Overview
- Headquarters
- Atlanta, GA
- Total Firm Assets
- $4.8 billion
- Average High-Net-Worth Client Portfolio Size
- $1.0 million
Clients
- High-Net-Worth Share of Firm Assets
- 74.06%
- Number of High-Net-Worth Clients
- 3,556
- Total Client Accounts
- 14,619
- Discretionary Accounts
- 13,721
- Non-Discretionary Accounts
- 898
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection, Educational Seminars
Regulatory Filings
- SEC CRD Number
- 168012
Primary Brochure: IFGA - ADV PART 2A - FIRM BROCHURE (2026-03-18)
View Document Text
Form ADV Part 2A
Firm Brochure
IFG Advisory, LLC
CRD #168012
200 Ashford Center North, Suite 400
Atlanta, GA 30338
(770) 353-6331
www.integrated-financial-group.com
March 18, 2026
Item 1: Cover Page
This Brochure provides information about the qualifications and business practices of IFG
Advisory, LLC (hereinafter referred to as the “IFGA,” “us,” “we,” or “firm”). If you have any
questions about the contents of this Brochure, please contact our Chief Compliance Officer,
Crystal Epstein, at (770) 353-6331 or via email at cepstein@intfingroup.com. The information
in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission or by any state securities authority. Additional information about IFG
Advisory, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.
Please note that the use of the term “registered investment adviser” and the description of
IFG Advisory, LLC and/or our associates as “registered” does not imply a certain level of skill or
training. You are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise you for more information on the qualifications of our firm and its
associates.
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Item 2: Material Changes
Since the last annual update of this brochure on March 25, 2025, no material changes have
occurred.
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Item 3: Table of Contents
Item 1: Cover Page .................................................................................................................................. 1
Item 2: Material Changes ....................................................................................................................... 3
Item 3: Table of Contents ...................................................................................................................... 4
Item 4: Advisory Business ..................................................................................................................... 5
Item 5: Fees & Compensation................................................................................................................. 10
Item 6: Performance-Based Fees & Side-By-Side Management ..................................................... 14
Item 7: Types of Clients & Account Requirements ............................................................................. 14
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ............................................... 15
Item 9: Disciplinary Information ............................................................................................................ 21
Item 10: Other Financial Industry Activities & Affiliations ................................................................. 21
Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading ..... 23
Item 12: Brokerage Practices ............................................................................................................... 24
Item 13: Review of Accounts or Financial Plans ................................................................................ 28
Item 14: Client Referrals & Other Compensation .............................................................................. 29
Item 15: Custody ..................................................................................................................................... 30
Item 16: Investment Discretion .......................................................................................................... 30
Item 17: Voting Client Securities ........................................................................................................... 31
Item 18: Financial Information ................................................................................................................ 31
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Item 4: Advisory Business
IFG Advisory, LLC (“IFGA” or “Firm”) is dedicated to providing individuals and other types of
clients with a wide array of investment advisory services including portfolio management,
financial planning, and retirement plan advice. Our firm has been in business as an
independent investment adviser since 2013. The firm is wholly owned by Integrated Financial
Group, LLC. In turn, Integrated Financial Group, LLC. is owned by Donald Warren Patrick and
John Land Bridgers, each a principal owner. Please see the Brochure Supplements(s) for
more information on Mr. Patrick, Mr. Bridgers and other individuals who formulate investment
advice and have direct contact with clients or have discretionary authority over client
accounts.
Comprehensive Portfolio Management:
IFGA and its investment adviser representatives ("IARs") offer a variety of discretionary and
non-discretionary investment advisory services on a wrap and non-wrap fee basis. This
Brochure describes the advisory programs and advisory services offered by the IFGA on a non-
wrap fee basis. For more information on IFGA’s Wrap Fee Program, please see IFGA’s Wrap
Fee Program Brochure.
Asset Management Services
IFGA offers Asset Management services to advisory clients. IFGA will offer clients ongoing
asset management services through determining individual investment goals, time horizons,
objectives, and risk tolerance. Investment strategies, investment selection, asset allocation,
portfolio monitoring and the overall investment program will be based on the above factors.
Discretionary
When the Client elects to use IFGA on a discretionary basis, the Client will sign a
limited trading authorization or equivalent allowing IFGA to determine the securities to
be bought or sold and the amount of the securities to be bought or sold. IFGA will have
the authority to execute transactions in the account without seeking Client approval on
each transaction.
Non-Discretionary
When the Client elects to use IFGA on a non-discretionary basis, IFGA will determine
the securities to be bought or sold and the amount of the securities to be bought or
sold. However, IFGA will obtain prior Client approval on each and every transaction
before executing any transaction.
Sub-Advisors:
IFGA may also select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services
to Client’s Account. Such Sub-Advisor Services will be as determined by IFGA. Such Sub-
Advisor(s), in providing Sub-Advisor Services, shall have all of the same authority relating to
the management, including fee deduction authority, of Client’s Account as is granted to IFGA.
In addition, at IFGA’s discretion, IFGA may grant such Sub-Advisor(s) full authority to further
delegate such discretionary investment authority to other Money Managers. Client will agree
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to such authority within IFGA’s Advisory Agreement. All fees paid by Client to IFGA are
inclusive of the fees paid to Sub-Advisor.
Third-Party Managers/Co-Advisory Platforms:
IFGA may also act as a promoter and refer clients to Third-Party Manager/investment advisory
(“TPM”) firms for management services. The advisory representative will assist you in
determining your investment objective for the account and recommend an appropriate
portfolio or management style offered by the third-party advisor. The third-party advisor will
buy and sell securities in your account on a discretionary basis. IFGA does not participate in
the management of accounts managed by the third-party advisor. You should refer to the
disclosure brochure for the third-party advisor for further information about the services
offered by the third-party advisor, as well as whether or not the third-party advisor will permit
you to impose reasonable restrictions on the investments selected within the account.
IFGA may also act as a promoter and refer retirement plan participants and plan sponsors to
third party investment advisory firms for services including allocation recommendations and
retirement education, but specifically excluding account management or assistance with
trading. Such services will be provided to you primarily through a web portal provided by the
third-party advisor. The advisory representative will assist you in establishing the relationship
with the third-party advisor and be available to answer questions and facilitate the
relationship on an ongoing basis. You should refer to the disclosure brochure for the third-
party advisor for further information about the services offered by the third-party advisor.
You will be required to enter into an investment advisory agreement and other account
paperwork with the third-party advisor to establish a relationship, as well as sign a disclosure
that IFGA is acting in a promoter-only capacity.
Held Away Assets
IFGA utilizes third-party platforms to facilitate the management of held-away assets, in which
we will have discretionary and non-discretionary authority. These are primarily 401(k)
accounts, 529 Plans, HSA’s, and other assets which are held at third-party custodians. IFGA
regularly reviews, monitors, and trades in these accounts in the same way we do other
accounts. IFGA will seek to align the Client’s held-away account(s) with their overall
investment time horizon, risk tolerance, objectives, and goals.
Financial Planning & Consulting:
We provide a variety of standalone financial planning and consulting services to individuals,
families, and other clients regarding the management of their financial resources based upon
an analysis of the client’s current situation, goals, and objectives. Generally, such financial
planning services will involve preparing a financial plan or rendering a financial consultation
for clients based on the client’s financial goals and objectives. This planning or consulting can
encompass one or more of the following areas: Investment Planning, Retirement Planning,
Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax
Considerations, Cost Segregation Study, Real Estate Analysis, Mortgage/Debt Analysis,
Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning.
Business Valuation estimates are also offered as part of Financial Planning.
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Our written financial plans or consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For
example, recommendations may be made that the clients begin or revise investment
programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or
alter retirement savings, or establish education or charitable giving programs.
It should also be noted that we refer clients to accountants, attorneys, or other specialists, as
necessary for non-advisory related services. For written financial planning engagements, we
provide our clients with a summary of their financial situation, observations, and
recommendations. For financial consulting engagements, we usually do not provide our
clients with a written summary of our observations and recommendations as the process is
less formal than our planning service. Plans or consultations are typically completed within six
(6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
ERISA RETIREMENT PLAN SERVICES
IFGA offers Retirement Plan Consulting Services to qualified and non-qualified retirement plans
including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and
deferred compensation plans. IFGA may act as a 3(21) or 3(38) advisor:
Limited Scope ERISA 3(21) Fiduciary. IFGA acts as a limited scope ERISA 3(21) fiduciary that
can advise, help, and assist plan sponsors with their investment decisions. As an investment
advisor, IFGA has a fiduciary duty to act in the best interest of the Client. The plan sponsor is
still ultimately responsible for the decisions made in their plan, though using IFGA can help
the plan sponsor delegate liability by following a diligent process.
IFGA offers consulting services to retirement plan sponsors in some or all of the following
areas as agreed upon between the plan sponsor and IFGA in the written consulting services
agreement.
