representatives are likewise responsible for gathering all information provided by clients.
Advisory Representatives will interview and work with clients to gather all information needed relative to their investment
objectives and needs in order to provide management services through the Program. Clients need to contact their
Advisory Representative whenever there are changes to their financial situation that will impact or materially influence the
way LFAS manages accounts.
Item 8 – Client Contact with Portfolio Managers
Because only Advisory Representatives of LFAS serve as portfolio managers, there are no restrictions placed on clients’
ability to contact and consult with their portfolio managers. In the event LFCM is engaged to provide sub-advisory
services, clients may from time to time also have communication with the LFCM portfolio team which would be facilitated
through coordination with the LFAS Advisory Representative. It is the policy of LFAS to provide an “open channel” of
communication between Advisory Representatives and their clients. Clients are encouraged to contact their Advisory
Representative whenever they have questions about the management of their account.
Item 9 – Additional Information
Account Reviews and Reviewers
Account reviews are provided in connection with the Program. For clients participating in the Program, the client’s
individual Advisory Representative will contact the client at least annually for the purpose of reviewing their account and
to determine if there have been changes in their financial situation or investment objectives. The calendar is the main
triggering factor, although more frequent reviews may also be triggered by changes in the client’s circumstances, client
request, or changes within the market.
The underlying investments held in Program accounts and/or the recommended holdings in portfolios which may be sub-
advised by LFCM are reviewed on a more frequent basis. Portfolios are usually reviewed as frequently as monthly, but no
less than quarterly, by the LFAS Advisory Representative responsible for managing the account or the LFCM Investment
Committee if sub-advised by LFCM.
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Statements and Reports
Clients will receive statements and transaction confirmations from Schwab or Fidelity on at least a quarterly basis. Clients
may also receive quarterly, monthly, or on-demand performance reports showing the investment performance of their
accounts from LFAS. LFAS may utilize the Black Diamond performance reporting functionality to provide such reports.
Clients are strongly urged to compare all statements received from LFAS against their brokerage account statements
received from Schwab and Fidelity. Discrepancies between statements received from LFAS and Schwab or Fidelity need to
be reported to LFAS immediately.
Clients are strongly urged to compare any reports received from LFAS against account statements received from the
qualified custodian. Discrepancies between reports received from LFAS and the statements received from the qualified
custodian should be reported immediately to LFAS and the qualified custodian.
Disciplinary Information
This item is not applicable to LFAS’ brochure because there are no legal or disciplinary events listed at Item 9 of the Form
ADV Part 2A instructions that are material to a client’s or prospective client’s evaluation of LFAS’ business or the integrity
of LFAS’ management.
Other Financial Industry Activities and Affiliations
LFAS is not and does not have a related company that is a (1) 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), (2) futures commission merchant, commodity pool operator, or commodity trading advisor, (3)
banking or thrift institution, (4) pension consultant, (5) real estate broker or dealer, (6) sponsor or syndicator of limited
partnerships, or (7) law firm.
LFAS’ only business is providing advisory services and investment advice to clients. However, many of LFAS’ Advisory
Representatives are engaged in professions other than giving investment advice. Those that are registered representatives
of a broker-dealer or licensed insurance agents may sell securities and/or insurance products to any client and will receive
usual and customary commissions for these transactions.
Accounting Services
Some of LFAS’ Advisory Representatives may establish relationships with CPA firms not related to LFAS and may provide
advisory services to clients of these accounting firms. Some of those accountants may also be licensed as registered
representatives of affiliated firm, Level Four Financial, LLC. In their capacities as registered representatives, the Advisory
Representatives may implement securities transactions on behalf of CPA firm clients and share the usual and customary
commissions received with the licensed accountants. Clients are not obligated to use the services of the CPA firm or LFAS’
Advisory Representatives.
