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ADV PART 2A ADVOCACY FINANCIAL
Advocacy Financial LLC (CRD 305954), brochure dated October 8, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
212 Park Place
Covington, LA 70433
(888) 787-4590
www.advocacyfinancial.com
Advocacy Financial, LLC
Financial Office of:
Joseph M. Prisco Jr., JD, CFP®
Nicholas A. Bowers, CFP®
Disclosure Brochure
This disclosure brochure provides information about the qualifications and business practices of Advocacy
Financial, LLC (“Advocacy Financial”, “Advisor” or “Firm”.) If you have any questions about the contents of this
brochure, please contact us at the phone number listed below. 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 Advocacy Financial, LLC is also available at the SEC’s website
https://adviserinfo.sec.gov. The Firm is a registered investment advisory firm. The registration does not imply
any level of skill or training. Please use this information as factors in your decision to hire the firm or to continue
a business relationship.
ITEM 1 – COVER PAGE, ADV PART 2A:
October 08, 2026
CRD #: 305954
www.advocacyfinancial.com
212 Park Place, COVINGTON, LA 70433
(888) 787-4590
Certified Financial Planner Board of Standards Inc. owns the certification marks CFP®, CERTIFIED FINANCIAL PLANNER™.
ITEM 2 – MATERIAL CHANGES
This brochure dated October 08, 2026, has been prepared by Advocacy Financial to meet state requirements. It has changed
materially since our last posting of this document on March 20, 2026, as follows:
ITEM 5 – FEES AND COMPENSATION
The hourly rate of financial planning is $300.00 per hour.
Advocacy Financial does not take receipt of more than $1200 in fees per client more than six (6) months in advance of the provision of
services represented by the fees. A partial initial fee of $1200 may be charged, and the remainder of the fees can be charged in arrears,
with the balance payable upon presentation of the analysis or completion of the agreed services.
ITEM 18 – FINANCIAL INFORMATION
Advocacy Financial does not solicit prepayment of more than $1200 in fees per client six (6) months or more in advance.
Disclosure Brochure, Form ADV Part 2A
2026
Advocacy Financial, LLC
ITEM 3: Table of Contents
Disclosure Brochure .............................................................................................................................................. 1
ITEM 1 – COVER PAGE, ADV PART 2A ................................................................................................................. 1
ITEM 2 – MATERIAL CHANGES ........................................................................................................................... 2
ITEM 4 – ADVISORY BUSINESS ........................................................................................................................... 4
ITEM 5 – FEES AND COMPENSATION ................................................................................................................. 7
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................... 10
ITEM 7 – TYPES OF CLIENTS.............................................................................................................................. 10
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ............................................. 11
ITEM 9 – DISCIPLINARY INFORMATION ............................................................................................................ 13
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................... 13
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ......................................................................................................................................................... 15
ITEM 12 – BROKERAGE PRACTICES ................................................................................................................... 15
ITEM 13 – REVIEW OF ACCOUNTS .................................................................................................................... 16
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ............................................................................ 16
ITEM 15 – CUSTODY ......................................................................................................................................... 17
ITEM 16 – INVESTMENT DISCRETION .............................................................................................................. 17
ITEM 17 – VOTING CLIENT SECURITIES ............................................................................................................. 17
ITEM 18 – FINANCIAL INFORMATION .............................................................................................................. 18
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ITEM 4 – ADVISORY BUSINESS
Since 2010, Advocacy Financial has been the Louisiana Limited Liability Company of the independent financial practice of founder,
Joseph M. Prisco Jr., JD, CFP®, primarily for accounting, tax, and liability purposes. The financial practice has served clients by providing
financial planning, investment advisory, and risk management capabilities enabled through third-party providers. As of January 2020,
Advocacy Financial, LLC filed to become a Registered Investment Advisor in the State of Louisiana. The main office is located in
Covington, Louisiana. In 2026 Advocacy Financial became eligible for SEC registration.
Principal Members
Joseph M. Prisco Jr, JD, CFP®, Managing Member/Chief Compliance Officer, 90% ownership. Mr. Prisco Jr. may be contacted by email at
jprisco@advocacyfinancial.com or by telephone at (888) 787-4590.
Advocacy Financial offers a broad array of financial planning and investment advisory services to clients. The mission is to be an
advocate for clients' financial and estate planning needs. Advocacy Financial helps manage, organize, and simplify financial affairs with
an emphasis on risk management. We seek to maximize client resources to obtain sustainable results. Customized services are offered
that strive to guide clients on an optimal path for asset accumulation, preservation, and wealth succession.
Prior to providing any advisory services, clients are required to enter into one or more written agreements with Advocacy Financial.
Financial Planning and Consulting Services
Financial Planning consists of a process of sourcing qualitative and quantitative information from clients combined with software tools
of the firm utilized by an experienced planner to recommend and help optimize a clients’ strategy, risk management situation, and in
its basic form, help clients with decision making in matters related to their life and financial interests, which are often closely tied.
Considering both the art and science of the process, Advocacy Financial typically takes a comprehensive view of a client and calls on a
deep knowledge and experience with business, law, tax, estates and successions, trusts, retirement plans and planning, among other
areas. If chosen by a client, as mentioned, financial planning will take into account information collected from the client such as
financial status, investment objectives, tax status, and financial resources, among other items. Financial Planning may also be limited
in scope. Our fiduciary obligation is to always act and make recommendations in the clients’ best interest.
