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Item 1
Cover Page
DELTA ADVISORY GROUP, INC.
FIRM BROCHURE
Part 2A of Form ADV
696 North Maitland Avenue
Maitland, Florida 32751
407-331-9213
www.DeltaAdvisory.com
March 2025
of
this
brochure,
please
contact
us
at
407-331-9213
This brochure provides information about the qualifications and business practices of
Delta Advisory Group, Inc. (“DAG” or the “Firm”). If you have any questions about the
or
contents
MJohnson@DeltaAdvisory.com. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission (“SEC”) or by any
state securities authority.
Registration with the SEC or with any state securities authority does not imply a certain
level of skill or training.
Additional information about Delta Advisory Group, Inc. is also available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by a unique identifying
number, known as a CRD number. The firm’s CRD number is 105966.
Item 2
Material Changes
This brochure, dated March 2025, provides you with a summary of DAG’s advisory
services and fees, professionals, certain business practices and policies, as well as actual
or potential conflicts of interest, among other things. Any material changes made since
the last Brochure update in March 2024 will be listed below.
Material Changes
Should a material change in our operations occur, depending on the nature of the change,
DAG will promptly communicate this change to Clients (and it will be summarized in this
Item). “Material changes” requiring prompt notification will include changes in ownership
or control; location; disciplinary proceedings; significant changes to our advisory services
or advisory affiliates; or any information that is critical to a Client’s full understanding of
who the Firm is; how to find us, and how we do business.
• There are no material changes.
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Item 3
Table of Contents
Item 1
Cover Page .................................................................................................... 1
Item 2 Material Changes ........................................................................................... 2
Item 3
Table of Contents .......................................................................................... 3
Item 4
Advisory Business .......................................................................................... 4
Item 5
Fees and Compensation ................................................................................ 8
Item 6
Performance-Based Fees and Side-By-Side Management ......................... 11
Item 7
Types of Clients ........................................................................................... 12
Item 8 Methods of Analysis, Investment Strategies, & Risk of Loss ....................... 13
Item 9
Disciplinary Information ................................................................................ 16
Item 10 Other Financial Industry Activities & Affiliations ........................................... 17
Item 11 Code of Ethics, Participation or Interest in Client Transactions, & Personal
Trading ........................................................................................................ 17
Item 12
Brokerage Practices..................................................................................... 19
Item 13 Review of Accounts ..................................................................................... 21
Item 14 Client Referrals and Other Compensation ................................................... 22
Item 15 Custody ........................................................................................................ 23
Item 16
Investment Discretion .................................................................................. 24
Item 17 Voting Client Securities ................................................................................ 25
Item 18
Financial Information ................................................................................... 26
Item 19 Requirements for State-Registered Advisers Error! Bookmark not defined.
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Item 4
Advisory Business
About Delta Advisory Group, Inc. (“DAG”)
DAG is a Florida corporation founded in 1996. DAG is an investment adviser registered
with the Securities & Exchange Commission (“SEC”) with its home office located at 696
North Maitland Avenue, Maitland, Florida, 32751. DAG maintains a branch office at 698
North Maitland Avenue Suite 201, Maitland, Florida 32751.
Please note that the words “we,” “us,” and “our” may be used to refer to DAG throughout
this brochure, as the context may require. Furthermore, the words “you,” “your,” and
“Client” may be used to refer to you as either a client or a prospective client of DAG, as
the context may require.
DAG’s principal shareholder (i.e., those individuals and/or entities controlling 25% or more
of this company) is:
• Clarence – Pelton, LTD
Advisory Services Offered
Prior to forming an investment advisor-client relationship, DAG may offer a complimentary
general consultation to prospective Clients to discuss the nature of its service offerings
and to determine the possibility of a potential advisory relationship. Investment advisory
services begin only after the prospective Client and DAG formalize their relationship with
a properly executed written advisory agreement.
Portfolio Management
DAG provides continuous advice to a Client regarding the investment of Client funds and
non-continuous asset management of Client funds based on individual needs of the
Client. Through personal discussions and the data gathering process, the Client’s goals
and objectives based on a his/her particular circumstances are established to determine
the appropriate manner in which to manage the Client’s portfolio. During our data
gathering process, we determine the Client’s individual objectives, time horizons, risk
tolerance, and liquidity needs. As appropriate, we also review and discuss a client’s prior
investment history, as well as family composition and background.