•
Investment Policy Statement – assist the plan sponsor in developing or revising the
plan’s investment policy statement based upon its objectives and constraints
• Service Provider Liaison – act as a liaison between the plan and its service providers,
product sponsors and vendors based solely on instructions from the plan on
investment or administrative matters. IFGA will not exercise judgment or discretion
with regard to these matters
•
Investment Monitoring – perform ongoing monitoring of investments and/or
investment managers based on written guidance provided by the plan
•
Investment Recommendations – recommend specific investments for plan sponsor to
consider within the plan or to make available to plan participants (if applicable), and/or
recommend replacement investments if an existing investment is deemed no longer
suitable by the plan sponsor. All decisions regarding investment options to be made
available to plan participants for purchase are the responsibility of the plan sponsor
•
Investment Education – provide education on general investment product types and
strategies
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• Performance Reports – provide performance reports generated through Orion Advisor
or an IFGA approved performance reporting vendor
• 404(c) Assistance – assist plan in identifying investment options under the “broad
range” requirement of ERISA 404(c)
• Qualified Default Investment Alternative (QDIA) Assistance – assist Client in identifying
an investment alternative within the definition of QDIA under ERISA
• Education Services to Plan Sponsor – provide training for members of the plan sponsor
or any plan committee with regard to their services, including education with respect
to their fiduciary responsibilities
• Participant Enrollment – assist and/or provide resources to assist the plan in enrolling
plan participants in the plan, including facilitating agreed upon enrollment meetings
and providing participants with information about the plan such as terms and operation
of the plan, benefits of plan participation, benefits of increasing plan contributions, and
impact of preretirement withdrawals on retirement income
• Participant Education – facilitate individual or group investment education meetings
for plan participants providing information about investment options under the plan
such as investment objectives and historical performance, explaining investment
concepts such as diversification and risk and return, and providing guidance as to how
to determine investment time horizon and risk tolerance. This will not include
individualized investment advice for a particular participant
• Changes in Investment Options – assist in making changes to investment options
under the plan upon the plan sponsor’s direction. IFGA will have no discretion over the
changes made or be involved in trade execution
• Vendor Analysis – assist plan with the preparation, distribution and evaluation of
Requests for Proposals, finalist interviews and conversion support
• Benchmarking Services – provide plan with comparisons of plan data such as fees,
services, participant enrollment and participant contributions levels to data from the
plan’s prior years and/or similar plans
• Fee Assessment – assist plan in identifying fees and other costs incurred by the plan for
recordkeeping, participant education, participant
investment management,
communication and/or other services provided
The plan sponsor is responsible for determining whether or not to implement any
recommendations provided by IFGA. IFGA does not take discretion with respect to plan assets
and IFGA does not provide individualized advice to participants in the plan.
In some situations, where agreed to in writing by IFGA, certain specified investment
management services may be provided to plan sponsors. These services include making
investment selections and developing custom model portfolios.
In certain situations, an advisor providing Retirement Plan Consulting Services may also offer
his/her advisory services to participants of the plan under the Participant Investment Advice
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Program and/or through Financial Planning Services. In this case, the advisor would be
compensated for their services as advisor to the plan and as advisor to the participants of the
plan.
3(38) Investment Manager. IFGA acts as an ERISA 3(38) Investment Manager in which it has
discretionary management and control of a given retirement plan’s assets. IFGA would then
become solely responsible and liable for the selection, monitoring and replacement of the
plan’s investment options.
1. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the
initial selection, retention, removal and addition of investment options in
accordance with the Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options
consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The
IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the
selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Plan Sponsor retains the sole responsibility to provide all notices to
the Plan participants required under ERISA Section 404(c)(5).
• Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the
investment recommendations.
2. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. The Advisor’s
assistance in education of the Plan participants shall be consistent with and within
the scope of the Department of Labor’s definition of investment education
(Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not
providing fiduciary advice as defined by ERISA to the Plan participants. Advisor will
not provide investment advice concerning the prudence of any investment option
or combination of investment options for a particular participant or beneficiary
under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding
by the employees.
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IFGA may provide these services or, alternatively, may arrange for the Plan’s other providers
to offer these services, as agreed upon between Advisor and Plan Sponsor.
3.
IFGA has no responsibility to provide services related to the following types of assets
(“Excluded Assets”):
a. Employer securities;
b. Real estate (except for real estate funds or publicly traded REITs);
c. Stock brokerage accounts or mutual fund windows;
d. Participant loans;
e. Non-publicly traded partnership interests;
f. Other non-publicly traded securities or property (other than collective trusts and
similar vehicles); or
g. Other hard-to-value or illiquid securities or property.
Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. These restrictions may,
however, prohibit engagement with IFGA.
Participation in Our Wrap Fee Program
We offer a wrap fee program in order to simplify the payment of management fees and
brokerage expenses. The wrap fee includes the brokerage expenses (i.e., commissions, ticket
charges, etc.) of the account as well as our management fee. For further details, please see
our Appendix 1, Wrap Fee Program Brochure. Our wrap fee and non-wrap fee accounts are
managed on an individualized basis according to the client’s investment objectives, financial
goals, risk tolerance, etc. We do not manage wrap fee accounts in a different fashion than
non-wrap fee accounts. As further described in our Appendix 1, Wrap Fee Program Brochure
we receive a portion of the wrap fee for our services.
Assets Under Management
As of December 31, 2025, we managed $4,485,583,999 on a discretionary basis and $273,603,484
on a non-discretionary basis totaling $4,759,187,483 assets under management.
Item 5: Fees & Compensation
Comprehensive Portfolio Management:
We are compensated for our Comprehensive Portfolio Management services according to the
following table:
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Portfolio Value Maximum Fee
Assets Under Management
$0 – $249,999.99
$250,000 – $499,999.99
$500,000 – $749,999.99
$750,000 – $1,249,999.99
$1,250,000 – $1,999,999.99
$2,000,000 – $4,999,999.99
$5,000,000+
Annual Percentage of Assets
2.00%
1.75%
1.65%
1.40%
1.25%
1.15%
1.00%
Our fees are based on a negotiated percentage of the market value of assets under
management, not to exceed the respective percentage for each asset level designated above of
total assets under management. We consider cash to be an asset class and include these
amounts in assets under management for billing and investment management purposes.
Your initial advisory fee will include a pro-rated amount for services rendered from the
account opening date with the qualified custodian. With the exception of accounts held with
SEI, Lincoln Financial Group and Pontera, advisory fees are billed on a pro-rata basis for cash
withdrawals/deposits or terminated accounts during the prior quarter.
With the exception of Lincoln Financial Group, Nationwide, and SEI accounts which bill in
arrears, all fees are billed in advance at the beginning of each quarter based on the value of
the account on the last day of the previous quarter. SEI bills monthly, not quarterly, based on
the value of the account on the last day of the month.
A small percentage of our accounts are held with American Funds or Nationwide. Both
American Funds and Nationwide calculate the annualized advisory fee based on average daily
balance and bill quarterly in arrears.
Fees will be deducted from your managed account; in certain circumstances we allow direct
billing as an option to our clients. As part of the fee deduction process, clients are made aware
of the following:
a) Your independent custodian sends statements to you on at least a quarterly (typically
monthly) basis showing your holdings, their market value, and all disbursements;
b) You provide authorization permitting us to be paid directly from the managed account
held by the independent custodian;
c) The custodians calculate the advisory fees for all fee schedules and deduct them from
your account.
The ultimate management fee is listed on Schedule A of the client agreement and is indicated
on the custodial account application form. Our firm does not have the authority to instruct
the account custodian to raise or deduct fees without written client consent.
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Separate Account Managers
We are compensated by Managers on Separately Managed Accounts (“SMAs”). The
compensation paid to us is typically the same as our stated investment advisory fee
percentage. Our Financial Advisors refer clients to third party investment advisors that offer
asset management services to clients. We are paid by third party money managers when we
refer you to them and you decide to open a managed account. Third party money managers
pay us a portion of the investment advisory fee that they charge you for managing your
account. Fees paid to us by third party money managers are generally ongoing. The Manager
will also have an agreed upon fixed fee that will be disclosed to the client and charged in
addition to our advisory fee. The fee paid to the Manager can be higher or lower than our fee
depending on the type of investment strategy utilized within the account. The terms and
conditions under which the client shall engage the Manager shall generally be set forth in a
tri-party agreement between the client, our firm, and the designated Manager.
All fees we receive from third-party money managers and the separate disclosures made to
you regarding these fees comply with applicable SEC rules. The third-party money managers
we recommend will not directly charge you a higher fee than they would have charged without
us introducing you to them. Third-party money managers establish and maintain their own
separate billing processes over which we have no control. In general, they will directly bill
you and describe how this works in their separate written disclosure documents. Please see
Item 10 – Other Financial Affiliations and Activities for more information.
Portfolio Management Services through LPL
LPL serves as program sponsor, investment adviser and broker-dealer for the LPL advisory
programs. We and LPL can share in the account fee associated with program accounts. LPL
advisory programs have a maximum account fee of 2.50% and are payable quarterly in
advance. For more information regarding the LPL programs, please see the LPL Form ADV
Part 2 or applicable client agreement.
Financial Planning & Consulting
We charge on an hourly, flat, or annual percentage of Assets Under Advice fee basis for
financial planning and consulting services. Assets Under Advice are investments and other
assets generally included in a financial plan review, and our firm will provide a schedule of
Assets Under Advice annually using year-end values when available. The total estimated fee,
as well as the ultimate fee we charge you, is based on the scope and complexity of our
engagement with you. Our hourly fees are generally up to $500 for financial advisors. Flat fees
generally range from $1,500 to $10,000. Our firm reserves the discretion to reduce or waive the
hourly fee and/or the minimum fixed fee for Financial Planning & Consulting services if a client
chooses to engage us for our Asset Management services. The Client is billed on actual fees
accrued if not deducted from a specified advisory account.
For Initial Financial Planning and Miscellaneous Services, we may require a retainer of fifty
percent (50%) of the estimated financial planning or consulting fee with the remainder of the
fee directly billed to you and due to us within thirty (30) days of your financial plan being
delivered or consultation rendered to you. For Ongoing Financial Planning Review, fees are
billed and due quarterly, unless otherwise agreed to. In all cases, we will not require a retainer
exceeding $1,200 when services cannot be rendered within 6 (six) months.
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ERISA Retirement Plan Services:
We charge an hourly or flat fee basis for consulting services rendered to Plan Sponsors. Our
hourly fees range from $175 to $350 for Retirement Account Advisory Services. Flat fees range
from $1,500 to $100,000 or can be charged as a percentage of assets within the plan not to
exceed 1.0%. While fees are negotiable, the total estimated fee as well as the ultimate fee that
we charge you, is based on the scope and complexity of our engagement with you. For example,
when assessing the fee to be charged, we will consider the size of the plan, number of
employees, travel costs (e.g., flights, hotels, etc.), and software subscriptions required to monitor
the plan. Fees will be charged annually, quarterly, or monthly for ongoing consulting services.