Financial Planning includes the use of software for reviews and projections and may apply to any or all of the following areas depending
on the Client’s circumstances:
Other Insurance Analysis & Strategy
Disability Planning
Tax Management & Planning
Trust and Estate Planning
Retirement Planning
Business Planning
Charitable Giving
Risk Management
Asset Planning – Location and Allocation
Budgeting and Cash Flow Planning
Debt Management
Capital Needs Analysis (Goal Funding)
Education Planning
Portfolio Review and Evaluation
Data and Documents Requested for Financial Planning may include:
Personal Data
Family and personal information, including dates of birth, family tree, any special needs, and health status
Investment Account Information
Brokerage account statements
Annuity statements – (e.g., fixed, variable, index)
Mutual fund statements
Roth IRA, traditional IRA, and other tax advantaged account statements
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Any pension, deferred compensation, defined contribution (e.g., 401(k), 403(b) 457 SIMPLE, SEP) and profit sharing
plan statements
Stock, bond, certificate of deposit, and other security statements
Restricted stock plans and stock options statements
Insurance Policies
Group benefits – (e.g., health, disability, life, legal plans)
Individually owned policies – ( e.g. life, health, disability, long term care, annuities, homeowners or renters, auto,
liability umbrella)
Public insurance and benefits statements
Education / Minor’s Savings Acct
Education/ Minor’s Savings Account Statements
529, Coverdell, UTMA, and UGMA accounts
Tax Returns, Other Financial and Legal Documents
Tax Returns, Other Financial and Legal Documents
Previous two (2) years of income tax returns, including any gift tax returns previously filed
Information on approximate value of collectable assets
Partnership interest: (e.g., prospectuses, latest reports, K1 tax forms)
Savings and bank account balance information
Copy of a recent pay stub(s)
Household budget, if available
Any estate planning documents, including information on any interests in trusts
Real Estate Statements
Approximate fair market value info, using online real estate estimates or appraisals
Mortgage statements, including basic provisions (start, rate, term, payment) of any mortgages and information
regarding any repayments
Other Liability Statements
Terms of loans and information regarding any note payments such as auto, personal debts, etc.
Financial planning services can vary and are customized depending on each client’s circumstances and client requests. The financial
planning services will be defined and agreed upon by both parties in advance. In addition, the amount of time it takes to provide
these services is dependent on the quality and scope of the information that is provided by the client. In performing these
services, Advocacy Financial is not required to verify any information received from the client or from the client’s other
professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information.
Beyond ordinary Financial Planning, Advocacy Financial provides an array of customized Consulting Services which may vary
greatly in depth and scope and may be offered in a variety of different situations or circumstances. We may consult regarding
topics that are not covered under our general financial planning services or may not rise to the level of financial planning in the
extent of data-gathering and breadth and depth of recommendations. We may consult on such items as a real estate purchase, a
sale analysis, a review of a financial account, among other circumstances. The scope and cost of our consulting services are to be
defined in writing prior to the engagement and will depend on the complexity of the situation. Consulting and Financial Planning
services can be offered to any client who the advisor deems to have circumstances that could be aided by our services. Some
factors in this determination may be the advisor’s experience and level of expertise with the situation.
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Disclosure Brochure, Form ADV Part 2A
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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 interests ahead of yours. As
fiduciaries we are obligated to do the following:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
A conflict of interest exists due to Advocacy Financial having a financial incentive to offer itself for investment management and/or
its associated registered reps and insurance agents for the purchase or sale of securities or insurance products where it receives
a fee or part of a commissions or other additional compensation as a result of recommendations. In addition, there is an incentive
to recommend a law firm under a common owner for legal services. This conflict is mitigated through disclosure and by making
recommendations in the best interest of clients. Clients always have the right to act or not act on any of the recommendations
by Advocacy Financial. Please see Other Industry Activities and Affiliations for more information.
Investment and Wealth Management Services
Advocacy Financial manages client investment portfolios on a discretionary or non-discretionary basis.
As a fiduciary, Advocacy Financial always acts solely in a client’s best interests. Client portfolios are customized based on
investment objectives. Advocacy Financial works with clients to identify their qualitative and quantitative information to
determine investment goals and objectives, as well as risk tolerance, in order to recommend an appropriate portfolio allocation
designed to complement the clients’ financial goals and objectives. Advocacy Financial may create a portfolio, consisting of, but
not limited to, exchange traded funds (ETFs), individual stocks, bonds, annuities, REITS, options, no-load funds, and/or load-waived
funds.
Once an appropriate portfolio has been implemented, we will review the portfolio and rebalance periodically based upon client’s
individual needs, goals, objectives, as well as macroeconomic circumstances. Advocacy Financial seeks to meet client investment
objectives while providing clients with access to perspective and advice over time. Advocacy Financial may also provide advice
about any type of legacy position or other investment held in client portfolios.
Clients may engage Advocacy Financial to advise on certain investment products that are not maintained at a recommended
custodian, such as variable life insurance and annuity contracts, and other assets held in employer sponsored retirement plans
and qualified tuition plans. We may be asked to conduct asset management services for client’s held-away accounts (i.e., 401(k)
participant accounts, etc.). In order to provide these services, the client will need to verify any custodial policies, provide our firm
with account access information and advisor authorization or a limited power of attorney to provide services for the account;
subsequently, such access may allow for control over those assets. In such event, Advocacy Financial can recommend and
potentially allocate the account assets among the investment options available on the platform. Advocacy Financial will likely be
limited to making recommendations regarding the allocation of the assets among the investment alternatives available through
the sponsor. Advocacy Financial will likely not receive communications from the sponsor or custodian, and it shall remain the
client’s obligation to notify Advocacy Financial of any changes in investment alternatives, restrictions, etc. pertaining to the
account.