DAG manages these advisory accounts on a discretionary basis. Account supervision is
guided by the client’s stated objectives and tax considerations. Clients may impose
reasonable restrictions on investing in certain securities, types of securities, or industry
sectors.
DAG’s investment recommendations are not limited to any specific product or service
offered by a broker/dealer or insurance company. Because some types of investments
involve certain additional degrees of risk, they will only be implemented or recommended
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when consistent with the Client’s stated investment objectives, tolerance for risk, liquidity,
and suitability.
Selection of Broker by DAG
As a condition of participation in most services with DAG, Clients are generally required
to maintain their brokerage account(s) at Charles Schwab & Co. Inc. (“Schwab”).
Financial Planning Services
DAG provides financial planning services. Financial planning is a comprehensive
evaluation of a Client’s current and future financial state by using currently known
variables to predict the future cash flows, asset values, and withdrawal plans. Through
the financial planning process, all questions, information, and analysis are considered as
they impact and are impacted by the entire financial and life situation of the Client. Clients
purchasing this service receive a written report which provides the Client with a detailed
financial plan designed to assist the Client in achieving his/her financial objectives.
Generally, the financial plan addresses any or all of the following areas: personal
situations, tax and cash flow, investments, insurance, retirement, death and disability, and
estate. DAG gathers required information through written information and documentation
provided by the Client, as well as in-depth personal interviews. The information gathered
includes the Client’s current financial status, tax status, future goals, return objectives,
and attitudes towards risk. Should the Client choose to implement the recommendations
contained in the plan, we will suggest the Client work closely with his/her attorney,
accountant, insurance agent, and/or stockbroker. Implementation of the financial plan
recommendations is entirely at the Client’s discretion.
DAG also provides general non-securities advice on topics that may include tax and
budgetary planning, estate planning, and business planning.
Typically, the financial plan is presented to the Client within six months of the contract
date, provided that all information needed to prepare the financial plan has been promptly
provided.
Financial planning recommendations are not limited to any specific product or service
offered by a broker/dealer or insurance company.
Consulting
There are situations in which a DAG investment advisor provides advice on specific topics
not involving a comprehensive financial plan. Often, these situations are associated with
events such as divorce, death, retirement, or a child entering college.
Newsletters
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DAG provides Clients with newsletters sent monthly that include updates and investment-
related advice.
Client Tailored Services and Client Imposed Restrictions
DAG will tailor services for each individual Client based on industry standards and
information gathered from Client suitability forms such as the Risk Tolerance
Questionnaire and the Client Profile. Clients may impose restrictions in receiving
recommendations for investing in certain securities or types of securities in accordance
with their values or beliefs. However, if the restrictions prevent DAG from making proper
recommendations for the Client account, DAG reserves the right to end the relationship.
IRA Rollover Considerations & Recommendations
As part of our investment advisory services to you, we may recommend that you withdraw
the assets from your employer's retirement plan and roll the assets over to an individual
retirement account (IRA) that we will manage on your behalf. If you elect to roll the assets
to an IRA that is subject to our management, we will charge you an asset-based fee as
set forth in the agreement you executed with our firm. This practice presents a conflict of
interest because persons providing investment advice on our behalf have an incentive to
recommend a rollover to you for the purpose of generating fee-based compensation
rather than solely based on your needs. You are under no obligation, contractually or
otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are
under no obligation to have the assets in an IRA managed by our firm.
We comply with the Department of Labor (“DOL”) Prohibited Transaction Exemption
2020-02 (“PTE 2020-02”) where applicable. Our firm is providing the following additional
acknowledgment:
When the Adviser provides investment advice to individuals regarding a retirement plan
account or individual retirement account, the firm is deemed a fiduciary 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
the Adviser makes money creates potential conflicts with a client’s interest. Therefore,
the Adviser, operates under a special rule which requires the firm to act in a client’s best
interest and not put the Adviser’s interest ahead of the client. Under this special rule’s
provisions, the Adviser must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put the Adviser’s financial interests ahead of a client when making
recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees and investments;
• Follow policies and procedures designed to ensure advice given is in the client’s
best interest;
• Charge no more than is reasonable for services; and • Provide basic information
about conflicts of interest.
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Client Assets Under Management
As of December 31, 2024, DAG provides continuous management services for
$192,575,000.00 in client assets for 466 clients on a discretionary basis. DAG does not
currently provide any non-discretionary portfolio management.
