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IFS Group
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of IFS Group. If you have any
questions about the contents of this brochure, please contact us at (717) 766-1144 or by email at: joe@ifsgroup1.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 IFS Group is also available on the SEC’s website at www.adviserinfo.sec.gov. IFS
Group’s CRD number is: 328774.
1205 Manor Drive Ste 200
Mechanicsburg, PA 17055
(717) 766-1144
joe@ifsgroup1.com
https://www.ifsgroup1.com
Registration as an investment adviser does not imply a certain level of skill or training.
Version Date: 02/23/2026
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Item 2: Material Changes
The material changes in this brochure will be updated annually or when material changes occur since
the previous release of the Firm Brochure. The last filing of this brochure was on 01/29/2025. Material
changes relate to IFS Group policies, practices, or conflicts of interests only.
•
•
IFS Group has removed Kevin M Doyle. (Item 5 and 10)
IFS Group has updated its Assets Under Management. (Item 4.E)
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Item 3: Table of Contents
Item 1: Cover Page
Item 2: Material Changes ....................................................................................................................................... ii
Item 3: Table of Contents ...................................................................................................................................... iii
Item 4: Advisory Business ......................................................................................................................................2
Item 5: Fees and Compensation .............................................................................................................................9
Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................13
Item 7: Types of Clients ........................................................................................................................................13
Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .............................................................13
Item 9: Disciplinary Information .........................................................................................................................18
Item 10: Other Financial Industry Activities and Affiliations .........................................................................19
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............20
Item 12: Brokerage Practices ................................................................................................................................21
Item 13: Review of Accounts ................................................................................................................................23
Item 14: Client Referrals and Other Compensation ..........................................................................................24
Item 15: Custody ....................................................................................................................................................25
Item 16: Investment Discretion ............................................................................................................................25
Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................25
Item 18: Financial Information .............................................................................................................................26
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Item 4: Advisory Busines
A. Description of the Advisory Firm
IFS Group (hereinafter “IFS LLC”) is a Limited Liability Company organized in the State
of Pennsylvania. The firm was formed in February 2002, and the principal owner is Joseph
Eugene Krichten.
B. Types of Advisory Services
Portfolio Management Services
IFS LLC offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. IFS LLC creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a
portfolio that matches each client's specific situation. Portfolio management services
include, but are not limited to, the following:
•
•
•
Investment strategy •
•
Asset allocation
•
Risk tolerance
Personal investment policy
Asset selection
Regular portfolio monitoring
IFS LLC evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. IFS LLC will request discretionary authority from clients in order
to select securities and execute transactions without permission from the client prior to
each transaction. Risk tolerance levels are documented in the Investment Policy
Statement, which is given to each client.
IFS LLC seeks to provide that investment decisions are made in accordance with the
fiduciary duties owed to its accounts and without consideration of IFS LLC’s economic,
investment or other financial interests. To meet its fiduciary obligations, IFS LLC attempts
to avoid, among other things, investment or trading practices that systematically
advantage or disadvantage certain client portfolios, and accordingly, IFS LLC’s policy is
to seek fair and equitable allocation of investment opportunities/transactions among its
clients to avoid favoring one client over another over time. It is IFS LLC’s policy to allocate
investment opportunities and transactions it identifies as being appropriate and prudent,
including initial public offerings ("IPOs") and other investment opportunities that might
have a limited supply, among its clients on a fair and equitable basis over time.
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LPL Financial Sponsored Advisory Programs
IFS LLC may provide advisory services through certain programs sponsored by LPL
Financial LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief
description of each LPL advisory program available to IFS LLC. For more information
regarding the LPL programs, including more information on the advisory services and
fees that apply, the types of investments available in the programs and the potential
conflicts of interest presented by the programs please see the program account packet
(which includes the account agreement and LPL Form ADV program brochure) and the
Form ADV, Part 2A of LPL or the applicable program.