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Clients may make requests or suggestions in writing regarding the investments in a portfolio. However, restrictions on trading
which, in Advocacy Financial’s opinion, are not in a client’s best interest cannot be honored, and if forced, may result in the
termination of an agreement.
In cases where Advocacy Financial is not provided discretion by the client, the firm must receive permission from the client to
make any trades on a non-discretionary basis. In non-discretionary accounts, clients have the right to decide whether to act upon
Advocacy Financial’s recommendations. If clients elect to act on any of the recommendations, client has the right to affect a
transaction through a provider unaffiliated with Advocacy Financial.
ERISA 3(21) Fiduciary Services
As part of our fiduciary responsibilities, we offer ERISA 3(21) services to clients with employee benefit plans subject to the
Employee Retirement Income Security Act of 1974 (ERISA). Under this service, we act as a co-fiduciary alongside the plan sponsor,
providing advice and recommendations on plan investment options. Specifically, our role includes:
1.
Investment Selection and Monitoring: We assist in the selection, evaluation, and ongoing monitoring of investment options
available to plan participants, ensuring these options align with the plan's objectives and comply with ERISA's prudence and
diversification requirements.
2.
Investment Advice: We provide non-discretionary advice regarding the investment decisions for the plan, including asset
allocation and fund choices. Our recommendations are designed to help the plan sponsor meet their fiduciary duty to act in
the best interest of plan participants and beneficiaries.
3. Ongoing Plan Review: We provide periodic reviews of the plan’s investment lineup and provide updated recommendations
based on performance, market conditions, and changes in regulatory requirements.
As a 3(21) fiduciary, we do not have discretionary authority over plan assets but offer expert guidance to assist the plan sponsor
in fulfilling their fiduciary duties under ERISA. This service is designed to help plan sponsors make informed, prudent decisions in
the best interest of participants and beneficiaries while mitigating potential fiduciary risk.
Wrap Program
Advocacy Financial does not sponsor nor provide portfolio management services to a wrap fee program.
Assets Under Management
Advocacy Financial, as of December 31, 2025, had $103,416,660 in discretionary reportable assets under management and $0 in non-
discretionary reportable assets under management for a total of $103,416,660 in assets under management.
ITEM 5 – FEES AND COMPENSATION
Financial Planning and Consulting Fees
Advocacy Financial generally charges fees for financial planning and consulting services on a fixed basis, however, an hourly
arrangement may be utilized. After a no-fee and no-obligation initial consultation, based on the services requested by the client,
Advocacy Financial should prepare a quote for services to be provided. Flat fees are based on the complexity, nature, and time
required to gather, analyze, and interpret relevant information. As plans and consulting become more complex, require additional
expertise, and cover multiple topics, they may require additional time and fees. Fees are negotiable, but generally, fixed fee
arrangements usually range from $1000 to $10,000. The hourly rate of financial planning is $300.00 per hour.
Advocacy Financial does not take receipt of more than $1200 in fees per client more than six (6) months in advance of the provision
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of services represented by the fees. A partial initial fee of $1200 may be charged, and the remainder of the fees can be charged in
arrears, with the balance payable upon presentation of the analysis or completion of the agreed services. For clients with
investment accounts managed by Advocacy Financial under a separate agreement, we may discount or waive all or a portion of
the financial planning and/or consulting fees.
Financial planning and consulting fees may be paid by personal check or the client may elect, by written authorization, to have
their fee debited from an Advocacy Financial managed non-qualified account with a custodian approved for such fee debit
payments. Advocacy Financial will send the client a written invoice including the fee, the formula used to calculate the fee and
the time period covered by the fee, and if applicable, the amount of assets on which the fee was based. Clients may terminate
agreements at any time, and if an agreement is terminated prior to completion, Advocacy Financial will invoice for all earned fees
as of the date of termination. All fees will be disclosed to clients in writing prior to the engagement, and clients always have the
right to decide whether to engage Advocacy Financial for Financial Planning or Consulting Services. Lower fees for comparable
services may be available from other sources.
Advocacy Financial has a conflict of interest due to offering financial planning, consulting, and investment management services,
among other implementation capabilities. For example, when providing financial planning and consulting services, Advocacy
Financial has an incentive to recommend itself for investment management services as Advocacy Financial receives additional
compensation. Advocacy Financial mitigates conflicts of interest by disclosing conflicts to clients. If a conflict exists between
the interests of the Advisor or its associated persons and the interest of a client, the conflict should be disclosed. The client always
has the right to decide whether to act on any of the recommendations made by Advocacy Financial. If client elects to act on any
of the recommendations, client has the right to effect transactions through a professional unaffiliated with Advocacy Financial.
Our fiduciary obligation is to always act and recommend in the clients’ best interest. Please see Other Industry Activities and
Affiliations for more information.
Investment Management Fees
Advocacy Financial offers investment management services and compensation for those services are calculated in accordance
with an Investment Advisory Agreement signed by a client. The fee is negotiable and can vary depending on:
Size of the relationship – actual or potential, i.e., larger balance accounts may receive more favorable pricing.
Level of services needed – clients requesting more services may have higher fees, or reduced rates.
Client relationship – history, legacy, or other relationship considerations.
Trading activity and portfolio management – actively managed accounts can have higher fees.
Employee and family related accounts can be charged reduced fees.
•
• Accounts within the same household may be combined for a reduced fee.
•
•
•
• Account with certain allocation types may have lower fees.
•
Advocacy Financial will not discriminate on the basis of race, color, religion (creed), gender, gender expression, age, national
origin (ancestry), disability, marital status, sexual orientation, or military status.