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Item 5
Fees and Compensation
Portfolio Management Fees
DAG’s annual fees for Portfolio Management are based upon a percentage of assets
under management up to 2.95%.
The fees are billed quarterly or semiannually, in advance, at the beginning of each
calendar period based upon the value (market value or fair market value in the absence
of market value), of the client’s account(s) at the end of the previous period. For some
Clients, the value of fees to be paid six months or more, in advance, may exceed $500.
For most Clients, fees will be debited from the account in accordance with the client
authorization in the Client Services Agreement; however, under certain circumstances
and at DAG’s discretion, the Client has the option of being billed for advisory fees.
Though the fees charged by DAG are generally considered to be reasonable, Clients
could find the same or similar services offered by other investment advisors who charge
fees that are lower than the fees charged by DAG.
Limited Negotiability of Advisory Fees
DAG retains the discretion to negotiate alternative fees on a client-by-client basis. Client’s
facts, circumstances, and needs are considered in determining the fee schedule,
including but not limited to, the complexity of the client’s situation, assets to be placed
under management, anticipated future business, related accounts, portfolio style, account
composition, among other factors. The specific annual fee schedule is identified in the
investment advisory agreement between DAG and the Client.
DAG may group certain related Client accounts for the purposes of achieving the
minimum account size requirements and determining annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family
members and friends of associated persons.
Financial Planning and Consulting Fees
DAG’s financial planning fee is determined based on the nature of the services being
provided and the complexity of each client’s circumstances. All fees are agreed upon prior
to entering into a contract with any client.
Financial planning fees are calculated and charged on an hourly basis, ranging from $195
to $295 per hour. Although the length of time it takes to provide a financial plan depends
on each client’s personal situation, DAG will provide an estimate for the total hours at the
start of the advisory relationship.
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The fee for this service is separated into two payments: 50% of the estimated planning
hours are due upon entering into the agreement for financial planning services and the
balance, based on actual hours of service accrued, is due upon delivery of the completed
financial plan.
Newsletters
Newsletters are sent to all Clients, free of charge, on a monthly basis.
General Information
Mutual Fund Fees
All fees paid to DAG for investment advisory services are separate and distinct from the
fees and expenses charged by mutual funds and/or exchange traded funds. These fees
and expenses are described in each fund’s prospectus. These fees will generally include
a management fee, other fund expenses, and a possible distribution fee. If the fund also
imposes sales charges, a client may pay an initial or deferred sales charge. Accordingly,
the Client should review both the fees charged by the funds and our fees to fully
understand the total amount of fees to be paid by the Client and to thereby evaluate the
advisory services
Termination of the Advisory Relationship
A client agreement can be cancelled at any time with written notice of cancellation and
will become effective ninety days following receipt of written notice by DAG. Client is
entitled to a refund of any unearned portion of the management fee. For Clients who are
residents of California, Maryland, Massachusetts, and Pennsylvania, the termination
notifications will become effective thirty days following receipt by DAG.
Clients will receive a copy of Form ADV Part 2A prior to entering into an advisory
agreement. For Clients who are residents of Pennsylvania, if a copy of Form ADV Part
2A is not provided to the Client at least 48 hours prior to signing an agreement, the Client
has five (5) business days to cancel the agreement, with no penalty.
Where Client is entitled to a refund of unearned management fees, such fees will be
prorated based upon the number of days that DAG’s advisory services were actually
rendered during the termination quarter. Any unearned fees will be returned to the Client.
Additional Fees and Expenses
In addition to our advisory fees, clients are also responsible for other fees and expenses
charged by custodians and imposed by broker/dealers, including but not limited to, any
transaction imposed by a broker/dealer with which an independent investment manager
effects transactions for the client’s account(s). Please refer to Item 10 of this brochure,
“Brokerage Practices”, for additional information.
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ERISA Accounts
Pursuant to the Employee Retirement Income and Securities Act (“ERISA”), and
regulations under the Internal Revenue Code of 1986, the Firm is deemed to be a fiduciary
to advisory clients that are employee benefit plans or individual retirement accounts. As
such, we are subject to specific duties and obligations under ERISA and the Internal
Revenue Code that include among other things, restrictions concerning certain forms of
compensation. To avoid engaging in prohibited transactions, we may only charge fees for
investment advice about products for which the Firm and/or related persons do not receive
any commissions or 12b-1 fees, except that the Firm and/or related persons may provide
investment advice about products for which we receive commissions or 12b-1 fees, only
if such fees are used to offset our advisory fees.