Advisory Services
Strategic Wealth Management Platform II (SWM II)
SWM and SWM II offer clients an asset management account that allows the IAR to direct
and manage specified client assets. The difference between SWM and SWM II is the type
of fee charged. On the SWM platform clients pay an asset-based management fee and
separate transaction costs. On the SWM II platform, clients pay a single wrap fee for
advisory services and execution of transactions. IFS LLC Financial employs a Portfolio
Analyst who is responsible for the review, analysis and due diligence of various
investment vehicles. The Portfolio Analyst presents information on these investment
vehicles to the IFS LLC Financial’ Investment Committee. The Investment Committee has
created different models to be used by the IARs depending on the client’s investment
objective. The Investment Committee meets monthly, or more frequently as needed, to
review the models and determine what, if any, changes may be needed based on market
conditions, performance, etc. The IARs can choose to use these models within the SWM
and SWM II platform; however, they still have the flexibility to deviate from the model to
suit the individual client’s needs.
Manager Access Select Program
Manager Access Select offers clients the ability to participate in the Separately Managed
Account Platform (the “SMA Platform”) or the Model Portfolio Platform (the “MP
Platform”). In the SMA Platform, IFS LLC will assist client in identifying a third-party
portfolio manager (SMA Portfolio Manager) from a list of SMA Portfolio Managers made
available by LPL, and the SMA Portfolio Manager manages client’s assets on a
discretionary basis. IFS LLC will provide initial and ongoing assistance regarding the
SMA Portfolio Manager selection process. In the MP Platform, clients authorize LPL to
direct the investment and reinvestment of the assets in their accounts, in accordance with
the selected model portfolio provided by LPL’s Research Department or a third-party
investment advisor.
A minimum account value of $50,000 is required for Manager Access Select, however, in
certain instances, the minimum account size may be lower or higher.
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Optimum Market Portfolios Program (OMP)
OMP offers clients the ability to participate in a professionally managed asset allocation
program using Optimum Funds shares. Under OMP, client will authorize LPL on a
discretionary basis to purchase and sell Optimum Funds pursuant to investment
objectives chosen by the client. IFS LLC will assist the client in determining the suitability
of OMP for the client and assist the client in setting an appropriate investment objective.
IFS LLC will have discretion to select a mutual fund asset allocation portfolio designed by
LPL consistent with the client’s investment objective. LPL will have discretion to
purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL
will also have authority to rebalance the account.
A minimum account value of $1,000 is required for OMP. In certain instances, LPL will
permit a lower minimum account size.
Model Wealth Portfolios Program (MWP)
MWP offers clients a professionally managed mutual fund asset allocation program. IFS
LLC will obtain the necessary financial data from the client, assist the client in determining
the suitability of the MWP program and assist the client in setting an appropriate
investment objective. IFS LLC will initiate the steps necessary to open an MWP account
and have discretion to select a model portfolio designed by LPL’s Research Department
consistent with the client’s stated investment objective. LPL’s Research Department, a
third-party portfolio strategist and/or Advisor, through its IAR, may act as a portfolio
strategist responsible for selecting the mutual funds or ETFs within a model portfolio and
for making changes to the mutual funds or ETFs selected.
The client will authorize LPL to act on a discretionary basis to purchase and sell mutual
funds and ETFs and to liquidate previously purchased securities. The client will also
authorize LPL to effect rebalancing for MWP accounts.
MWP requires a minimum asset value for a program account to be managed. The
minimums vary depending on the portfolio(s) selected and the account’s allocation
amongst portfolios. The lowest minimum for a portfolio is $10,000. In certain instances, a
lower minimum for a portfolio is permitted.
Small Market Solution (SMS) Program
Under SMS, LPL Research (a team of investment professionals within LPL) creates and
maintains a series of different investment menus (“Investment Menus”) consisting of a
mix of different asset classes and investment vehicles (“investment options”) for clients
that sponsor and maintain participant-directed defined contribution plans (“Plan
Sponsors”). The Plan Sponsor is responsible for selecting the Investment Menu that it
believes is appropriate based on the demographics and other characteristics of the Plan
and its participants. LPL Research is responsible for the selection and monitoring of the
investment options made available through Investment Menus. The investment options
that are offered through SMS are limited to the specific investments available through the
record keeper that the Plan Sponsor selects. The Plan Sponsor may only select an
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Investment Menu in its entirety and does not have the option to remove or substitute an
investment option.