In consideration of the services, Advocacy Financial charges a quarterly fee withdrawn directly from the Account(s) after the
end of a quarter. The fee is determined by taking the annual percentage rate Client is charged, divided by four, multiplied by
the quarter-end market value of the account. For example, a $1,000,000 account balance at the end of a quarter charged at
a 1% annual rate is charged .25% per quarter, so $1,000,000 x .0025 = $2,500. The market value is the sum of the values of all
assets in the account, not adjusted by any margin debit. In cases where an agreement commences or terminates during a
partial quarter, the Account will be charged on a pro-rated basis based on the number of days of service.
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The below regular fee schedule may be utilized, or the Advisor and Client may agree on a Flat Fee percentage rate. The Fee
may be amended from time to time by written agreement signed by Client and Advisor.
ANNUAL FEE Rate (%)
ASSETS UNDER
MANAGEMENT
$0 – $249,999
2.00%
$250,000 – $499,999
1.50%
$500,000 – $999,999
1.25%
$1,000,000 -- $2,499,999
1.00%
$2,500,000 – $5,000,000
0.75%
Over $5,000,000
Negotiable
Generally, there is a minimum Account Size of $50,000 for an account, however, Advocacy Financial may be able to accommodate
on a case-by-case basis. While we strive to maintain competitive fees, the same or similar services may be available from other
firms at higher or lower fees.
For purposes of determining value, securities and other instruments traded on a market for which actual transaction prices are
publicly reported are valued at the last reported sale price on the principal market in which they are traded.
When we provide investment management services, we do not charge additional fees to generally coordinate with your other
professionals, such as attorney and/or accountant. Our fee includes the time and activities necessary to work with your other
professionals in finding solutions, as well as assisting them in implementation of appropriate documents. We are not responsible
for attorney, accounting, or other professional fees charged to you as a result of the above activities.
Advocacy Financial requires written authorization from the client to deduct advisory fees from an account held by a qualified
custodian. Advocacy Financial sends the qualified custodian written notice of the amount of the fee to be deducted from the
client’s account. Advocacy Financial will send the client a written invoice itemizing the fee, including the formula used to calculate
the fee, the time period covered by the fee, and the amount of assets under management on which the fee was based. Advocacy
Financial fees are paid from the account by the custodian when we submit an invoice to them. We strongly urge you to compare
our invoices to custodian statements for accuracy. If there is insufficient cash in your account to pay your fees, securities in your
portfolio may be sold to cover the fee.
While we seek to minimize other charges and fees, such as custodian and broker-dealer commissions, account transfer fees, short-
term trading penalties, 12b-1 fees, and other similar charges,, these charges are to be paid out of the assets of client accounts or
billed separately to the client and are in addition to investment advisory compensation paid to Advocacy Financial. While we take
measures to ensure the fees charged are accurate, it is your responsibility to ensure the amount of fee charged is correct. In
addition to invoices and reports sent by us, you will receive statements directly from custodians.
Advocacy Financial does not accept commission for the sale of securities or other investment products in managed account(s),
including asset-based sales charges, or service fees from the sale of mutual funds or any other charges from the custodian. 12b-
1 fees on accounts are retained by the custodians. For accounts which include No-Transaction Fee (NTF) mutual funds and/or NTF
exchange traded funds, 12b-1 fees are paid to the custodian in lieu of the client paying transaction or trading costs. If a fund
participates in the NTF platform and does not have a 12b-1 fee, the custodians generally receive a portion of the fund management
fee. The participation of funds in an NTF platform generally does not increase the cost of the same share-class of the fund to the
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client. Funds that do not participate in a custodian’s NTF platform may have lower expense ratios, which may result in a lower
annual cost to the client; however, the client will likely incur transaction fees and trading costs.
Clients may make additions and withdrawals in their account at any time, subject to Advocacy Financial right to terminate an
agreement. Additions may be in cash or securities. Advocacy Financial reserves the right to liquidate any transferred securities
and can decline to accept particular securities. Clients may withdraw account assets, subject to securities settlement procedures.
Advocacy Financial generally designs client portfolios as long-term investment accounts and a withdrawal of assets may impair
the achievement of a client’s objectives. We may consult with its clients about the implications. Clients are advised that when
transferred securities are liquidated, they may be subject to custodian transaction fees, short-term redemption fees, fees assessed
at the fund level (e.g., contingent deferred sales charges) and/or tax implications.
When we conduct asset management services for client’s held-away accounts, the account billing cycle begins once the client
agreement is executed and account assets have settled into the client’s separately identifiable account held by the custodian(s)
of record, or once held-away account management access has been achieved for accounts being managed on a held-away basis.
Depending on the custodian, fees for held-away asset account management may be charged in a direct or indirect manner (i.e.,
from another of the client’s accounts managed by Advocacy Financial at a recommended custodian).
The investment advisory contract may be terminated by the client within five (5) days of signing the agreement without incurring
any advisory fees or penalty. Ongoing, Advocacy Financial and clients can terminate agreements at any time upon receipt of
written notice to the other party. If an agreement is terminated, and Advocacy Financial holds any pre-paid unearned fees, refund
will be made within 30 days of the effective date of termination.
Commissionable Securities Sales
Representatives of our firm are registered representatives of Purshe Kaplan Sterling Investments, Inc (“PKS”), member
FINRA/SIPC. As such they are able to accept compensation for the sale of securities or other investment products, including
distribution or service (“trail”) fees from the sale of mutual funds. Clients should be aware that the practice of accepting
commissions for the sale of securities presents a conflict of interest and gives our firm and/or our representatives an incentive to
recommend investment products based on the compensation received. Our firm generally addresses commissionable sales
conflicts that arise when explaining to clients these sales create an incentive to recommend based on the compensation to be
earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds are also available.