The fee-paying arrangements for the Retirement Plan Advisory service will be determined on
a case-by-case basis and will be detailed in the signed client agreement. The client fees will
be debited directly from the Plan’s account(s) and/or billed by invoice directly to the Plan.
In cases where the fee is charged as a percentage of assets within the plan, the ongoing fee
is due and payable annually, quarterly, or monthly in advance or in arrears based upon the
value of the Plan's Account(s) on the last day of the previous year, quarter, or month. Should
the Plan have more than one Account, the fee shall be payable in proportion to the respective
Account value(s). The Adviser's fees will be debited directly from the Plan's Account(s) and
Client authorizes the custodian for the Plan assets, which will be upon instruction from the
Plan's administrator, to deduct Adviser’s fees directly from the Plan's Account(s). Client
acknowledges that the custodian shall have no responsibility to determine whether the fee is
properly calculated. Adviser shall not be compensated on the basis of a share of capital gains
or capital appreciation of the Plan's Account(s).
Other Types of Fees & Expenses:
Our fees are separate and distinct from the internal fees and expenses charged by Managers,
mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders
(generally including a management fee and fund expenses, as described in each fund’s
prospectus, or offering materials). Certain Mutual Funds charge a 12b-1 fee to cover annual
marketing or distribution costs. The 12b-1 fees are paid to the custodians, not our firm or our
Financial Advisors. The client should review our fees and the fees charged by Managers, funds,
brokers, and others to fully understand the total amount of fees paid by the client for investment
and financial-related services. Please see Item 12 -Brokerage Practices for additional
information.
Clients typically pay management fees to us separately from the brokerage expenses of the
account. Accordingly, our clients will pay a management fee, plus the cost of transactions in the
account. Alternatively, clients participating in our Wrap Fee Program will pay one inclusive fee
that includes our management fee and the brokerage expenses incurred in the management of
their investment portfolio. Our wrap fee program is further described in our Appendix 1, Wrap
Fee Program Brochure, which is provided to our clients at or before the time of establishing a
wrap fee account. Inasmuch as we pay the transaction and execution costs associated with
client accounts, this can create a disincentive for us to trade securities in wrap accounts.
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Termination & Refunds:
We charge our advisory fees quarterly in advance, except for American Funds, Lincoln
Financial, Nationwide and SEI accounts in which fees are charged in arrears. SEI charges
fees monthly, not quarterly. In the event that you wish to terminate our services, we will refund
the unearned portion of our advisory fee to you. You need to contact us by phone or in writing
and state that you wish to terminate our services. Upon notification of termination, we will
proceed to close out your account. If you pay advisory fees in advance, we will process a
pro-rata refund of unearned advisory fees. If you are in a program that charges advisory fees
in arrears, we will generate a final invoice or the Custodian will charge your account for fees
earned.
Commissionable Securities Sales:
Many of our associated persons are also associated with LPL, a FINRA and SIPC member and
registered broker/dealer and registered investment adviser, as broker-dealer registered
representatives (“Dually Registered Persons”). As such, they may offer you products and
services from this arrangement. These associated persons are entitled to receive commissions
or other remuneration on the sale of insurance as well as other products. To protect client
interests, our policy is to disclose all forms of compensation before any such transaction is
executed. Clients will not pay both a commission to these individuals and also pay an advisory
fee to the firm on the same pool of assets. These fees are exclusive of each other. Clients are
under no obligation to purchase any products or services from any associated person of IFGA.
Item 6: Performance-Based Fees & Side-By-Side Management
The Firm does not have any performance-based fee arrangements. “Side-by-Side
Management” refers to a situation in which the same firm manages accounts that are billed
based on a percentage of assets under management and at the same time manages other
accounts for which fees are assessed on a performance fee basis. Because we have no
performance-based fee accounts, we have no side-by-side management.
Item 7: Types of Clients & Account Requirements
Types of clients we typically manage accounts on behalf of, include:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates and Charitable Organizations;
• Pension and Profit-Sharing Plans;
• Corporations, Limited Liability Companies and/or Other Business Types.
Our requirements for opening and maintaining accounts or otherwise engaging us:
There is no minimum account balance to be a client, but some accounts require minimums
to open, depending on the platform. The Client will be made aware of these minimums before
opening an account. In addition, we have no minimum fee for written financial plans.
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Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
Methods of Analysis
Investing in securities involves risk of loss that clients should be prepared to bear. Past
performance is not a guarantee of future returns. Security analysis methods may include:
Cyclical Analysis: In this type of technical analysis, we measure the movements of a particular
stock against the overall market in an attempt to predict the price movement of the security.
Fundamental Analysis: We attempt to measure the 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
good time to sell). Fundamental analysis does not attempt to anticipate market movements.
This presents a potential risk, as the price of a security can move up or down along with the
overall market regardless of the economic and financial factors considered in evaluating the
stock.
Technical Analysis: We analyze past market movements and apply 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. This presents a risk in that a poorly managed or financially unsound
company may underperform regardless of market movement.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill
liquidity or income needs in a portfolio, or to add a component of capital preservation. We will
generally evaluate and select individual bonds or bond funds based on a number of factors
including, without limitation, rating, yield, and duration.
We generally invest client’s cash balances in money market funds, FDIC Insured Certificates
of Deposit, high-grade commercial paper and/or government backed debt instruments.
Ultimately, we try to achieve the highest return on our client’s cash balances through relatively
low-risk conservative investments. In most cases, at least a partial cash balance will be
maintained in a money market account for the debiting of advisory fees.
Investment Strategies We Use
The investment strategy for each specific Client is based upon the objectives stated by the
Client during consultations. The Client may change these objectives at any time by providing
written notice to IFGA. Each Client executes a Client profile form or similar form that
documents their objectives and their desired investment strategy.
Risk of Investments and Strategies Utilized
Investing in securities involves risk of loss that clients should be prepared to bear. IFGA’s
investment approach constantly keeps the risk of loss in mind. Investors may face the
following investment risks:
General Investment and Trading Risks. Clients may invest in securities and other financial
instruments using strategies and investment techniques with significant risk characteristics.
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The investment program utilizes such investment techniques as option transactions, margin
transactions, short sales, leverage, and derivatives trading, the use of which can, in certain
circumstances, maximize the adverse impact to which a Client may be subject.
Interest-rate Risk. Fluctuations in interest rates may cause investment prices to fluctuate. For
example, when interest rates rise, yields on existing bonds become less attractive, causing
their market values to decline.
Inflation Risk. When any type of inflation is present, a dollar today will buy more than a dollar
next year, because purchasing power is eroding at the rate of inflation.
Currency Risk. Overseas investments are subject to fluctuations in the value of the dollar
against the currency of the investment’s originating country. This is also referred to as
exchange rate risk.
Reinvestment Risk. This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed
income securities.
Liquidity Risk. Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
Management Risk. The advisor’s investment approach may fail to produce the intended
results. If the advisor’s assumptions regarding the performance of a specific asset class or fund
are not realized in the expected time frame, the overall performance of the Client’s portfolio
may suffer.
Cybersecurity Risk. IFGA and its service providers may be subject to operational and
information security risks resulting from cyberattacks. Cyberattacks include, among other
behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks
on websites, the unauthorized release of confidential information or various other forms of
cybersecurity breaches. Cybersecurity attacks affecting IFGA and its service providers may
adversely impact clients. For instance, cyberattacks may interfere with the processing of
transactions, cause the release of private information about clients, impede trading, subject
IFGA to regulatory fines or financial losses, and cause reputational damage. Similar types of
cybersecurity risks are also present for issuers of securities in which clients may invest in,
qualified custodians, governmental and other regulatory authorities, exchange and other
financial market operators, or other financial institutions. Cybersecurity incidents that could
ultimately cause them to incur losses, including, for example, financial losses, cost and
reputational damages, and loss from damage or interruption of systems. Although IFGA has
established its systems to reduce the risk of these incidents from coming to fruition, there is
no guarantee that these efforts will always be successful, especially considering that IFGA
does not directly control the cybersecurity measures and policies employed by third-party
service providers.
Options Trading. The risks involved with trading options are that they are very time-sensitive
investments. An options contract is generally for a few months. The buyer of an option could
lose his or her entire investment even with a correct prediction about the direction and
magnitude of a particular price change if the price change does not occur in the relevant time
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period (i.e., before the option expires). Additionally, options are less tangible than some other
investments. An option is a “book-entry” only investment without a paper certificate of
ownership.
Trading on Margin. In a cash account, the risk is limited to the amount of money that has
been invested. In a margin account, risk includes the amount of money invested plus the
amount that has been loaned. As market conditions fluctuate, the value of marginable
securities will also fluctuate, causing a change in the overall account balance and debt ratio.
As a result, if the value of the securities held in a margin account depreciates, the Client will
be required to deposit additional cash or make full payment of the margin loan to bring the
account back up to maintenance levels. Clients who cannot comply with such a margin call
may be sold out or bought in by the brokerage firm.
Exchange-Traded Funds. ETFs are a type of index fund bought and sold on a securities
exchange. The risks of owning an ETF generally reflect the risks of owning the underlying
securities they are designed to track, although lack of liquidity in an ETF could result in it being
more volatile and ETFs have management fees that increase their costs. ETFs are also subject
to other risks, including: (i) the risk that their prices may not correlate perfectly with changes
in the underlying reference units; and (ii) the risk of possible trading halts due to market
conditions or other reasons that, in the view of the exchange upon which an ETF trades, would
make trading in the ETF inadvisable.
Mutual Fund Risks. An investment in mutual funds could lose money over short or even long
periods. A mutual fund’s share price and total return are expected to fluctuate within a wide
range, like the fluctuations of the overall stock market.