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March 2025
Item 6
Performance-Based Fees and Side-By-Side Management
DAG does not charge performance-based fees.
DAG’s personnel may manage accounts which belong either to themselves, individually,
or to their family (collectively, Proprietary Accounts) or the accounts of affiliated entities
(Affiliated Accounts) while simultaneously continuing to manage DAG's accounts. It is
possible that orders for Proprietary Accounts and Affiliated Accounts may be entered
opposite to orders for Clients' Accounts, pursuant to, for instance, a different trading
strategy, or trading at a different risk level. The management of any Proprietary Account
or Affiliated Account is subject to the duty of DAG and its personnel to exercise good faith
and fairness in all matters affecting its Clients' account.
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Item 7
Types of Clients
DAG provides advisory services to a variety of Clients including, but not limited to:
Individuals (other than high net worth individuals)
•
• High net worth individuals
Minimum Account Size
DAG does not have a minimum account size.
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Item 8
Methods of Analysis, Investment Strategies, & Risk of Loss
Methods of Analysis
The firm uses the following methods of analysis in formulating our investment advice
and/or managing client assets:
Charting
In this type of technical analysis, DAG reviews charts of market and security activity in an
attempt to identify when the market is moving up or down and to predict how long the
trend may last and when that trend might reverse.
Fundamental Analysis
DAG attempts to measure intrinsic value of a security by looking at economic and financial
factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating
it may be a good time to buy) or overpriced (indicating it may be a time to sell).
Fundamental analysis does not attempt to anticipate market movements, which presents
a potential risk, as the price of a security can move up or down along with the overall
market regardless of the economic and financial factors considered in evaluating the
stock.
Technical Analysis
DAG analyzes past market movements and applies that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future
price movement. Technical analysis does not consider the underlying financial condition
of a company and, therefore, presents a risk in that a poorly managed or financially
unsound company may underperform regardless of market movement.
Cyclical Analysis
In this type of technical analysis, DAG measures the movements of a particular stock
against the overall market in an attempt to predict the price movement of the security.
Risks for all forms of analysis
DAG securities analysis methods rely on the assumption that the companies whose
securities DAG purchases and sells, the rating agencies that review these securities, and
other publicly available sources of information about these securities are providing
accurate and unbiased data. While DAG is alert to indications that data may be incorrect,
there is always a risk that our analysis may be compromised by inaccurate or misleading
information.
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Investment Strategies
DAG uses the following strategies in managing Client accounts, provided that such
strategies are appropriate to the needs of the Client and consistent with the Client’s
investment objectives, risk tolerance, and time horizons, among other considerations:
Long-Term Purchases
DAG purchases securities with the idea of holding them in the Client’s account for a year
or longer. Typically, we employ this strategy when we believe the securities to be currently
undervalued and/or want exposure to a particular asset class over time, regardless of the
current projection for this class.
A risk in a long-term purchase is that by holding the security for this length of time, we
may not take advantage of short-term gains that could be profitable to the Client.
Moreover, if we are incorrect, a security may decline sharply in value before we make the
decision to sell.
Short-Term Purchases
When utilizing this strategy, DAG purchases securities with the idea of selling them within
a relatively short time (less than a year). Typically, we employ this strategy in an attempt
to take advantage of conditions that we believe will soon result in a price swing in the
securities we purchase.
A short-term purchase strategy poses the risk that, should the anticipated price swing not
materialize, we are then left with the option of having a long-term investment in a security
that was designed to be a short-term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy
and will result in increased brokerage and other transaction-related costs, as well as less
favorable tax treatment of short-term capital gains.
Trading
DAG purchases securities with the idea of selling them very quickly (30 days or less), in
an attempt to take advantage of brief price swings.
Utilizing a trading strategy creates the potential for sudden losses if the anticipated price
swing does not materialize. Moreover, under those circumstances, we are then left with
the option of having a long-term investment in a security that was designed to be a short-
term purchase, or potentially taking a loss.
In addition, because this strategy involves more frequent trading than does a longer-term
strategy, there will be a resultant increase in brokerage and other transaction-related
costs, as well as less favorable tax treatment of short-term capital gains.