Joseph M. Prisco Jr., managing member and CCO, has additional capacities that create a conflict of interest. Please see Other
Financial Industry Activities and Affiliations for more information.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Advocacy Financial does not charge advisory fees based on the performance in your account, and therefore, does not engage in “side
by side management.”
ITEM 7 – TYPES OF CLIENTS
Advocacy Financial generally provides financial planning, consulting, and asset management services to the following types of
clients:
Individuals
Trusts
Estates
High-Net-Worth Individuals
Business Entities
Pension and Profit-Sharing Plans
Charitable Entities
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Generally, there is a minimum account size of $50,000 for an account, however, Advocacy Financial may be able to accommodate on
a case-by-case basis.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
When creating client investment recommendations, Advocacy Financial considers relevant client information including return
objectives, risk tolerance, investment constraints, among other items. Constraints include items such as time horizon, tax
considerations, legal constraints, liquidity requirements, or other various suitability factors identified by the advisor and client.
We analyze multiple aspects of a client’s financial situation and objectives through a consultative approach, so that we can review
forecasts and potential outcomes prior to recommending a specific portfolio.
Advocacy Financial’s objective is long term appreciation and to help clients manage risk and returns while providing perspective
in various market cycles and economic conditions to help avoid mistakes. Advocacy Financial abides by principles rooted in
common sense and modern portfolio theory, namely, diversification and asset allocation. The focus is on steady growth and capital
preservation, but each client has different needs and unique circumstances.
Advocacy Financial focuses on cost-effective, after-tax results, aware that what matters is the net-return actually received by the
client. Advocacy Financial does not rely on any one strategy or investment type. Advocacy Financial works to utilize what we
believe to be the best available investment types for the client’s portfolio.
Advocacy Financial uses multiple sources of information to obtain analysis and strategies, including sources such as subscriptions
to economist’s research, market strategist research, financial publications, custodian’s economic research, webinars, financial
conferences, corporate rating services, prospectuses, company press releases, annual reports, and filings with the SEC.
Investment Strategies
Advocacy Financial’s methods of analysis include strategies centering on the tradeoff between risk and return. “Asset allocation”
and “diversification” based on Modern Portfolio Theory and Post-Modern Portfolio Theory, as well as behavior aspects to finance
are most notably considered. Advocacy Financial has a sliding-risk-scale of portfolios based on potential volatility and expected
return, as well as account type, for example, tax deferred or taxable account types. Allocating funds to different classes of financial
assets can generally result in diversification. Diversification can potentially lower risks and volatility as different assets can react
differently to any given economic environment.
Modern Portfolio Theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of
portfolio risk, or equivalently minimize risk for a given level of expected return, by choosing the proportions of various asset.
Post-Modern Portfolio Theory is a portfolio optimization methodology that uses the downside risk of returns instead of the mean
variance of investment returns used by modern portfolio theory (MPT). Both theories describe how risky assets should be
valuated, and how rational investors should utilize diversification to achieve portfolio optimization. The difference lies in each
theory's definition of risk, and how that risk influences expected returns.
Portfolios generally utilize historical data in an attempt to predict an expected risk and expected return of a particular portfolio.
Subscription software assists in a forward-looking exercise. Advocacy Financial seeks to exceed the expected return of the
portfolio, as this would add value for clients. Nevertheless, past results and expected returns are not a guarantee of the future,
and actual returns.
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Risk of Loss
All investments include a risk of loss and volatility that clients should be prepared to bear. Performance of any investment is not
guaranteed. We use our best efforts, experience, and expertise to manage assets, however, we cannot guarantee any level of
performance or that clients will not experience financial loss.
Modern Portfolio Theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected
return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same
for investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected
return profile i.e., if for that level of risk an alternative portfolio exists which has better expected returns.
The differences in risk, as defined by the standard deviation of returns (volatility,) between Post Modern Portfolio Theory and
Modern Portfolio Theory is the key factor considered in portfolio construction. Modern Portfolio Theory assumes symmetrical risk
whereas Post Modern Portfolio Theory assumes asymmetrical risk. Symmetric risk is when the risk and reward payoff are equal.
Asymmetric risk is the risk an investor faces when the gain realized from the move of an underlying asset in one direction is
significantly different from the loss incurred from its move in the opposite direction. Downside risk is measured by target semi-
deviation, termed downside deviation, and captures what investors fear most: negative returns.
Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (aside
from bank CDs and Treasury securities) are not guaranteed or insured by the FDIC or any other government agency.
Equity investments generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital
gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each
company, industry conditions, and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of
investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and
structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type
of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As
interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed
income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties.
The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit minimal.
Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds
have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature,
among other variations. Shares of mutual funds are generally distributed and redeemed by the fund itself or a broker acting on
its behalf. The trading price at which a share is transacted is equal to a fund’s net asset value (“NAV”), plus any shareholders’ fees
(e.g., sales loads, purchase fees, redemption fees). The NAV of a mutual fund is calculated at the end of a business day. A trading
price of a mutual fund may differ significantly from the NAV during periods of market volatility which may lead to a mutual fund’s
shares trading at a premium or discount to NAV. Shareholders are also liable for taxes on any fund-level capital gains, as mutual
funds and ETFs (see below) are required to distribute capital gains in the event securities are sold and cannot be offset.