Common Stocks and Equity-Related Securities. Certain ETFs or mutual funds hold common
stock. Prices of common stock react to the economic condition of the company that issued
the security, industry and market conditions, and other factors which may fluctuate widely.
Investments related to the value of stocks may rise and fall based on an issuer’s actual and
anticipated earnings, changes in management, the potential for takeovers and acquisitions,
and other economic factors. Similarly, the value of other equity-related securities, including
preferred stock, warrants, and options may also vary widely.
Small- and Mid-Cap Risks. Certain ETFs and mutual funds hold securities of small- and mid-
cap issuers. Securities of small-cap issuers may present greater risks than those of large-cap
issuers. For example, some small- and mid-cap issuers often have limited product lines,
markets, or financial resources. They may be subject to high volatility in revenues, expenses,
and earnings. Their securities may be thinly traded, may be followed by fewer investment
research analysts, and may be subject to wider price swings and thus may create a greater
chance of loss than when investing in securities of larger-cap issuers. The market prices of
securities of small- and mid-cap issuers generally are more sensitive to changes in earnings
expectations, to corporate developments, and to market rumors than are the market prices
of large-cap issuers.
Futures, Commodities, and Derivative Investments. Certain ETFs and mutual funds hold
commodities, commodities contracts, and/or derivative instruments, including futures,
options, and swap agreements. The prices of commodities contracts and derivative
instruments, including futures and options, are highly volatile. Payments made pursuant to
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swap agreements may also be highly volatile. Price movements of commodities, futures and
options contracts, and payments pursuant to swap agreements are influenced by, among
other things, interest rates, changing supply and demand relationships, trade, fiscal, monetary
and exchange control programs and policies of governments, and national and international
political and economic events and policies. The value of futures, options, and swap
agreements also depends upon the price of the commodities underlying them. In addition,
Client assets are subject to the risk of the failure of any of the exchanges on which its positions
trade or of its clearinghouses or counterparties.
Highly Volatile Markets. The prices of financial instruments can be highly volatile. Price
movements of forward and other derivative contracts are influenced by, among other things,
interest rates, changing supply and demand relationships, trade, fiscal, monetary and
exchange control programs and policies of governments, and national and international
political and economic events and policies. Clients are also subject to the risk of failure of any
of the exchanges on which their positions trade or of its clearinghouses.
Non-U.S. Securities. Certain ETFs and mutual funds hold securities of non-U.S. issuers.
Investments in securities of non-U.S. issuers pose a range of potential risks which could
include expropriation, confiscatory taxation, imposition of withholding or other taxes on
dividends, interest, capital gains or other income, political or social instability, illiquidity, price
volatility, and market manipulation. In addition, less information may be available regarding
securities of non-U.S. issuers, and non-U.S. issuers may not be subject to accounting, auditing,
and financial reporting standards, and requirements comparable to or as uniform as those of
U.S. issuers.
Emerging Markets. Certain ETFs and mutual funds hold securities of emerging markets
issuers. In addition to the risks associated with investments outside of the United States,
investments in emerging markets (i.e., the developing countries) may involve additional risks.
Emerging markets generally are not as efficient as those in developed countries. In some
cases, a market for the security may not exist locally, and transactions will need to be made
on a neighboring exchange. Volume and liquidity levels in emerging markets are lower than
in developed countries. When seeking to sell emerging market securities, little or no market
may exist for the securities. In addition, issuers based in emerging markets are not generally
subject to uniform accounting and financial reporting standards, practices, and requirements
comparable to those applicable to issuers based in developed countries, thereby potentially
increasing the risk of fraud or other deceptive practices.
Capitalization Risks. Investing in Companies within the same market capitalization category
carries the risk that the category may be out of favor due to current market conditions or
investor sentiment.
Market Risks. Turbulence in the financial markets and reduced liquidity may negatively affect
the Companies, which could have an adverse effect on each of them. If the securities of the
Companies experience poor liquidity, investors may be unable to transact at advantageous
times or prices, which may decrease the Company’s returns. In addition, there is a risk that
policy changes by central governments and governmental agencies, including the Federal
Reserve or the European Central Bank, which could include increasing interest rates, could
cause increased volatility in financial markets, which could have a negative impact on the
Companies. Furthermore, local, regional, or global events such as war, acts of terrorism, the
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spread of infectious illness or other public health issues, recessions, or other events could have
a significant impact on the Companies. For example, the rapid and global spread of a highly
contagious novel coronavirus respiratory disease, designated COVID-19, resulted in extreme
volatility in the financial markets and severe losses; reduced liquidity of many Companies’
securities; restrictions on international and, in some cases, local travel; significant disruptions
to business operations (including business closures); strained healthcare systems; disruptions to
supply chains, consumer demand and employee availability; and widespread uncertainty
regarding the duration and long-term effects of this pandemic. Some sectors of the economy
and individual issuers experienced particularly large losses. In addition, the COVID-19
pandemic resulted in increased volatility and/or decreased liquidity in the securities markets.
The Companies’ values could decline over short periods due to short-term market
movements and over longer periods during market downturns.
Inverse and Leveraged Products. IFGA may recommend and engage in trading with
leveraged and inverse products. These products are aggressive in nature and carry unusual
and significant risk. They are not appropriate for inexperienced investors. These products are
intended to be used/traded daily. Most leveraged and inverse ETFs reset on a daily basis and
have published prospectuses that state (I) they're designed to achieve their stated objective
within one day, (2) clients can lose all of their investment potentially in one day, and (3) holding
these securities for periods longer than one day could lead to losses even if the underlying
index moves in the anticipated direction. Regulatory organizations, such as FINRA & SEC, have
released alerts stating that inverse and leveraged ETFs that reset daily typically are not
suitable for retail investors who plan to hold them longer than one day. Managers may hold
these products in client accounts for periods of time significantly greater than one day.
Investors with holding periods longer than a day expose themselves to substantial risk as the
holding period returns will deviate from the returns to a leveraged or inverse investment in
the index. It is possible for an investor in a leveraged ETF to experience negative returns even
when the underlying index has positive returns.
Penny Stock Risks. Generally, Penny Stocks are low-priced shares of small companies that
are not traded on an exchange. Penny Stocks typically trade over-the-counter, such as on the
OTC Bulletin Board or Pink Sheets. Penny Stocks, unlike listed stocks, are not subject to SEC
reporting requirements or the listing standards of stock exchanges. Because of this,
information about the Penny Stock companies can be difficult to find and verify. Penny Stocks
also have lower liquidity as they are traded less frequently. This also leads to higher volatility.
For these reasons, Penny Stocks are considered to be speculative investments and clients who
trade in penny stocks should be prepared for the possibility that they may lose their entire
investment, or an amount in excess of their investment if they purchased Penny Stocks on
margin.
Variable Annuity Risk. A variable annuity is a form of insurance where the seller or issuer
(typically an insurance company) makes a series of future payments to a buyer (annuitant) in
exchange for the immediate payment of a lump sum (single-payment annuity) or a series of
regular payments (regular-payment annuity). The payment stream from the issuer to the
annuitant has an unknown duration based principally upon the date of death of the annuitant.
At this point, the contract will terminate, and the remainder of the funds accumulated are
forfeited unless there are other annuitants or beneficiaries in the contract. Annuities can be
purchased to provide an income during retirement. Unlike fixed annuities
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that make payments in fixed amounts or in amounts that increase by a fixed percentage,
variable annuities pay amounts that vary according to the performance of a specified set of
investments, typically bond and equity mutual funds. Many variable annuities typically impose
asset-based sales charges or surrender charges for withdrawals within a specified period.
Variable annuities may impose a variety of fees and expenses, in addition to sales and
surrender charges, such as mortality and expense risk charges; administrative fees; underlying
fund expenses; and charges for special features, all of which can reduce the return. Earnings
in a variable annuity do not provide all the tax advantages of 401(k)s and other before-tax
retirement plans. Once the investor starts withdrawing money from their variable annuity,
earnings are taxed at the ordinary income rate, rather than at the lower capital gains rates
applied to other non-tax-deferred vehicles which are held for more than one year. Proceeds
of most variable annuities do not receive a "step-up" in cost basis when the owner dies like
stocks, bonds and mutual funds do. Some variable annuities offer "bonus credits." These are
usually not free. In order to fund them, insurance companies typically impose mortality and
expense charges and surrender charge periods. In an exchange of an existing annuity for a
new annuity (so-called 1035 exchanges), the new variable annuity may have a lower contract
value and a smaller death benefit; may impose new surrender charges or increase the period
of time for which the surrender charge applies; may have higher annual fees; and provide
another commission for the broker.
Alternative Investments. When appropriate for a Client’s objective, risk tolerance and
qualifications, IFGA recommends the Client participate in private issues, such as single
purpose vehicles, funds of funds, private equity, and hedge funds. These are usually structured
as limited partnerships with differing minimum investments, liquidity, fees and carries.
The foregoing list of risk factors does not purport to be a complete enumeration or
explanation of the risks involved in an investment with IFGA.
Use of Third-Party Model Portfolios. IFGA may utilize model portfolios provided by third-
party investment managers (“Model Providers”) as part of its investment strategy for certain
clients. These model portfolios are typically designed based on specific investment
objectives, risk tolerances, and time horizons, and may include allocations across various
asset classes.
Model Providers deliver portfolio recommendations or models, which IFGA may implement
directly in client accounts, either as-is or with modifications. Model Providers do not have any
discretionary authority over client accounts, and IFGA retains final decision-making authority
regarding the implementation of the models.
Clients should be aware of the following risks associated with the use of third-party model
portfolios:
• Model Risk: The strategies provided by Model Providers are based on assumptions and
historical data that may not accurately predict future performance.