Some of LFAS’ Advisory Representatives may also be separately licensed as Certified Public Accountants or Enrolled
Agents with the Internal Revenue Service. They may provide accounting or tax preparation services to clients. If
appropriate, advisory clients may be referred to these individuals for accounting or tax preparation services, but they are
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not obligated to use these services. If clients do elect to use these services, charges for tax or accounting services
provided will be separate from fees charged for advisory services.
Level Four Financial Services, LLC
A number of LFAS’ Advisory Representatives may also be dually registered as a registered representative with affiliated
firm, Level Four Financial Services, LLC (“LFF”), a FINRA registered broker-dealer and SEC investment adviser. As of
October 2020, the holding company of LFAS, LFG Group, LLC, acquired ownership in LFF, thus creating common control
and ownership between LFF and LFAS. LFF and LFAS share office space and operational personnel.
Level Four Business Solutions, LLC
LFAS is under common control with a business consulting firm, Level Four Business Solutions, LLC, (“LFBS”) which provides
various business solutions to businesses through engagement of services. Some of LFAS’ representatives may provide
such services through a separate engagement with LFBS.
Other Registered Investment Advisory Services
LFAS is also under common control with other investment advisers, Level Four Capital Management, LLC (“LFCM”), an SEC
registered investment adviser and The Preferred Legacy National Trust Bank, a national bank. LFAS and LFCM have
overlap in personnel and LFAS may use LFCM as a sub-advisor for client accounts. LFAS may have occasion to refer clients
to The Preferred Legacy National Trust Bank for trust services as may be appropriate given a client’s stated needs and
objectives; however, LFAS and The Preferred Legacy National Trust Bank do remain operationally independent entities.
Insurance Activities
Some of LFAS’ Advisory Representatives are also independently licensed insurance agents and may be affiliated with
various insurance companies. When selling insurance products in this separate capacity, they may receive normal and
customary commissions. Level Four Group, LLC is the sole owner of LFAS and Level Four Insurance Agency, a licensed
insurance agency. Some of LFAS’ Officers and Advisory Representatives own Level Four Group, LLC and sell insurance
products through Level Four Insurance Agency.
Carr, Riggs & Ingram, L.L.C.
Our parent company, Level Four Group, is indirectly controlled by Carr, Riggs, & Ingram, L.L.C. (CRI), an Alabama limited
liability company and accounting firm. Although clients of LFAS in need of accounting services will typically be referred to
the client’s individual Advisory Representative’s related accounting firm, clients may also be referred to CRI. Because of
CRI’s relationship to controlled LFAS, we have a financial incentive to recommend CRI over other accounting firms.
Moreover, CRI may and frequently does refer their accounting clients to LFAS for investment management services. Due
to the relationship between CRI and LFAS, CRI has an economic incentive to recommend LFAS over other financial firms
offering similar services to those offered by LFAS.
CRI is also the 100% indirect owner of a number of financial services-related entities, including without limitation,
Auditwerx, LLC, another accounting firm, CRI Solutions Group, LLC, an executive consulting firm, CRI Advanced Analytics,
an analytics firm, CRI TPA Services, a third party administrator firm, CRI M&A, LLC, a mergers and acquisitions advisory
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firm and registered broker/dealer, CRI Simple Numbers, a business profitability consulting firm and Paywerx, a payroll
management solution. LFAS does not have direct material arrangements with these firms; however, may share or refer
clients with such firms.
If you are referred to an affiliated company of LFAS or referred by an affiliated company of LFAS, please understand you
are under no obligation to work with LFAS or one of our affiliated companies. You can work with any accounting firm,
investment advisor or other financial professional of your choosing.
Conflict of Interest: The recommendation by LFAS representatives that a client purchase securities or insurance
commission products from the firm presents a conflict of interest, as the receipt of commissions may provide an incentive
to recommend investment products based on commissions to be received, rather than on a particular client’s need. We
address this conflict through disclosure, and policies and procedures designed to ensure that advisory representatives act
in the best interest of each client based upon a client’s investment objectives, risk tolerance and financial needs. No client
is under any obligation to purchase any securities or insurance commission products from LFAS and/or its representatives.