An ETF is an investment fund traded on stock exchanges, similar to stocks, which generally attempts to track an index, hence they
may be termed “index funds.” ETFs offer investors a way to pool money in a fund that makes investments in stocks, bonds, other
assets, or some combination of these investments and, in return, receive an interest in that investment pool. ETFs do not sell
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individual shares directly to, or redeem their individual shares directly from, retail investors. Instead, ETF shares are traded
throughout the day on national stock exchanges and at market prices that may or may not be the same as the NAV of the shares.
Investors in ETFs cannot directly influence which securities are included in the funds’ portfolios. Investing in ETFs carries the risk
of capital loss. Areas of concern include index tracking error, the lack of transparency in products, increasing complexity, conflicts
of interest, and the possibility of inadequate compliance. Although generally not utilized, precious metal and commodity ETFs
may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant
portion of aggregate world holdings, (2) a significant increase in hedging activities by producers, (3) a significant change in the
attitude of speculators and investors.
Annuities are insurance company issued products for those who may have the ability to pay a premium and desire to receive
certain payments immediately or at some point in the future. Annuities are generally designed to meet long-term goals. An
annuity is not a life insurance policy but may have death benefits as well as living benefits. Annuities come in many variations,
including variable annuities, which are designed to be long-term investments, and meet retirement and other long-range goals.
Annuities are typically not suitable for meeting short-term goals because substantial taxes and insurance company charges may
apply if funds are withdrawn early. Annuities, especially variable annuities, also involve investment risks.
Advocacy Financial may recommend an investment or allocation in real estate investment trusts (“REITs”), the shares of which
can be either publicly traded or privately placed securities. REITs are investment vehicles with portfolios comprised mainly of real
estate and mortgage related holdings. REITs can hold concentrations of investments tied to commercial and/or residential
developments, which subject REIT investors to the risks associated with a downturn in the real estate market. REITS can give rise
to interest rate risk, inflation, liquidity, counter-party risk, among other considerations.
Advocacy Financial may recommend option contracts. Investments in options contracts have the risk of losing value in a relatively
short period of time. Option contracts are instruments that allow the holder of a contract to control, reduce, or increase risk of
other shares of an underlying security. Leverage, or borrowing for the purchase of options, can be used to offset risk but can also
compound gains or losses.
ITEM 9 – DISCIPLINARY INFORMATION
Neither Advocacy Financial nor any of its associated personnel have ever been the subject of a reportable disciplinary or legal
event.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Advocacy Financial is not registered, nor does it have an application pending to register, as a broker-dealer, futures commission
merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities.
The principal business of Advocacy Financial is that of a registered investment advisor and provider of financial planning services.
However, Advocacy Financial personnel may have additional capacities beyond financial planning and asset management, for
example, as a lawyer, registered rep of a broker-dealer, and insurance agent. Multi-faceted Professionals can significantly benefit
Clients due to increased breadth of skill, knowledge, and experience, however, Client must acknowledge that professional services
pursuant to an Investment Advisory or Financial Planning Agreement are financial in nature only and are distinct and separate
from other services, and the additional capacities create a conflict of interest due to additional compensation abilities. Other
services are provided under a separate agreement(s) and are compensated for under separate arrangement(s). Client
acknowledges that compensation by other services may influence a strategy recommended and there exists a potential or real
conflict of interest. Furthermore, other services do not carry protections normally afforded as part of the services of registered
investment advisors and are provided pursuant to distinct regulation and distinct licensing requirements.
Joseph M. Prisco Jr. is a licensed practicing attorney admitted to the Bar of the State of Louisiana. Joseph M. Prisco Jr.’s legal
practice is separate and distinct from financial planning and investment advisory services. In limited circumstances, he may serve
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as legal counsel to Advocacy Financial’s advisory clients. These services are provided pursuant to a separate engagement and for
separate fees, which are agreed upon prior to rendering legal services. A conflict of interest exists to the extent that Advocacy
Financial recommends clients engage Joseph M. Prisco Jr. in the capacity as a lawyer and he receives compensation as a result.
Clients have the right to decide whether to use Mr. Prisco’s legal services. As a fiduciary, Advocacy Financial will only make a
recommendation when it is in the client’s best interest.
Joseph M. Prisco Jr. is the managing member of Legacy Louisiana, LLC. Legacy Louisiana is a platform for attorneys and their clients to
market and provide technology for certain legal services and is one-third owned by Mr. Prisco.
Representatives of our firm are registered representatives of PKS, member FINRA/SIPC, and licensed insurance agents. As a result
of these transactions, they receive commissions. A conflict of interest exists as these commissionable sales create an incentive to
recommend products based on the compensation earned. To mitigate this potential conflict, our firm will act in the client’s best
interest.
Advocacy Financial will disclose any material conflict of interest relating to Advocacy Financial, its representatives, and any of our
associates which could reasonably be expected to impair the rendering of unbiased and objective advice. As fiduciaries, Joseph M.
Prisco Jr. and Nicholas A. Bowers will only act in the client’s best interest.
Item 10c. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests
The principal business of Advocacy is that of a registered investment adviser and provider of financial planning services. Some of
the principals and associated persons of the firm are licensed as insurance agents and consultants. When acting in the capacity of
an insurance agent, the Adviser and associated persons receive the usual and customary commissions or fees associated with the
insurance products that the client purchases. Receiving commissions on insurance products may create a conflict of interest. To
mitigate this conflict, clients are informed of the potential compensation received, and the client is reminded that they are free
to select another insurance broker for implementation of advisor's insurance recommendations and all recommendations are
made in accordance with the fiduciary duty owed to our clients.