• Limited Customization: Model portfolios may not be tailored to the specific needs or
financial circumstances of each individual client. However, IFGA reviews each client's
individual needs before recommending a model portfolio.
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• Third-Party Dependence: IFGA relies on the accuracy and timeliness of the models
provided by third parties. Delays or errors in model delivery could affect portfolio
performance.
•
Implementation Risk: Differences in trading platforms, execution timing, or account
restrictions may result in performance deviations between the model and a client’s
actual portfolio.
IFGA conducts due diligence on all Model Providers before selecting them and continues to
monitor their performance and strategies on an ongoing basis.
IFGA does have an arrangement with and may specifically recommend clients utilize model
portfolios created by Invesco Distributors Inc. (“Invesco”). Under the terms of this
arrangement, Invesco provides compensation to IFGA on revenue generated by IFGA’s use of
model portfolios. This arrangement presents a conflict of interest because we have a financial
incentive to recommend that you invest in a model portfolio with Invesco. This conflict is
mitigated as IFGA is bound by fiduciary duty to do what is in the client’s best interest and
reviews each client’s individual needs before recommending a model portfolio.
Item 9: Disciplinary Information
IFGA and its management have not been involved in any criminal or civil actions,
administrative or self-regulatory enforcement proceedings, nor any legal or disciplinary
events that are material to a Client’s or prospective Client’s evaluation of IFGA or the integrity
of its management.
Item 10: Other Financial Industry Activities & Affiliations
Registration as a Broker-Dealer or Broker-Dealer Representative
Certain Investment Advisor Representatives (IAR) of IFGA may also be registered as
Registered Representatives (RR) of LPL Financial, a dually registered Investment Advisor and
Broker-Dealer. This registration allows those IARs to perform brokerage services for clients by
executing security transactions. This practice represents a conflict of interest because
Investment Advisor Representatives are able to choose between offering clients fee-based
programs and services (as is typical of an advisory relationship) and/or commission-based
products and services (as is typical of a brokerage relationship). While a client generally pays
a fee to their Investment Advisor Representatives on an advisory account based on the value
of account assets and not the number of transactions, in their capacities as Registered
Representatives, an Investment Advisor Representative can offer securities and receive a
commission, markup, or markdown on each transaction.
This conflict is mitigated by disclosures, procedures, and IFGA’s fiduciary duty to place the best
interest of the Client first. Moreover, clients are not required to engage the broker-dealer or
its representatives if they do not wish to. More information on this can be found in the
respective Investment Advisor Representative’s Form U4 and ADV 2B.
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Registration as a Futures Commission Merchant, Commodity Pool Operator, or a
Commodity Trading Advisor
Neither IFGA nor its management persons are registered as futures commission merchant,
commodity pool operator, or a commodity trading advisor.
Relationships Material to this Advisory Business and Possible Conflicts of Interest
Certain advisory representatives are also licensed as independent insurance agents and
appointed through various insurance companies to offer a variety of types of insurance
depending upon the individual. The types of insurance that may be available include life
insurance, long term care insurance, fixed annuities, and disability insurance. In such capacity,
the advisory representatives can sell insurance products to clients and receive normal and
customary compensation in the form of commissions. Client’s purchasing insurance from
advisory representatives will receive certain disclosure documents and complete an insurance
application process when conducting such transactions.
Many of IFGA’s IARs have their own legal business entities whose trade names and logos are
used for marketing purposes and may appear on marketing materials and/or client
statements. The clients should understand that the businesses are legal entities of the IAR’s
and not of IFGA. The IARs are under our supervision and the advisory services of the IARs are
provided through our firm.
Selection of Other Advisors or Managers
IFGA may select and appoint one or more Sub-Advisor(s) to provide Sub-Advisor Services to
Client Accounts. When selecting Sub-Advisors, the Client’s best interest will be the main
determining factor of IFGA. IFGA ensures that before selecting other Sub-Advisors that they
are properly licensed or registered as an investment advisor.
Clients placed with TPMs will be billed in accordance with the TPM’s fee schedule which will
be disclosed to the Client prior to signing an agreement. When referring clients to a TPM, the
Client’s best interest will be the main determining factor of IFGA. IFGA ensures that before
selecting other advisors for Client that the other advisors are properly licensed or registered
as an investment advisor.
These practices represent conflicts of interest because IFGA is compensated directly or
indirectly for recommending certain TPMs and may choose to recommend a particular TPM
based on the compensation that IFGA is to receive. This conflict is mitigated by disclosures,
procedures, and IFGA’s fiduciary obligation to act in the best interest of its clients. Clients are
not required to accept any recommendation of TPMs given by IFGA and have the option to
receive investment advice through other money managers of their choosing.
As described elsewhere in this brochure, IFGA refers clients to third party investment advisory
firms for advisory services. IFGA receives a portion of the investment advisory fee paid by the
client to the third-party advisor for the referral. This referral fee from the third-party advisory
firm may be a percentage of assets under management (generally ranges from 0% to 1.00%)
or as a flat annual fee. This presents a conflict of interest as IFGA does not refer clients to other
third-party advisors that do not share the advisory fee. In some cases, the third-party investment
advisory firm will also pay additional compensation to IFGA in the form
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of an asset retention bonus or loyalty program payment. This also presents a conflict of
interest in that IFGA has a financial incentive to recommend that you maintain your account
with a third-party advisory firm that pays an asset retention bonus or loyalty program
payment.
As discussed previously, advisory representatives of
IFGA may also be registered
representatives of LPL. Because of this relationship, LPL may have access to certain confidential
information (for example, financial information, investment objectives, transactions, and
holdings) about IFGA’s clients, even if the Client does not establish an account through LPL. If
you would like a copy of LPL’s privacy policy, please contact your IFGA advisory representative
or our Chief Compliance Officer, Crystal Epstein to request a copy. Please see Item 12 –
Brokerage Practices for more information.
Item 11: Code of Ethics, Participation, or Interest in Client Transactions &
Personal Trading
Code of Ethics
The affiliated persons (affiliated persons include employees and/or independent contractors)
of IFGA have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth
standards of conduct expected of IFGA affiliated persons and addresses conflicts that may
arise. The Code defines acceptable behavior for affiliated persons of IFGA. The Code reflects
IFGA and its supervised persons’ responsibility to act in the best interest of their Client.
One area which the Code addresses is when affiliated persons buy or sell securities for their
personal accounts and how to mitigate any conflict of interest with our clients. We do not
allow any affiliated persons to use non-public material information for their personal profit or
to use internal research for their personal benefit in conflict with the benefit to our clients.
IFGA’s policy prohibits any person from acting upon or otherwise misusing non-public or
inside information. No advisory representative or other affiliated person, officer, or director of
IFGA may recommend any transaction in a security or its derivative to advisory clients or
engage in personal securities transactions for a security or its derivatives if the advisory
representative possesses material, non-public information regarding the security.
IFGA’s Code is based on the guiding principle that the interests of the Client are our top
priority. IFGA’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to
our clients and must diligently perform that duty to maintain the complete trust and confidence
of our clients. When a conflict arises, it is our obligation to put the Client’s interests over the
interests of either affiliated persons or the company.
The Code applies to “access” persons. “Access” persons are affiliated persons who have access
to non-public information regarding any clients' purchase or sale of securities, or non-public
information regarding the portfolio holdings of any reportable fund, who are involved in
making securities recommendations to clients, or who have access to such recommendations
that are non-public.
IFGA will provide a copy of the Code of Ethics to any Client or prospective Client upon request.
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Recommendations Involving Material Financial Interests
LPL’s parent company, LPL Investment Holdings Inc., is a publicly traded company (Symbol:
LPLA). IFGA does not recommend or solicit orders of LPL Investment Holdings Inc. stock in
Program accounts.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of
Interest
IFGA and its affiliated persons may invest in the same securities (or related securities, e.g.,
warrants, options, or futures) that IFGA or an affiliated person recommends to clients. In order to
mitigate conflicts of interest, such as frontrunning, IFGA’s Chief Compliance Officer, or their
designee, will no less than quarterly, review firm and/or employee personal trading of its
affiliated persons. These reviews ensure that the personal trading of affiliated persons does
not disadvantage clients of IFGA.
Client Securities Recommendations or Trades and Concurrent Advisory Firm
Securities Transactions and Conflicts of Interest
IFGA and its affiliated persons may recommend securities, or buy or sell securities for Client’s
accounts, at or about the same time, that they also buy or sell the same securities in their own
account(s). As stated above, in order to mitigate conflicts of interest, such as frontrunning,
IFGA’s Chief Compliance Officer, or their designee, will no less than quarterly, review firm
and/or personal holdings of its affiliated persons. These reviews ensure that the personal
trading of affiliated persons does not disadvantage clients of IFGA.
Item 12: Brokerage Practices
Selecting a Brokerage Firm
We seek to recommend a custodian/broker-dealer who will hold your assets and execute
transactions on terms that are overall most advantageous when compared to other available
providers and their services. We consider a wide range of factors, including, among others, the
following:
• Timeliness of execution
• Timeliness and accuracy of trade confirmations
• Research services provided
• Ability to provide investment ideas
• Execution facilitation services provided
• Record keeping services provided
• Custody services provided
• Frequency and correction of trading errors
• Ability to access a variety of market venues
• Expertise as it relates to specific securities
• Financial condition
• Business reputation
• Quality of services
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LPL Financial
While our firm recommends that clients establish brokerage accounts with LPL, member
FINRA/SIPC, clients are advised that they are under no obligation to implement our
recommendations. Clients may pay commissions or fees that are higher or lower than those
that may be obtained elsewhere for similar services.