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Margin Transactions
DAG will purchase stocks for a Client’s portfolio with money borrowed from the Client’s
brokerage account. Purchasing on margin allows a Client to purchase more stock than
he/she would be able to with his/her available cash and allows us to purchase stock
without selling other holdings.
Option Writing
DAG may use options as an investment strategy. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at
a specific price on or before a certain date. An option, just like a stock or bond, is a
security. An option is also a derivative, because it derives its value from an underlying
asset.
The two types of options are calls and puts:
• A call gives us the right to buy an asset at a certain price within a specific period
of time. We will buy a call if we believe that the stock will increase substantially
before the option expires.
• A put gives the holder the right to sell an asset at a certain price within a specific
period of time. We will buy a put if we believe that the price of the stock will fall
before the option expires.
DAG will use options to hedge on the possibility of a sharp price swing or hedge a
purchase of the underlying security. In other words, we will use an option purchase to
limit the potential upside and downside of a security we have purchased for the Client’s
portfolio.
DAG uses “covered calls”, in which we sell an option on a security the Client owns. In this
strategy, the Client receives a fee for making the option available, and the person
purchasing the option has the right to buy the security from the Client at an agreed upon
price.
We use a “spreading strategy”, in which two or more option contracts for the same
underlying security. This strategy effectively puts the Client on both sides of the market,
but with the ability to vary price, time, and other factors.
Risks of Loss
The assets in the portfolios are financial securities. Any investment of this type involves a
risk of loss, not only of income but of investment dollars which the investor client must be
prepared to bear. An extended period of market uncertainty or economic recession could
result in significant loss of value.
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Item 9
Disciplinary Information
DAG is required to disclose any legal or disciplinary events that are material to a client’s
or prospective client’s evaluation of our advisory business or the integrity of our
management.
There are no reportable disciplinary events for DAG or its management personnel.
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Item 10 Other Financial Industry Activities & Affiliations
Broker-Dealer or other Investment Advisors
As of the date of this brochure, neither DAG nor its management are or intend to become
registered as a broker-dealer and no individuals affiliated with our firm are currently
registered representatives of a broker-dealer.
Futures or Commodities Registration
Neither DAG nor its management are or intend to become registered as a futures
commission merchant, commodity pool operator, commodity trading advisor, or an
associated person of any of the foregoing.
Material Relationships with Related Persons
Mr. Donald Nestor is licensed to sell insurance products and may receive separate, yet
customary commission compensation for effecting insurance sales. This may represent
a potential conflict of interest because he may have an incentive to recommend insurance
products to you for the purpose of generating commissions rather than solely based on
your needs. However, you are under no obligation, contractually or otherwise, to purchase
products through any person affiliated with our firm.
Mr. Anthony DeLuca is licensed to sell insurance products and may receive separate, yet
customary commission compensation for effecting insurance sales. This may represent
a potential conflict of interest because he may have an incentive to recommend insurance
products to you for the purpose of generating commissions rather than solely based on
your needs. However, you are under no obligation, contractually or otherwise, to purchase
products through any person affiliated with our firm.
Mr. Roy Miranda is the managing member of Delta Insurance Group, LLC (“DIG”) through
which he licensed to sell insurance products and may receive separate, yet customary
commission compensation for effecting insurance sales. This may represent a potential
conflict of interest because he may have an incentive to recommend insurance products
to you for the purpose of generating commissions rather than solely based on your needs.
However, you are under no obligation, contractually or otherwise, to purchase products
through any person affiliated with our firm.
Since no investment advisers are licensed to sell insurance products in the state of
Pennsylvania, insurance products will not be offered by DAG to Clients who reside in
Pennsylvania.
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Interest
in Client
Item 11 Code of Ethics, Participation or
Transactions, & Personal Trading
Code of Ethics
DAG has adopted a Code of Ethics (“Code”) which sets forth high ethical standards of
business conduct that DAG requires of its employees, including compliance and
applicable federal securities laws.
The Code is designed to ensure that the personal securities transactions, activities, and
interests of our employees will not interfere with: (i) making decisions in the best interest
of advisory clients; and (ii) implementing such decisions while, at the same time, allowing
employees to invest for their own accounts.
A copy of the Code is available to our advisory clients and prospective clients. You may
request a copy by email to MJohnson@DeltaAdvisory.com, or by calling us at 407-331-
9213.