Item 10d. - Selection of Other Advisors and How this Advisor is Compensated for those Selections.
Advocacy Financial may recommend outside money managers or sub-advisors.
In the event that we recommend a Sub-Adviser, we do not share in their advisory fee. Our fee is separate and in addition to their
compensation (as noted in Item 5 of this brochure). In addition, Clients will receive a copy of the Sub-Adviser’s Form ADV 2A,
Firm Brochure, which also describes the Sub-Adviser’s fee. You are not obligated, contractually or otherwise, to use the services
of any Sub-Adviser we recommend.
SyntheticFI
Advocacy Financial has a relationship with SyntheticFI. The client pays the SyntheticFI management fee.
The fees charged by SyntheticFi will be disclosed to the client in the ADV Part 2A and in their client agreement.
SyntheticFi will not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any
portion of the funds of the Account.
O’Shaughnessy Asset Management, L.L.C. doing business as Canvas
Advocacy Financial has a relationship with Canvas. The client pays the Canvas management fee.
The fees charged by Canvas will be disclosed to the client in the ADV Part 2A and in their client agreement.
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Canvas will not be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion
of the funds of the Account.
Due Diligence and Oversight
Advocacy Financial will conduct due diligence on Sub-Adviser platforms and the underlying investment strategies to confirm that
the use of these Sub-Advisers is suitable and consistent with a client’s goals.
Advocacy Financial conducts initial and ongoing due diligence on Sub-Advisers, which may include a review of the manager’s
registration status, regulatory history, investment strategy, performance history, fee structure, operational capabilities, and
compliance policies. Advocacy also periodically reviews account performance and other relevant information provided by the Sub-
Adviser. However, Advocacy does not control the day-to-day management of assets by Sub-Advisers and cannot guarantee their
future performance.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING
We have adopted a Code of Ethics to which all investment advisor representatives and employees are bound to adhere. The key
component of our Code of Ethics states that Advocacy Financial and its investment advisor representatives and employees shall
always:
• Act with integrity, competence, dignity, and ethically when dealing with the public, clients, prospects, employers,
•
and employees.
Exercise authority and responsibility for the benefit and interest of clients first and to refrain from having outside
interests that conflict with the interests of its clients.
• Avoid any circumstances that might adversely affect its duty of loyalty to its clients.
• Refrain from disclosing any nonpublic personal information about a client to any nonaffiliated third party unless the
client gives permission to Advocacy Financial to do so. All client information will otherwise be treated as confidential.
• Maintain the security of nonpublic information, including information stored on computers.
In addition, our practice is to monitor personal securities transactions of employees who have prior or concurrent access to client
trade information. Advocacy Financial always tries to obtain the best price for the client. Advocacy Financial has in place processes
to allow contemporaneous trading (submitting Advocacy Financial or employee orders at the same time as client order) in block
or aggregate trades. In other cases, except in the case of unaffiliated mutual funds, we will always trade individual securities in a
client account before we trade Advocacy Financial or employee accounts. Advocacy Financial, or its employees, may buy and sell
some of the same securities for our own accounts that we buy and sell for clients. In some cases, Advocacy Financial, or its
employees, may buy or sell securities for our own accounts and not for clients’ accounts, as it may not meet the objectives or
plans for the client. We will always evaluate our activity from the viewpoint of clients to ensure that any and all required
disclosures are made. For example, we will disclose anything that would cause clients to be unfairly influenced to make any
decision regarding actions or inactions in client accounts. Advocacy Financial does not buy or sell between Advocacy Financial, our
employees or our clients’ accounts.
ITEM 12 – BROKERAGE PRACTICES
Advocacy Financial does not maintain custody of your assets that we manage. Your assets must be maintained in an account at
a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use either Fidelity Institutional Wealth
Services (“Fidelity”) or Charles Schwab & Co. Inc. (“Schwab”) as the qualified custodian. Advocacy Financial is independently
owned and operated and not affiliated with Fidelity or Schwab.
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Custodians will hold your assets in a brokerage account and buy and sell securities when instructed to do so. While we recommend
that you use Fidelity or Schwab as custodian/broker, you will decide whether to do so and open your account by entering into an
account agreement directly with them. If you do not wish to place your assets with Fidelity or Schwab, then we cannot manage
your account. Fidelity and Schwab are third-party custodians and will provide clients with monthly statements and confirmations
of actions in an account, including asset values and any additions or withdrawals. It is recommended that clients review custodian
statements for accuracy. Advocacy Financial does not receive client referrals from Fidelity or Schwab.
Advocacy Financial has selected Fidelity and Schwab based on experience, financial strength, reputation, price, reliability, speed
of processing, tools, research, “best execution,” among other considerations. Advocacy Financial will periodically review its
recommendation for a custodian in light of its duty to clients. While clients are not required to effect transactions through any
custodian recommended by us, we believe we have made our selections based on a totality of benefits they offer and can only offer
our services based on our recommendations. Advocacy Financial does not permit clients to direct brokerage managed assets.
Advocacy Financial may purchase or be provided with software, tools, training programs, seminars, conferences, and education
services from the custodian as non-financial benefits for using custodian’s services. These benefits are sometimes referred to as
“soft dollar” benefits. Advocacy Financial endeavors, at all times, to act in the client’s best interest, but clients should be aware
that the receipt of the benefits discussed above can create conflicts of interest by influencing the choice of a Custodian.