We receive support services and/or products from LPL, many of which assist us to better
monitor and service program accounts maintained at LPL. These support services and/or
products may be received without cost, at a discount, and/or at a negotiated rate. Where such
services are provided by a third-party vendor, LPL will either make a payment to us to cover
the cost of such services, reimburse us for the cost associated with the services, or pay the
third-party vendor directly on our behalf. The products and support services we receive
include:
investment-related research
•
• pricing information and market data
• software and other technology that provide access to client account data
• compliance and/or practice management-related publications
• consulting services
• attendance at conferences, meetings, and other educational and/or social
events
• marketing support
• computer hardware and/or software
• other products and services used by us in furtherance of our investment
advisory business operations
The products and services described above are provided to us as part of our overall
relationship with LPL. While as a fiduciary we endeavor to act in our clients’ best interests, the
receipt of these benefits creates a conflict of interest because our recommendation that
clients custody their assets at LPL is based in part on the benefit to us of the availability of the
foregoing products and services and not solely on the nature, cost or quality of custody or
brokerage services provided by LPL.
While LPL does not participate in, or influence the formulation of, the investment advice we
provide, certain of our supervised persons are Dually Registered Persons. Dually Registered
Persons are restricted by certain FINRA rules and policies from maintaining client accounts at
another custodian or executing client transactions in such client accounts through any
broker-dealer or custodian that is not approved by LPL. LPL charges a fee for its oversight of
activities conducted through these other broker-dealers and custodians. This arrangement
presents a conflict of interest because we have a financial incentive to recommend that you
maintain your account with LPL rather than with another broker-dealer or custodian to avoid
incurring the oversight fee.
LPL provides various benefits and payments to Dually Registered Persons that are new to the
LPL platform to assist the representative with the costs (including foregone revenues during
account transition) associated with transitioning his or her business to the LPL platform
(collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance
payments are intended to be used for a variety of purposes, including but not necessarily
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limited to, providing working capital to assist in funding the Dually Registered Person’s
business, satisfying any outstanding debt owed to the Dually Registered Person’s prior firm,
offsetting account transfer fees (ACATs) payable to LPL as a result of the Dually Registered
Person’s clients transitioning to LPL’s custodial platform, technology set-up fees, marketing
and mailing costs, stationary and licensure transfer fees, moving expenses, office space
expenses, staffing support and termination fees associated with moving accounts.
Transition payments are generally based on the size of the Dually Registered Person’s business.
Please refer to the relevant Part 2B Brochure Supplement for more information about any
specific Transition Payments your representative may have received. The receipt of Transition
Assistance by such Dually Registered Persons creates conflicts of interest relating to our advisory
business because it creates a financial incentive for our representatives to recommend that
clients maintain their accounts with LPL.
We attempt to mitigate these conflicts of interest by evaluating and recommending that
clients use LPL’s services based on the benefits that such services provide to our clients, rather
than the Transition Assistance earned by any particular Dually Registered Person.
Recommendation of Custodians other than LPL
We are assessed an “oversight fee” by LPL based on all assets held away from LPL. This fee is
passed on to the Advisor of record. This is a conflict of interest because our Advisors have a
financial incentive to recommend the use of LPL as the custodian for client accounts. To
mitigate this conflict, our Advisors are required to act in the best interest of the client, not their
own interests, when recommending a custodian.
Schwab Advisor Services
We may recommend that clients establish brokerage accounts with the Schwab Advisor
Services division of Charles Schwab & Co., Inc. (Schwab), a registered broker-dealer, member
SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. The final
decision to custody assets with Schwab is at the discretion of the Advisor’s clients, including
those accounts under ERISA or IRA rules and regulations, in which case the client is acting as
either the plan sponsor or IRA account holder. We are independently owned and operated and
not affiliated with Schwab. Schwab provides us with access to its institutional trading and
custody services, which are typically not available to Schwab retail investors. These services
generally are available to independent investment advisors on an unsolicited basis, at no
charge to them so long as a total of at least $10 million of the advisor’s clients’ assets are
maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage
services that are related to the execution of securities transactions, custody, research,
including that in the form of advice, analyses and reports, and access to mutual funds and
other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment.
For our client accounts maintained in its custody, Schwab generally does not charge
separately for custody services but is compensated by account holders through commissions
or other transaction-related or asset-based fees for securities trades that are executed
through Schwab or that settle into Schwab accounts.
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Schwab also makes available to us other products and services that benefit our firm but may
not benefit its clients’ accounts. These benefits may include national, regional or IFGA specific
educational events organized and/or sponsored by Schwab Advisor Services. Other potential
benefits may include occasional business entertainment of personnel of our firm by Schwab
Advisor Services personnel, including meals, invitations to sporting events, including golf
tournaments, and other forms of entertainment, some of which may accompany educational
opportunities. Other of these products and services assist us in managing and administering
clients’ accounts. These include software and other technology (and related technological
training) that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for multiple
client accounts), provide research, pricing information and other market data, facilitate
payment of our advisory fees from its clients’ accounts, and assist with back-office training
and support functions, recordkeeping and client reporting. Many of these services generally
may be used to service all or some substantial number of our accounts, including accounts
not maintained at Schwab Advisor Services. Schwab Advisor Services also makes available to
us other services intended to help our firm manage and further develop its business
enterprise. These services may include professional compliance, legal and business
consulting, publications and conferences on practice management, information technology,
business succession, regulatory compliance, employee benefits providers, human capital
consultants, insurance, and marketing. In addition, Schwab may make available, arrange
and/or pay vendors for these types of services rendered to us by independent third parties.
Schwab Advisor Services may discount or waive fees it would otherwise charge for some of
these services or pay all or a part of the fees of a third-party providing these services to us.
While, as a fiduciary, we endeavor to act in our clients’ best interests, our recommendation
that clients maintain their assets in accounts at Schwab may be based in part on the benefit
to IFGA of the availability of some of the foregoing products and services and other
arrangements and not solely on the nature, cost or quality of custody and brokerage services
provided by Schwab, which may create a potential conflict of interest.
SEI Investments Management Corp
We may also recommend clients establish a custodial account with SEI Investment
Management Corp (SEI). We work primarily with SEI for administrative convenience and also
because SEI offers a good value to our clients for the transaction costs and other costs
incurred. SEI provides services which may include research, brokerage, custody, access to
mutual funds and other investments that are otherwise available only to institutional investors
or would require a significantly higher minimum initial investment.
SEI also makes available to us other products and services that benefit us but may not directly
benefit client accounts. Some of these other products and services assist us in managing and
administering clients’ accounts. These include software and other technology that provide
access to client account data, provide research, facilitate payment of our fees from client
accounts and assist with back office support, recordkeeping, and client reporting.
SEI may also provide other services intended to help us manage and further develop their
respective business enterprises. These services may include consulting, publications and
presentations on practice management, information technology, business succession,
regulatory compliance, and marketing. In addition, SEI may make available, arrange, and/or
discount these types of services to us by independent third parties. SEI may discount or waive
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fees that it would otherwise charge for some of these services or pay all or a part of the fees
charged by a third-party for providing these services to us. The availability of the foregoing
products and services is not contingent on us committing to SEI any specific amount of
business (assets in custody or trading).
We do not aggregate the purchase or sale of securities for SEI client accounts. Most trades
involve mutual funds and exchange traded funds where trade aggregation does not provide
any benefit to our clients.
Soft Dollars
Although our Firm does not have any specific Soft Dollar arrangements, we do receive
research and other benefits and services outlined above. These benefits and services do not
influence our investment advice. Our firm does not accept products or services that do not
qualify for Safe Harbor outlined in Section 28(e) of the Securities Exchange Act of 1934, such
as those services that do not aid in investment decision-making or trade execution.
Client Brokerage Commissions
Our firm does not refer clients to particular broker-dealers in exchange for client referrals from
those broker-dealers.
Brokerage for Client Referrals
Our firm does not receive brokerage for client referrals.
Aggregation of Trades
Our firm typically directs trading in individual client accounts as and when trades are
appropriate based on the client’s investment plan, without regard to activity in other client
accounts. When client accounts require rebalancing to meet their investment objectives,
those trades will be directed individually, and the purchase or sale price of a security may vary
by account. However, we may aggregate trades together for multiple client accounts, most
often when these accounts are being directed to buy or sell the same securities within a
portfolio model. If such an aggregated trade is not filled, we will automatically allocate shares
received (in an aggregated purchase) or sold (in an aggregated sale) across participating
accounts on a pro rata or other fair basis.
Item 13: Review of Accounts or Financial Plans
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews
Advisory representatives conduct reviews of client Program accounts on a periodic basis (at
least annually). Account reviews are performed more frequently when market conditions
dictate. Reviews of Client accounts include, but are not limited to, a review of Client
documented risk tolerance, adherence to account objectives, investment time horizon, and
suitability criteria, reviewing target allocations of each asset class to identify if there is an
opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities.
Financial plans are updated as requested by the Client and pursuant to a new or amended
agreement, IFGA suggests updating at least annually.
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Factors That Will Trigger a Non-Periodic Review of Client Accounts
Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws,
new investment information, and changes in a Client's own situation. Client account reviews
may also be triggered upon client request.
Content and Frequency of Regular Reports
Clients receive written account statements no less than quarterly for managed accounts.
Account statements are issued by the Client’s custodian. Client receives confirmations of each
transaction in account from Custodian and an additional statement during any month in which
a transaction occurs. IFGA may also send periodic or other event-inspired reports based on
market or portfolio activity. Reports will generally be provided in electronic format. Additional
reporting may also be available upon request from your advisory representative.
Item 14: Client Referrals & Other Compensation
Economic Benefits Provided by Third Parties
As part of its fiduciary duties to clients, IFGA endeavors at all times to put the interests of its
clients first. Clients should be aware, however, that the receipt of economic benefits by IFGA
or its related persons in and of itself creates a potential conflict of interest and may indirectly
influence the IFGA’s choice of a particular custodian for custody and brokerage services.