Clients are reminded that they may purchase securities and insurance products recommended by LFAS through other,
non-affiliated broker-dealers and/or insurance agencies.
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:
o Meet a professional standard of care when making investment recommendations (give prudent advice);
o Never put our financial interests ahead of yours when making recommendations (give loyal advice);
o Avoid misleading statements about conflicts of interest, fees, and investments;
o Follow policies and procedures designed to ensure that we give advice that is in your best interest;
o Charge no more than is reasonable for our services; and
o Give you basic information about conflicts of interest.
LFAS’ Chief Compliance Officer remains available to address any questions that a client or prospective client may
have regarding the above conflict of interest.
Miscellaneous
Financial Planning and Non-Investment Consulting/Implementation Services.
To the extent requested by a client, LFAS may provide consulting services regarding non-investment-related matters, such
as estate planning, tax planning, insurance, etc. under a separate Financial Planning Agreement. LFAS does not serve as an
attorney, accountant, or insurance agent, and no portion of LFAS’s services should be construed as same. To the extent
requested by a client, LFAS may recommend the services of other professionals for certain non-investment
implementation purposes (i.e. attorneys, accountants, insurance, etc.), including representatives of LFAS in their separate
individual capacities as representatives of Level Four Financial, LLC (“LFF”), an SEC registered and FINRA member broker-
dealer and as licensed insurance agents through Level Four Insurance Agency, LLC or through affiliated business
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consulting firm, Level Four Business Solutions, LLC. . The client is under no obligation to engage the services of any such
recommended professional. The client retains absolute discretion over all such implementation decisions and is free to
accept or reject any recommendation from LFAS and/or its representatives. Please Note: If the client engages any such
recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse
exclusively from and against the engaged professional. Please Also Note-Conflict of Interest: The recommendation by
LFAS representatives that a client purchase a securities or insurance commission product from firm representatives in their
individual capacities as representatives of LFF and/or as insurance agents, presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend investment products based on commissions to be received, rather
than on a particular client’s need. No client is under any obligation to purchase any securities or insurance commission
products from LFAS representatives. Clients are reminded that they may purchase securities and insurance products
recommended by LFAS through other, non-affiliated broker-dealers and/or insurance agencies. LFAS’ Chief Compliance
Officer remains available to address any questions that a client or prospective client may have regarding the above
conflict of interest.
Code of Ethics Summary
According to the Investment Advisers Act of 1940, an investment adviser is considered a fiduciary. As a fiduciary, it is an
investment adviser’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment
adviser has a duty of utmost good faith to act solely in the best interest of each of its clients. LFAS and its Advisory
Representatives have a fiduciary duty to all clients. LFAS has established a Code of Ethics which all Advisory
Representatives must adhere to. They must execute an annual acknowledgment agreeing that they understand and agree
to comply with that Code of Ethics.
The fiduciary duty of LFAS and its Advisory Representatives to clients is considered the core underlying principle for LFAS’
Code of Ethics and represents the expected basis for all dealings the Advisory Representatives have with clients. LFAS has
the responsibility to make sure that the interests of clients are placed ahead of it or its Advisory Representatives’ own
investment interests. All Advisory Representatives will conduct business in an honest, ethical and fair manner. All Advisory
Representatives will comply with all federal and state securities laws at all times. Full disclosure of all material facts and
potential conflicts of interest will be provided to clients prior to services being conducted. All Advisory Representatives
have a responsibility to avoid circumstances that might negatively affect or appear to affect the Advisory Representatives’
duty of complete loyalty to their clients. This section is only intended to provide current clients and potential clients with a
description of LFAS’ Code of Ethics. If current clients or potential clients wish to review LFAS’ Code of Ethics in its entirety,
a copy may be requested from any of LFAS’ Advisory Representatives and a copy will be promptly provided.
Affiliate and Employee Personal Securities Transactions Disclosure
LFAS, our Advisory Representatives and/or our personnel may buy or sell securities in their personal accounts that we may
also recommend to clients. Because this policy may create a conflict between the interests of clients and the personal
investing opportunities of our personnel, we have established several procedures to control for the apparent conflict of
interest.