Participation or Interest in Client Transactions & Personal Trading
From time to time, DAG and/or individuals associated with DAG may buy or sell for their
personal accounts securities identical to or different from those recommended to the
Clients. In addition, any related person may have an interest or position in a certain
security which may also be recommended to a Client.
It is our expressed policy that no person employed by DAG may purchase or sell any
security prior to transactions being implemented for an advisory account, thereby
preventing such employee(s) from benefiting from transactions placed on behalf of
advisory accounts.
DAG may aggregate employee trades with client transactions where possible and when
compliant with our duty to seek best execution for our clients. In these instances,
participating clients will receive an average share price and transaction costs will be
shared equally and on a pro rata basis. In the instances where there is a partial fill of a
particular batched order, DAG will allocate all purchases pro rata, with each account
paying the average price. Our employee accounts will be included in the pro rata
allocation.
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Item 12 Brokerage Practices
For discretionary clients, DAG requires clients to provide us with written authority to: (1)
determine the broker/dealer to use; (2) the commission costs that will be charged to these
clients for those transactions; and (3) provide limitations on discretionary authority. Clients
may amend these limitations as required. Such amendments must be provided to us in
writing.
DAG has an arrangement with Charles Schwab & Co. Inc. (“Schwab”) through which
Schwab provides us with “institutional platform services”. The institutional platform
services include, among others, brokerage, custody, and other related services. Schwab’s
institutional platform services that assist us in managing and administering clients’
accounts include software and other technology that: (i) provide access to client account
data (such as trade confirmations and account statements); (ii) facilitate trade execution
and allocate aggregated trade orders for multiple client accounts; (iii) provide research,
pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and
(v) assist with back-office functions, recordkeeping and client reporting.
We will arrange for the execution of securities brokerage transactions for the account
through Schwab. In seeking best execution, the determinative factor is not lowest possible
commission cost but whether the transaction represents the best qualitative execution,
taking into consideration the full range of a broker-dealers’ service, including the value of
research provided, execution capability, commission rates and responsiveness.
Accordingly, although we will seek competitive commission rates, we may not necessarily
obtain the lowest possible commission rate for account transactions.
Clients are encouraged, but not required, to establish an account with Schwab. The client
may direct DAG to use a particular broker-dealer (subject to our right to decline and/or
terminate the engagement) to execute some or all transactions for the client’s account. In
such event, the Client will negotiate terms and arrangements for the account with that
broker-dealer and DAG will not seek better execution services or prices from other broker-
dealers. As a result, Client may pay higher commissions or other transaction costs or
greater spreads or receive less favorable net prices on transactions for the accounts than
would otherwise be that case. In the event that transactions for client accounts are
executed through a broker-dealer that refers clients to DAG, the potential for conflict of
interest may arise.
Order Aggregation
We may, but are not obligated to, combine multiple orders for shares of the same
securities purchased for advisory accounts we manage (this practice is commonly
referred to as "block trading"). In the event orders are block traded, we will then
distribute a portion of the shares to participating accounts in a fair and equitable
manner. The distribution of the shares purchased is typically proportionate to the size of
the account, but it is not based on account performance or the amount or structure of
management fees. Subject to our discretion regarding factual and market conditions,
when we combine orders, each participating account pays an average price per share
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for all transactions and pays a proportionate share of all transaction costs on any given
day.
Accounts owned by our firm or persons associated with our firm may participate in block
trading with your accounts; however, they will not be given preferential treatment. In the
event orders are not block traded, you may pay different prices for the same securities
transactions than other clients pay. Furthermore, we may not be able to buy and sell the
same quantities of securities for you and you may pay higher commissions, fees, and/or
transaction costs than if orders were aggregated.
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Item 13 Review of Accounts
Portfolio Management
While the underlying securities within accounts for which DAG provides Portfolio
Management services are continually monitored, Client accounts are reviewed quarterly.
Accounts are reviewed in the context of each Client’s stated investment objectives and
guidelines. More frequent reviews may be triggered by material changes in variables such
as the Client’s individual circumstances, or the market, political, or economic
environment.
Mr. Alexander Petsos is responsible for the quarterly review of Client accounts.
Financial Planning
While reviews may occur at different stages depending on the nature and terms of the
specific engagement, typically no formal reviews will be conducted for financial planning
clients unless the Client contracts for additional services.