1. Advocacy Financial adheres to the Code of Ethics as outlined above.
2. Advocacy Financial believes the benefits provided by custodians for clients and Advocacy Financial far outweigh any
potential drawbacks.
3. Advocacy Financial will always act in accordance with all applicable federal and state regulations governing
registered investment advisory practices.
4. Advocacy Financial emphasizes that you always have the right to choose another investment advisor to avoid any
conflict of interest.
Advocacy Financial is authorized to aggregate purchases and sales and other transactions made for clients with purchases and
sales and other transactions in the same or similar securities or instruments for other clients. When aggregate transactions are
done, the actual prices applicable to the aggregated transactions will be averaged, and the account will be deemed to have
purchased or sold its proportionate share of the securities or instruments involved at the average price obtained.
Directed Brokerage
For held-away accounts with an outside custodian of the client’s choice, the client may choose to request that a particular broker
is used to execute some or all account transactions. Under these circumstances, the client will be responsible for the terms and/or
arrangements involving their account with that broker. Advocacy Financial will not be obligated to seek better execution services
or prices from these other brokers, and we will be unable to aggregate transactions for execution via our custodian with other
orders for accounts managed by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially
experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case.
ITEM 13 – REVIEW OF ACCOUNTS
Accounts receiving investment management services are reviewed by Joseph M. Prisco Jr. and Nicholas A. Bowers, the frequency
of reviews is determined based on client’s investment objectives, not less than quarterly. More frequent reviews are triggered by
a change in client objectives, tax considerations, large deposits or withdrawals, large sales or purchases, changes in management,
changes in economic climate, among other considerations. Clients should inform Advocacy Financial of any changes to
circumstances. At least annually, Clients and Advocacy Financial should review your financial goals, investment objectives, and
any life changes.
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Accounts receiving investment management services are monitored and performance reports of certain investments are provided
by request, and quarterly. Portfolio reports are generated with data provided by the custodian. Investment advisory clients also
receive standard account statements from the custodian of their accounts. We recommend clients compare reports to custodian
statements for accuracy.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
Advocacy Financial does not receive economic benefits from third parties for the advice we render to our clients.
ITEM 15 – CUSTODY
As noted in Item 12, Advocacy Financial, LLC, does not maintain custody of client assets. Third party custodians are utilized for
custody, brokerage, and clearing services of client assets: Fidelity Institutional Wealth Services (“Fidelity”) and Charles Schwab &
Co. Inc. (“Schwab”). Fidelity and Schwab are third-party custodians and will provide clients with monthly statements and
confirmations of actions in an account, including asset values and any additions or withdrawals. Advocacy Financial never has
physical custody of client funds or securities. Assets will be maintained by an unaffiliated custodian. Advocacy Financial is deemed
to have custody of client funds solely because of the client authority to deduct advisory fees from client accounts. The custodian
will send client statements as least quarterly, which will include fees charged by Advocacy Financial. Please see the Fees and
Compensation section.
Advocacy Financial shall have no liability to the Client for any loss or other harm to any assets or property in the Account resulting
from the insolvency of the custodian or any unauthorized or independent acts of the agents or employees of the custodian
regardless of whether the full amount of such loss is covered by Securities Investor Protection Corporation (“SIPC”) or any other
insurance which may be carried by the custodian. The client understands that SIPC provides only limited protection for the loss of
property held by a custodian broker-dealer. A custodial account agreement must also be executed for investment advisory
agreements to take effect.
When we conduct asset management services for held-away accounts, we may have access to clients’ user ID and password. Such
access may allow physical control over client assets. As a result, Advocacy Financial is considered to have custody. Advocacy
maintains safeguards to protect this information. Advocacy Financial will undergo a surprise audit annually by an unaffiliated
accounting firm that is in turn subject to review by the Public Company Accounting Oversight Board (PCOAB).
ITEM 16 – INVESTMENT DISCRETION
Advocacy Financial may be given discretionary authority by clients to execute transactions without client’s prior approval, on
behalf of those clients. This includes the buying or selling of securities, rebalancing and selection of portfolios, or the disbursement
of funds directly to the client as requested or arranged. Discretionary authority is granted on an Investment Advisory Agreement
and the agreement is signed by the client. In cases where Advocacy Financial is not given discretion, we must receive permission
from the client to make any trades on a non-discretionary basis.
Clients may make requests or suggestions in writing regarding the investments made in their portfolio. Restrictions on trading
which, in our opinion, are not in client’s best interest cannot be honored, and if forced by the client, may result in the termination
of an investment advisory agreement.
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ITEM 17 – VOTING CLIENT SECURITIES
The clients of Advocacy Financial retain the authority to proxy vote. Clients should ensure that proxy ballots are sent to them by
selecting this option on custodial application forms. Clients are welcome to delegate proxy voting authority to a third-party
representative (non-advisory personnel) by filing the appropriate custodial form. Advocacy Financial will not accept authority to
vote client proxies. This is set forth in Advocacy Financial's advisory agreement. Should Advocacy Financial inadvertently receive
proxy information for a security held in clients' accounts, we are to forward such information on to clients, but will not take further
action with respect to the voting of such proxy. Clients may contact Advocacy Financial for advice or information about a particular
proxy vote, however, Advocacy Financial shall not be deemed to have proxy voting authority solely as a result of providing such
advice to clients.
ITEM 18 – FINANCIAL INFORMATION
Advocacy Financial does not solicit prepayment of more than $1200 in fees per client six (6) months or more in advance. Advocacy
Financial has no financial issues that could impair its ability to carry out our fiduciary duty to our clients. Advocacy Financial has
never been the subject of a bankruptcy petition.
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