LFAS is and shall continue to be in compliance with The Insider Trading and Securities Fraud Enforcement Act of
•
1988. Personnel shall not buy or sell securities for their personal account(s) where their decision is derived, in
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whole or in part, from information obtained as a result of his/her employment unless the information is also
available to the investing public upon reasonable inquiry.
It is our policy that no Advisory Representative shall prefer his or her own interest to that of the advisory client.
•
• Our personnel may not purchase or sell any security traded over an exchange (such as a stock position) prior to
transactions in the same securities are implemented for an advisory client account.
• Most investments owned by our personnel are publicly traded and widely available (such as mutual funds).
Client Referrals and Other Compensation
Client Referrals
From time to time, LFAS and its Advisory Representatives receive from unaffiliated parties, client referrals in exchange for
compensation to that third-party (“referral arrangement”). Any referral arrangement entered into by LFAS for the
solicitation of advisory clients by a third-party that constitutes a “testimonial” or “endorsement” are in accordance with
Rule 206(4)-1 under the Advisers Act. Compensation to the solicitor or promoter is dependent on the client entering into
an advisory agreement with LFAS. Compensation to the solicitor/promoter will be an agreed upon percentage of LFAS’
investment advisory fee or a flat fee depending on the type of advisory services LFAS provides to the referred client. The
Solicitor is not permitted to offer clients any investment advice on behalf of LFAS and advisory fees charged to clients will
not increase as a result of compensation being shared with the solicitor. The details of the referral arrangement and a
description of the compensation paid to the solicitor will be disclosed to each referred client through a written disclosure.
From time to time, LFAS and its Advisory Representatives may enter into other types of referral arrangements, including
arrangements with company affiliates. These arrangements are also conducted in accordance with Rule 206(4)-1 under
the Advisers Act and any material conflict of interest created by such arrangement will be disclosed to any solicited or
referred client through the applicable disclosure and/or wrap fee brochure as well as any supplemental verbal or written
disclosures.
Other Compensation
Other than the receipt of advisory fees as described in Item 4 of this brochure, LFAS receives no other compensation in
connection with the management services offered through the Program.
However, a Program client may select other advisory services offered by LFAS or engage an Advisory Representative to
provide services on a strictly commission basis, purchase insurance products or provide accounting services. In such
situations, the client will pay other fees and expenses related to this service. Further LFAS and/or our Advisory
Representative will earn compensation in addition to the Program management fees.
Financial Information
This item is not applicable to this brochure. LFAS does not require or solicit prepayment of more than $1,200 in fees per
client, six months or more in advance. Therefore, we are not required to include a balance sheet for our most recent fiscal
year. LFAS is not subject to a financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients. Finally, LFAS has not been the subject of a bankruptcy petition at any time.
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CUSTOMER PRIVACY POLICY
WHAT DOES LEVEL FOUR DO WITH YOUR PERSONAL INFORMATION?
FACTS
Why?
The Firm(s) collects and develop personal information about clients and some of that information
is non-public personal information (Customer Information). The essential purpose for collecting
Customer Information is to provide and service the appropriate financial products and services
clients obtain from the Firm(s). The Firm(s) may share client information with one or more of our
affiliated companies (companies related by common ownership or control).
The affiliated companies of Level Four include Level Four Group LLC (LFG), Level Four Financial, LLC
(LFF), Level Four Advisory Services, LLC (LFAS), Level Four Capital Management, LLC, (LFCM) and
Level Four Insurance Services (LFIS) collectively (“the Firm(s)”). The Firm(s) may also have
relationships with other non-affiliated (companies not related by common ownership or control)
entities, including, insurance companies, trust companies, custodians and other financial institution
entities.
What?