LPL Financial
As referenced in Item 12 above, the IFGA may receive an indirect economic benefit from LPL
Financial. IFGA, without cost (and/or at a discount), may receive support services and/or products
from LPL Financial. IFGA’s clients do not pay more for investment transactions effected and/ or
assets maintained at LPL Financial as a result of this arrangement. There is no corresponding
commitment made by IFGA to LPL Financial or any other entity to invest any specific amount
or percentage of client assets in any specific mutual funds, securities, or other investment
products as a result of the above arrangement. IFGA and/or its Dually Registered Persons are
incentivized to join and remain affiliated with LPL Financial and to recommend that clients
establish accounts with LPL Financial through the provision of Transition Assistance (discussed
in Item 12 above). LPL also provides other compensation to IFGA and its Dually Registered
Persons, including but not limited to, bonus payments, repayable and forgivable loans, stock
awards and other benefits. The receipt of any such compensation creates a financial incentive
for your representative to recommend LPL Financial as custodian for the assets in your advisory
account. We encourage you to discuss any such conflicts of interest with your representative
before making a decision to custody your assets at LPL Financial.
Other Custodians
Other broker-dealers, such as the custodians referenced in Item 12 above, may also provide
similar indirect economic benefits, support services, and products and do not require higher
payments or fees, or minimums. We receive an economic benefit from our other custodians
in the form of the support products and services they make available to us and other
independent investment advisors whose clients maintain their accounts at their firms.
You do
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not pay more for assets maintained at our other custodians as a result of these arrangements.
However, we benefit from the referral arrangement because the cost of these services would
otherwise be borne directly by us. You should consider these conflicts of interest when
selecting a custodian. The products and services provided by our custodians, how they benefit
us, and the related conflicts of interest are described above (see Item 12—Brokerage
Practices).
Compensation to Non-Advisory Personnel for Client Referrals
IFGA enters into agreements with individuals and organizations, which may be affiliated or
unaffiliated with IFGA, that refer clients to IFGA in exchange for compensation. All such
agreements will be in writing and comply with the requirements of Federal or State regulation.
If a client is introduced to IFGA by a promoter or promoter, IFGA may pay that promoter a
fee. While the specific terms of each agreement may differ, generally, the compensation will
be a flat fee per referral or a percentage of the client’s managed assets. Any such fee shall be
paid solely from IFGA’s investment management fee and shall not result in any additional
charge to the client.
Each prospective client who is referred to IFGA under such an arrangement will be provided
a written disclosure document that describes the nature of the relationship between the
promoter and IFGA.
Item 15: Custody
All assets are held at qualified custodians, which means the custodians provide account
statements directly to clients at least quarterly. Clients are urged to compare the account
statements received directly from their custodians to any documentation or reports prepared
by IFGA.
Our firm has limited custody of client funds due to the deduction of advisory fees. We also
have custody of client funds by allowing Standing Letters of Authorization. We have followed
the conditions required by the SEC for these types of custody and, therefore, do not need to
obtain a yearly surprise audit of our firm.
LPL is the custodian of nearly all our client accounts. From time to time, however, clients may
select an alternate broker to hold accounts in custody. In any case, it is the custodian’s
responsibility to provide clients with confirmations of trading activity, tax forms and at least
quarterly account statements. Clients are advised to review this information carefully, and to
notify us of any questions or concerns. Clients are also asked to promptly notify us if the
custodian fails to provide statements on each account held.
Item 16: Investment Discretion
Clients have the option of granting our firm investment discretion on their behalf, pursuant to
an executed investment advisory client agreement. Clients grant us investment discretion,
through a limited power of attorney in their advisory agreement. The Firm is then authorized
to execute securities transactions, in which securities are bought and sold and the total
amount to be bought and sold.
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IFGA allows clients to place certain restrictions, as outlined in the Client’s Investment Policy
Statement or similar document. Such restrictions could include only allowing purchases of
socially conscious investments. These restrictions must be provided to IFGA in writing.
The Client approves the custodian to be used and the commission rates paid to the custodian.
IFGA does not receive any portion of the transaction fees or commissions paid by the Client
to the custodian.
Item 17: Voting Client Securities
The Firm does not accept the authority to vote proxies on behalf of our clients. Clients will
receive proxies or other solicitations directly from their custodian or a transfer agent. In the
event that proxies are sent to our firm, IFGA will forward them to you and ask the party who
sent them to mail them directly to you in the future. Clients may contact the Firm to discuss
questions they may have about particular proxy votes or other solicitations.
Item 18: Financial Information
IFGA does not require nor solicit prepayment of more than $1,200 in fees per Client, six
months or more in advance.
IFGA has no financial commitment that impairs its ability to meet contractual and fiduciary
commitments to clients and has not been the subject of a bankruptcy proceeding.
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Additional Brochure: IFGA WRAP FEE PROGRAM BROCHURE (2026-03-18)
View Document Text
Form ADV Part 2A
Wrap Fee Program Brochure
IFG Advisory, LLC
CRD #168012
200 Ashford Center North, Suite 400
Atlanta, GA 30338
(770) 353-6331
www.integrated-financial-group.com
March 18, 2026
Item 1: Cover Page
This Wrap Fee Program Brochure provides information about the qualifications and business
practices of IFG Advisory, LLC (hereinafter referred to as the “IFGA,” “us,” “we,” or “firm”). If you
have any questions about the contents of this Brochure, please contact our Chief Compliance
Officer, Crystal Epstein, at (770) 353-6331 or cepstein@intfingroup.com. The information in this
Brochure has not been approved or verified by the United States Securities and Exchange
Commission or by any state authority. IFG Advisory, LLC is an investment advisory firm
registered with the appropriate regulatory authority. Additional information about IFG Advisory,
LLC also is available on the SEC’s website at www.AdviserInfo.sec.gov.
Please note that the use of the term “registered investment adviser” and description of IFG
Advisory, LLC and/or our associates as “registered” does not imply a certain level of skill or
training. You are encouraged to review this Brochure and Brochure Supplements for our
firm’s associates who advise you for more information on the qualifications of our firm and its
associates.
IFG Advisory, LLC
Wrap Fee Program Brochure
March 2026
Item 2: Material Changes
Since the last annual update of this brochure on March 25, 2025, no material changes have
occurred.
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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: SERVICES, FEES, AND COMPENSATION ..................................................................................................... 4
ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................ 7
ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ................................................................... 7
ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ............................................... 8
ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................................................9
ITEM 9: ADDITIONAL INFORMATION ...............................................................................................................................9
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Item 4: Services, Fees, and Compensation
General Information
IFG Advisory, LLC (“IFGA” or “Firm”) is dedicated to providing individuals and other types of
clients with a wide array of investment advisory services including portfolio management,
financial planning, and retirement plan advice. Our firm has been in business as an independent
investment adviser since 2013. The firm is wholly owned by Integrated Financial Group, LLC. In
turn, Integrated Financial Group, LLC. is owned by Donald Warren Patrick and John Land
Bridgers, each a principal owner. Please see the Brochure Supplements(s) for more information
on Mr. Patrick, Mr. Bridgers and other individuals who formulate investment advice and have
direct contact with clients or have discretionary authority over client accounts.
IFG Wrap Fee Program
IFGA offers discretionary and non-discretionary asset management services through a wrap fee
program account (the “Program”) based on the individual needs of our clients. In order for IFGA
to manage your assets, you will be required to establish a wrap account in your name at one of
our primary qualified custodians. Our primary custodians include LPL Financial, LLC (“LPL”) or
Charles Schwab & Co, Inc. (“Schwab”). These custodians provide clearing, custody, and other
brokerage services for accounts established through the Program. You will retain all rights of
ownership on your account, including the right to withdraw securities or cash, vote proxies, and
receive transaction confirmations. In addition, you can also impose restrictions on investing in
certain securities or types of securities at the time you open the account. There is no difference
between how we manage the assets in Wrap accounts and non-Wrap accounts.
Schwab’s Brokerage Services. In addition to the advisory services, the wrap fee program
includes certain brokerage services of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer
registered with the Securities and Exchange Commission and a member of FINRA and SIPC.
We are independently owned and operated and not affiliated with Schwab. Schwab will act
solely as a broker-dealer and not as an investment advisor to you. It will have no discretion over
your account and will act solely on instructions it receives from us [or you]. Schwab has no
responsibility for our services and undertakes no duty to you to monitor our firm’s management
of your account or other services we provide to you. Schwab will hold your assets in a brokerage
account and buy and sell securities and execute other transactions when we [or you] instruct
them to.
In order to hire us to provide management services, you will be asked to enter into a written
investment advisory agreement with us. This agreement will set forth the terms and conditions
of our relationship and what services comprise the fee.
Fees
In a wrap account, clients pay IFGA a single annual advisory fee for advisory services and
execution of transactions. Clients do not pay transaction charges for execution of transactions
in addition to the advisory fee.
IFGA charges a single asset-based fee for services covered by the wrap program.
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Portfolio Value Maximum Fee:
Assets Under Management
$0 – $249,999.99
$250,000 – $499,999.99
$500,000 – $749,999.99
$750,000 – $1,249,999.99
$1,250,000 – $1,999,999.99
$2,000,000 – $4,999,999.99
$5,000,000+
Annual Percentage of Assets
Charge
2.20%
1.95%
1.85%
1.60%
1.45%
1.35%
1.20%
In addition to compensating IFGA for advisory services, the wrap fee you pay IFGA allows us to
pay for execution services provided by LPL or Schwab.
The annual advisory fee for management services is a maximum of 2.20% and is based on a
percentage of the market value of your account, including cash holdings. The fee may also
include Financial Planning and Consulting services. Advisory fees are negotiable between IFGA
and the client, and the amount of the advisory fee will be as agreed upon in writing between
IFGA and the client. The advisory fee may be higher than the fee charged by other investment
advisors for similar services.