Financial planning Clients will receive a completed financial plan. Additional reports will
not typically be provided unless the client contracts for additional services.
Reports
You will receive account statements from Schwab or other qualified custodian at least
quarterly. Account performance reports are used in account reviews with Clients. In some
instances, copies of those performance reports may be provided to the Client.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025
Item 14 Client Referrals and Other Compensation
It is our policy not to engage solicitors or to pay related or non-related persons for referring
potential clients to DAG.
Other Compensation
DAG and/or its associated persons are eligible to receive incentive awards (including
prizes such as trips or bonuses) for recommending certain types of investment product.
While we endeavor at all times to put the interest of our clients first as part of our fiduciary
duty, the possibility of receiving incentive awards creates a conflict of interest and may
influence the judgement of these individuals when making recommendations.
As listed in Item 10, the firm principals and some access persons receive additional
compensation from their outside business activities. Some of these outside business
activities can create a conflict of interest because these persons could be incentivized by
compensation to make certain recommendations.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025
Item 15 Custody
DAG is considered to take custody of Client assets in two ways. DAG has limited custody
of Client assets due to the debiting of advisory fees from the Client’s account. DAG is
also considered to take custody of Client assets for which there is a standing letter of
authorization (“SLOA”) signed by the Client and submitted to the qualified custodian.
Debiting of Fees
As previously disclosed in Item 5 of this Brochure, “Fees and Compensation”, we directly
debit advisory fees from most client accounts which imputes limited custody of those
assets. As part of this billing process, the Client’s qualified custodian is advised of the
amount of the fee to be deducted from the Client’s account. You will receive account
statements from Schwab, or other qualified custodian, at least quarterly. These account
statements will indicate the amount of our advisory fees deducted from your account(s)
each billing period.
Because the custodian does not calculate the amount of the fee to be deducted, it is
important for clients to carefully review their custodial statements to verify the accuracy
of the calculation, among other things. Clients should contact us directly if they believe
that there may be an error in their statement.
Standing Letters of Authorization
Some Clients also have SLOAs that allow DAG’s advisors to disburse funds or move
funds between specified accounts on the Client’s behalf. This ability causes DAG to
exercise custody over the funds or securities for which there is a SLOA as noted in Form
ADV Part 1, Item 9A.
You will receive account statements from Schwab or other qualified custodian at least
quarterly. These account statements will indicate any transactions made during that
period. You should carefully review account statements sent to you reflecting the amount
of advisory fee deducted from your account.
If you have a question regarding your account statement, or if you did not receive a
statement from your custodian, please contact us directly at the telephone number on the
cover page of this brochure.
DAG complies with the safekeeping provisions required of firms that maintain custody as
described above.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025
Item 16
Investment Discretion
Clients may hire DAG to provide discretionary asset management services, in which case
we are not required to obtain the client’s permission prior to placing trades in a client’s
account. This discretionary authority includes the ability to determine the security to buy
or sell and/or the amount of the security to buy or sell without first contacting the client.
Clients give DAG discretionary authority when they sign a discretionary agreement with
us and may limit this authority by giving us written instructions. Clients may also amend
such authority by providing us with written instructions.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025
Item 17 Voting Client Securities
As a matter of policy, we do not vote proxies on behalf of Clients. Therefore, although we
may provide investment advisory services as to client investment of assets, clients
maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by
issuers of securities beneficially owned by the client shall be voted; and (2) making all
elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or
other type of events pertaining to client’s investment assets. Clients are responsible for
instructing each custodian of the assets to forward copies of all proxies and shareholder
communications relating to the client’s investment assets to the Client.
DAG may provide a client with consulting assistance regarding proxy issues if the client
contacts us with questions at our principal place of business.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025
Item 18
Financial Information
Prepayment of Fees – Financial Statements
There are some Clients for which DAG requires prepayment of more than $500 in fees
more than six months in advance. As such, financials have been prepared and submitted
by an independent public accountant.
Financial Conditions
DAG also maintains discretionary authority of Client assets. There are no financial
conditions that are reasonably likely to impair our ability to meet any contractual
commitments to our Clients.
Bankruptcy
DAG has not been the subject of a bankruptcy petition at any time during the past ten
years.
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Delta Advisory Group, Inc.
Form ADV Part 2A
March 2025