The categories of Customer Information collected by the Firm(s) depend upon the scope of the
engagement with the individual affiliate entity and are generally described below. As investment
advisers, LFAS and LFCM collect and develop Customer Information about clients in order to provide
investment advisory services. As a broker dealer, LFF collects Customer Information about clients
in order to provide brokerage services. Customer Information collected includes:
▪
Information received from clients on financial inventories and questionnaires through
consultation with referring Advisory and Brokerage Representatives. This Customer
Information may include personal and household information such as income, spending
habits, investment objectives, financial goals, statements of account, and other records
concerning clients’ financial condition and assets, together with information concerning
employee benefits and retirement plan interests, wills, trusts, mortgages and tax returns.
▪
Information needed to open an account including social security numbers, investment
experience, assets, income, account balances.
▪
Information developed as part of financial plans, analyses or investment advisory services.
▪
Information concerning investment advisory account transactions, such as wrap account
transactions.
▪
Information about clients’ financial products and services transactions with LFAS, LFCM and
LFF.
▪ When you are no longer our customer, we continue to share your information as described in
this notice.
How?
All financial companies need to share customer’s personal information to run their everyday
business. In the section below, we
list the reasons financial companies can share their
customer’s personal information; the reasons Level Four chooses to share; and whether you
can limit this sharing.
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Reasons we can share your personal
information
Does Level Four
share?
Can you limit this
sharing?
Yes
No
Yes
No
For our everyday business purposes—
such as to process your transactions, maintain your
account(s), respond to court orders and legal investigations,
or report to credit bureaus
For our compliance with rules and regulations— information
about your transactions and communications provided to non-
affiliated brokerage or investment advisory firms when required to
comply with supervisory rules and regulations.
Yes
No
For our marketing purposes—
to offer our products and services to you
For joint marketing with other financial companies
Yes
No
Yes
No
For our affiliates’ everyday business purposes—
information about your transactions and experiences
No
We don’t share
For our affiliates’ everyday business purposes—
information about your creditworthiness
For our affiliates to market to you
No
We don’t share
For nonaffiliates to market to you
No
We don’t share
Level Four Financial, LLC, Level Four Advisory Services, LLC and Level Four Capital Management, LLC
Who we are
Who is providing this
notice?
What we do
To administer, manage and service customer accounts, process transactions and provide related
services for client accounts, it is necessary for Level Four to provide access to Customer Information
within the Firm and its affiliated companies and to non-affiliated companies, other investment
advisers, other broker-dealers, trust companies, custodians and insurance companies. The Firm(s)
may also provide Customer Information outside of the Firm as permitted by law, such as to
government entities, consumer reporting agencies or other third parties in response to subpoenas.
How we share
information with third
parties
LFAS and LFCM may also share information with Level Four Financial Services, LLC (LFF) which has
supervisory obligations over certain of LFAS’ and LFCM’s activities. As a result of the relationship,
LFF will have access to certain confidential information (e.g., financial information, investment
objectives, transactions and holdings) about LFAS’ clients, even if client does not establish any
account through LFF.
Level Four does not share Customer Information with affiliates or non-affiliated third parties for
marketing purposes.
How does Level Four
protect my information?
To protect your personal information from unauthorized access and use, we use security measures
that comply with federal law. These measures include computer safeguards and secured files and
buildings.
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We collect your personal information, for example, when you
▪ Open an account or perform transactions
▪ Make a wire transfer or tell us where to send money
▪ Tell us about your investment or retirement portfolio
How does Level Four
collect my personal
information?
We also collect personal information from others such as credit bureaus, affiliates and other
companies
Federal law gives you the right to limit only
▪ Sharing for affiliates’ everyday business purposes- information about your
creditworthiness
Why can’t I limit all
sharing?
▪ Affiliates from using your information to market to you
▪ Sharing for nonaffiliates to market to you
State laws and individual companies may give you additional rights to limit sharing. See below for
more on your rights under state law.
If you choose to opt out now; at any time in the future; or wish to withdraw your opt out
request, contact us at 866-834-1040. If it is your choice to opt out there will be a 30-day period
before your opt out will take effect.
How do I limit sharing?