Advisory fees are billed quarterly in advance and calculated based on the account’s market value
on the last business day of the prior quarter. The initial advisory fee is due at the beginning of
the quarter following execution of this Agreement and will include the prorated fee for the initial
quarter in addition to the standard quarterly fee for the upcoming quarter. Additional deposits
and withdrawals will be added or subtracted from the account’s value which may lead to an
adjustment of the advisory fee. Lastly, please note that IFGA may group certain related client
accounts, often known as “householding,” for the purposes of achieving the minimum account
size and determining the annualized fee.
IFGA, in its sole discretion, may charge a lesser investment advisory fee based upon certain
criteria (e.g., historical relationship, type of assets, anticipated future earning capacity,
anticipated future additional assets, dollar amounts of assets to be managed, related accounts,
account composition, negotiations with clients, etc.).
When managing a client’s account on a wrap fee basis, IFGA shall receive, as payment for its
investment advisory services, the balance of the wrap fee after all other costs incorporated into
the wrap fee have been deducted. Since transaction fees in a wrap fee account are paid by IFGA,
a conflict of interest exists as IFGA has the Firm has a disincentive to trade securities in the client
account.
In the event that you wish to terminate our services, we will refund the unearned portion of our
advisory fee to you. You need to contact us by phone or in writing and state that you wish to
terminate our services. Upon notification of termination, we will proceed to close out your
account. For accounts opened or closed mid-billing period, fees will be prorated based on the
days services are provided during the given period. In the case of hourly engagements, fees will
be prorated based on the work completed at the stated hourly rate . All unpaid earned fees will
be due to IFGA and all unearned fees will be refunded to the Client. Any increase in fees will be
acknowledged in writing by both parties before any increase in said fees occurs.
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Fee Differentials
As indicated above, IFGA prices its services based upon various objective and subjective factors.
Clients could pay diverse fees based upon the market value of their assets, the complexity of the
engagement, and the level and scope of the overall investment advisory and/or consulting
services to be rendered. As a result of these factors, the services to be provided by IFGA to any
particular client could be available from other investment advisers at lower fees. All clients and
prospective clients should be guided accordingly.
Fee Comparison
Clients may be able to purchase services similar to those offered under the Program from other
service providers either separately or as part of a similar wrap fee program. These services or
programs may cost more or less than our Program, depending on the fees charged by such
other service providers. A wrap fee is not based directly on the number of transactions in your
account. Various factors influence the relative cost of our wrap fee program to you, including
the cost of investment advice, custody, and brokerage services if you purchased them
separately, the types of investments held in your account, and the frequency, type, and size of
trades in your account. The program could cost you more or less than purchasing our
investment advice and custody/brokerage services separately.
For example, the Program Fee, which is fixed regardless of the number of transactions occurring
in the account, may be more or less than paying for execution on a per-transaction basis.
Additional Fees
Our wrap fee covers our advisory services and the execution services provided by LPL or Schwab.
As a result, we do not have an incentive to execute transactions for your account at LPL or
Schwab.
IFGA pays all transaction fees for all accounts under this Program. However, our wrap fee does
not cover all fees and costs. Custodians may charge other related costs on the purchases or sales
of mutual funds, equities, bonds, options, margin interest, and mark-ups, markdowns, or
spreads paid to market makers. Mutual funds, money market funds, and exchange-traded
funds may also charge internal management fees, which are disclosed in the fund’s prospectus.
IFGA does not directly receive any compensation from these fees.
12-b1 Fees
If a Client account holds certain shares of mutual funds or other investments that pay 12b-1
(commonly referred to as “trail commissions”), you should know that those 12b-1 fees are paid to
the broker-dealer (typically LPL), which will be in addition to the management fees paid to IFGA.
This can happen even when a share class of the same fund was available that would not provide
the broker-dealer with additional compensation. This creates a conflict of interest as it can
generate additional compensation for the broker-dealer. This conflict is mitigated by disclosures
and IFGA’s fiduciary obligation to place the best interest of the Client first. Moreover, IFGA has a
fiduciary duty to recommend the best, and often lowest cost share class to their Clients, and
IFGA’s policy prohibits our IARs from purchasing funds with 12b-1 fees in Client Wrap Program
accounts. Further, when Clients transfer holdings that include funds with 12b-1 fees into
accounts under management by IFGA, IARs will find suitable replacement funds for the client
to exchange into.
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Additional Compensation
IFGA nor its employees receive compensation, other than the portfolio management fee, for the
recommendation to the Client or the Client’s participation in the Program.
Item 5: Account Requirements and Types of Clients
There is no minimum account balance to be a client, but some accounts require minimums to
open, depending on the platform. The client will be made aware of these minimums before
opening an account.
Types of clients we typically manage wrap fee accounts on behalf of, include:
•
Individuals and High Net Worth Individuals;
• Trusts, Estates or Charitable Organizations;
• Pension and Profit-Sharing Plans; and
• Corporations, Limited Liability Companies and/or Other Business Types.
Item 6: Portfolio Manager Selection and Evaluation
Portfolio Manager Selection and Evaluation
IFGA is the sole Portfolio Manager and Advisor for the Program. IFGA develops each portfolio
strategy around each Client’s unique financial goals. The portfolio development process
includes:
• Determining the timing targets of the clients goals;
• Analyzing the individual risk/return comfort level;
• Developing specific investment strategies using a variety of investment methods
(shown below) to match the clients total situation;
• Monitoring the investments mix in an ongoing manner; and
• Providing ongoing meaningful communication between the advisor and the Client,
assuring the investment plan is in concert with the total financial and family situations
as they are now and as they evolve.
The following industry standards may be used to evaluate the Portfolio Manager’s performance
in security selection:
• Alpha (how an investment’s return compares with the returns of its peer group); the
investment’s 3-year alpha should show no difference or a positive difference between its
total return and the return of its peer group.
• Sharpe Ratio (evaluates a Mutual Fund’s or Exchange Traded Fund’s risk-adjusted
performance); The Sharpe Ratio is calculated by taking the excess return of a portfolio,
relative to the risk-free rate, and dividing it by the Standard Deviation of the portfolio’s
excess returns (Standard Deviation is a statistical measure of volatility over a period of
time). The higher a portfolio’s Sharpe Ratio, the better its risk-adjusted performance.
There is a natural potential conflict of interest with the Portfolio Manager conducting the
ongoing review of the standards by which the Portfolio Manager’s selection and management
have been acceptable. IFGA uses, when available, objective measures from well-known
investment data providers, which are not subject to manipulation, to help mitigate this potential
conflict.
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Related Persons as Program Managers
IFGA is the only Portfolio Manager for the Program. We do not offer access to additional Portfolio
Managers but offer one fee to our clients in order to eliminate concerns regarding variable
transaction costs. To the extent that we receive the Program Fee as a result of recommending
itself, we are in a conflict of interest with our clients.
Additional Program Information
IFGA and its investment adviser representatives ("IARs") offer a variety of discretionary and non-
discretionary investment advisory services on a wrap and non-wrap fee basis. This Brochure
describes the advisory programs and advisory services offered by the IFGA on a wrap fee basis.
For more information on IFGA’s non-wrap fee program services, please see IFGA’s Form ADV 2A.
Client-Tailored Services and Client-Imposed Restrictions
The goals and objectives for each Client are documented in our Client files. Investment
strategies are created that reflect the stated goals and objectives. Clients may impose
restrictions on investing in certain securities or types of securities. These restrictions may,
however, prohibit engagement with IFGA.
Wrap Fee Programs Management vs Non-Wrap Account Management
IFGA offers Asset Management services through the IFGA Wrap Fee Program. IFGA is both
sponsor and portfolio manager of the program. In a Wrap Fee account, clients are charged a
single bundled fee as a percentage of the assets managed in the wrap fee program that can
include advisory fees and transaction fees related to the wrap fee program.
There is no significant difference between how the Firm manages wrap fee accounts versus
non-wrap fee accounts. However, as stated above, if a client determines to engage IFGA on a
wrap fee basis the client will pay a single fee for investment management and transaction fees.
The services included in a wrap fee agreement will depend upon each client’s particular need.
When managing a client’s account on a wrap fee basis, IFGA shall receive, as payment for its
investment advisory services, the balance of the wrap fee after all other costs incorporated into
the wrap fee have been deducted. Since transaction fees in a wrap fee account are paid by IFGA,
a conflict of interest exists as IFGA has the Firm has a disincentive to trade securities in the client
account.
Please see our Firm Brochure for more information in the following areas: Item 4 – Advisory
Business, Item 6 – Performance Based-Fees and Side-by-Side Management, Item 8 –
Methods of Analysis, Investment Strategies and Risk of Loss, and Item 17 – Voting Client
Securities.
Item 7: Client Information Provided to Portfolio Managers
IFGA is the sole Portfolio Manager of the Program and collects and shares nonpublic
information (such as financial information, investment objectives, and risk tolerance) about
clients to aid in providing appropriate and suitable investment advice. Nonpublic personal
information about clients will be shared consistent with the disclosures made in IFGA’s Privacy
Policy.
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IFG Advisory, LLC
Wrap Fee Program Brochure
March 2026
Item 8: Client Contact with Portfolio Managers
Clients are always free to directly contact their Financial Advisors with any questions or
concerns they have about their portfolios or other matters.
Item 9: Additional Information
Disciplinary Information
IFGA and its management have not been involved in any criminal or civil actions, administrative
or self-regulatory enforcement proceedings, nor any legal or disciplinary events that are
material to a client’s or prospective client’s evaluation of IFGA or the integrity of its management.
Once the relevant accounts are under our management, we review such accounts on a
regular basis and at least annually. We may periodically rebalance or adjust client accounts
under our management.
Please see our Firm Brochure for more information in the following areas: Item 10 - Other
Financial Industry Activities and Affiliations, Item 11 - Code of Ethics, Item 13 - Review of
Accounts, Item 14 – Client Referrals and Other Compensation, and Item 18 - Financial
Information.
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