Please note: If you are a new customer, we can begin sharing your information from the date we
sent this notice. When you are no longer our customer, we continue to share your information as
described in this notice. However, you can contact us at any time to limit our sharing.
If Level Four provides services to a joint account, the Firm(s) will treat the opt-out request by a joint
account owner as applying to all owners on the account(s) managed or serviced by any Level Four
entity.
What happens when I
limit sharing for an
account I hold jointly
with someone else?
Definitions
Companies related by common ownership, control, or directly involved in execution and settlement
of client transactions. They can be financial and non-financial companies.
Affiliates
The affiliated companies of Level Four include Level Four Group LLC (LFG), Level Four Financial, LLC
(LFF), Level Four Advisory Services, LLC (LFAS), Level Four Capital Management, LLC, (LFCM) and Level
Four Insurance Services (LFIS).
Companies not related by common ownership, control, or directly involved in execution and
settlement of client transactions. They can be financial and non-financial companies.
The Firm(s) may also have relationships with other non-affiliated entities, including insurance
companies, trust companies, custodians and other financial institution entities.
Nonaffiliates
Additionally, our primary clearing firm, Raymond James & Associates, is directly involved in execution
and settlement of client transactions. Level Four also has execution and custody relationships with
Schwab and Fidelity.
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A formal agreement between nonaffiliated financial companies that together market financial
products or services to you.
Joint Marketing
▪ Our joint marketing partners may include banks and credit unions
Other important information
Level Four understands that the relationship clients have with their Advisory Representative and/or Registered Representatives
(“Representative”) is important. If a client’s Representative ends his or her affiliation with Level Four and he or she chooses to
move to a different Firm, or if an Representative’s relationship with Level Four is terminated, the Representative may be allowed
to take with him or her copies of all client and account documentation (including but not limited to: account applications;
customer statements; and other pertinent forms related to the advisory services provided to the client by Level Four), so the
Representative is able to continue the relationship with his or her client and continue providing services through his or her new
firm. Level Four will also retain copies of its client and account documentation. Clients do not need to take action if it is their
choice to allow their Representative to keep copies of their confidential information should he or she leave Level Four. If you do
not want your Advisory Representative to keep copies of your confidential information, should he or she decide to end the
relationship with Level Four in the future, you have the right to opt out.
levelfourfinancial.com,
Vermont: In accordance with Vermont law, we will not disclose information about your creditworthiness to our affiliates and will
not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties
to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Additional
levelfouradvisors.com and/or
information concerning our privacy policies can be found at
levelfourcapital.com or call 866-834-1040.
California: In accordance with California law, we will not share information we collect about you with companies outside of
Level Four Financial, unless the law allows. For example, we may share information with your consent, to service your
accounts, or to provide rewards or benefits you are entitled to. We will limit sharing among our companies to the extent
required by California law. For additional information regarding your rights, please refer to the privacy notice (ccpa) for
California residents at levelfourfinancial.com, levelfouradvisors.com and/or levelfourcapital.com.
Nevada: In accordance with Nevada law, if you would like to be placed on our Internal Do Not Call List, please call 866-834-
1040. For more information, you may contact Level Four Financial Services, 11 North Water Street, Ste 21290, Mobile, AL 36602,
or the Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV
89101. Phone number: 1-702-486-3132; email: BCPINFO@ag.state.nv.us.
For Insurance Customers in AZ, CA, CT, GA, IL, ME, MA, MN, MT, NV, NJ, NC, OH, OR, and VA only. The term “Information” in
this section means customer information obtained in an insurance transaction. We may give your Information to state insurance
officials, law enforcement, group policy holders about claims experience, or auditors as the law allows or requires. We may
provide your Information to insurance support companies that may retain it or send it to others as needed to service your
account. We may share your medical Information so we can learn if you qualify for coverage, process claims, or prevent fraud or
if you provide authorization. To see your Information, write to Level Four Advisory Services, LLC at 12400 Coit Road, Suite 700,
Dallas TX 75251. You must state your full name, address, the insurance company, policy number (if relevant), and the Information
you are requesting. We will inform you of what Information we have. You may see and copy the Information (unless privileged)
at our office or ask that we mail a copy to you for a fee. If you think any Information is incorrect, you may submit a written
request to have the Information corrected. We will notify you of what actions are taken. If you do not agree with our actions,
you may send us a statement.
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BUSINESS CONTINUITY PLAN DISCLOSURE
LFAS has developed a comprehensive business continuity plan that covers LFAS’ operations. The plan is designed to
ensure that LFAS is prepared to continue providing service to clients in the event a significant disruption of any kind
occurs to LFAS’ business operations. The plan addresses business disruptions of varying severity and scope. It provides
for testing at least annually and in response to any material changes affecting LFAS’ business. Although it is impossible to
anticipate every scenario, the plan is reasonably designed to enable LFAS to resume doing business upon the occurrence
of those events that are most likely to affect LFAS.
What follows is a description of how LFAS will respond to the following four types of disruptions: (1) A firm-only
disruption, (2) a disruption that affects a single building, (3) a disruption that affects the entire city or business district, and
(4) a disruption that affects the entire North Texas region. LFAS has also included information about how long it expects
to take to recover from these disruptions.
Firm-Only Disruptions
To respond to a disruption that affects only LFAS, such as a computer virus, LFAS has on-site full-time employees who are
fingerprinted associated persons or registered representatives of Level Four Financial, LLC, to successfully guide LFAS
through disruptions that may affect operations, the use of crisis communications systems and procedures that address life,
health, and safety issues; damage assessment; damage mitigation; personnel mobilization and mission-critical systems. If
this type of disruption takes place, LFAS intends to restore all critical services within one day after the disruption occurs.
However, in light of the various types of disruptions of this nature that could take place, it may take longer to resume
operations in one or more services during any particular disruption.
Disruptions that Affect a Single Building
In the event of a disruption that affects LFAS’ office, such as a fire in the building, the plan calls for a response involving
multiple locations. LFAS will resume critical services by moving key personnel to an alternate location, to the extent
necessary. Certain key personnel may also work remotely by connecting to the RJA network from a remote location. In
addition to relocating key personnel to back-up facilities, LFAS will, if necessary, transfer responsibility for certain
operations and support services to an offsite location. LFAS intends to resume operations in all critical service areas within
one day after a disruption of this nature occurs. It may, however, take as long as two or three days to continue doing
business in one or more critical service areas depending on the availability of data.
Disruptions that Affect the Entire City or Business District
If a disruption significant enough to affect the entire city or business district, such as an Act of God or a terrorist attack
that cuts off access to LFAS’ office, under the plan, LFAS will resume critical services at a back-up location. As above,
certain key employees will work remotely, and certain operations and support services would be handled at alternate
locations. LFAS intends to resume operations in all of its critical service areas within one day after a disruption of this
nature occurs. It may, however, take up to three or four days to recover depending on the availability of data and on the
availability of key employees.
Disruptions that Affect the Entire North Texas Region
In the event of a disruption that affects the entire North Texas Region, such as a regional power outage, LFAS will resume
critical service areas from back-up locations. Although LFAS intends to resume operations within one day after the
disruption occurs, one or more critical service areas may not be able to resume operations until the disruption is over.
In all of the situations described above, LFAS expects to continue doing business and expects to resume operations within
the specified time frames. However, in the event that a business disruption results in a significant loss of life at LFAS’
office or otherwise results in key employees being unavailable or unable to report to their designated location, the
recovery times described above may be significantly increased. Furthermore, although LFAS expects to continue
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operating regardless of the type of disruption, it is impossible to anticipate every scenario. It is, therefore, possible that a
significant business disruption could occur and as a result, LFAS may be unable to continue doing business. In those
situations, the plan provides procedures to help ensure that the customers have prompt access to their funds and
securities.
LFAS will continue to devote substantial resources to the enhancement of its business continuity plan and procedures.
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