In addition to the services described above, Plan Sponsor may also select from a number
of consulting services available under SMS that are provided by IFS LLC. These consulting
services may include, but are not limited to: general education, and support regarding the
Plan and the investment options selected by Plan Sponsor; assistance regarding the
selection of, and ongoing relationship management for, record keepers and other third-
party vendors; Plan participant enrollment support; and participant-level education
regarding investment in the Plan. These consulting services do not include any
individualized investment advice to the Plan Sponsor or Plan participants with respect to
Plan assets.
Guided Wealth Portfolios (GWP)
GWP offers clients the ability to participate in a centrally managed, algorithm-based
investment program, which is made available to users and clients through a web-based,
interactive account management portal (“Investor Portal”). Investment recommendations
to buy and sell exchange-traded funds and open-end mutual funds are generated through
proprietary, automated, computer algorithms (collectively, the “Algorithm”) of
FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL
and selected for the account as described below (such model portfolio selected for the
account, the “Model Portfolio”). Communications concerning GWP are intended to occur
primarily through electronic means (including but not limited to, through email
communications or through the Investor Portal), although IFS LLC will be available to
discuss investment strategies, objectives or the account in general in person or via
telephone.
A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-
five (45) days to help users determine whether they would like to become advisory clients
and receive ongoing financial advice from LPL, FutureAdvisor and IFS LLC by enrolling
in the advisory service (the “Managed Service”). The Educational Tool and Managed
Service are described in more detailin the GWP Program Brochure. Users of the
Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or IFS
LLC, do not enter into an advisory agreement with LPL, FutureAdvisor or IFS LLC, do
not receive ongoing investment advice or supervisions of their assets, and do not receive
any trading services.
A minimum account value of $5,000 is required to enroll in the Managed Service.
Investment adviser representatives of IFS LLC are also associated with LPL Financial as
broker-dealer registered representatives (“Dually Registered Persons”). In their capacity
as registered representatives of LPL Financial, certain Dually Registered Persons may earn
commissions for the sale of securities or investment products that they recommend for
brokerage clients. They do not earn commissions on the sale of securities or investment
products recommended or purchased in advisory accounts through IFS LLC. Clients have
the option of purchasing many of the securities and investment products we make
available to you through another broker-dealer or investment adviser. However, when
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purchasing these securities and investment products away from IFS LLC, you will not
receive the benefit of the advice and other services we provide.
Pension Consulting Services
IFS LLC offers consulting services to pension or other employee benefit plans (including
but not limited to 401(k) plans). Pension consulting may include, but is not limited to:
identifying investment objectives and restrictions
o
o providing guidance on various assets classes and investment options
o recommending money managers to manage plan assets in ways designed to
achieve objectives
o monitoring performance of money managers and investment options and making
recommendations for changes
o recommending other service providers, such as custodians, administrators and
broker-dealers
o creating a written pension consulting plan
These services are based on the goals, objectives, demographics, time horizon, and/or risk
tolerance of the plan and its participants.
Financial Planning
Financial plans and financial planning may include, but are not limited to: investment
planning; life insurance; tax concerns; retirement planning; college planning; and
debt/credit planning.
Services Limited to Specific Types of Investments
in
the gold and precious metal sectors),
treasury
IFS LLC generally limits its investment advice to mutual funds, fixed income securities,
real estate funds (including REITs), insurance products including annuities, equities, ETFs
(including ETFs
inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements. IFS LLC may use other securities as well to help diversify a
portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the
Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money
creates some conflicts with your interests, so we operate under a special rule that
requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule’s provisions, we must:
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• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations
(give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in
your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
IFS LLC will tailor a program for each individual client. This will include an interview
session to get to know the client’s specific needs and requirements as well as a plan that
will be executed by IFS LLC on behalf of the client. IFS LLC will take into consideration:
Income needs, Tax ramification, and Time Horizon for the client funds. IFS LLC may use
model allocations together with a specific set of recommendations for each client based
on their personal restrictions, needs, and targets. Clients may impose restrictions in
investing in certain securities or types of securities in accordance with their values or
beliefs. However, if the restrictions prevent IFS LLC from properly servicing the client
account, or if the restrictions would require IFS LLC to deviate from its standard suite of
services, IFS LLC reserves the right to end the relationship.
D. Wrap Fee Programs
Although clients do not pay a transaction charge for transactions in a SWM II account,
clients should be aware that IFS LLC pays LPL transaction charges for those transactions.
The transaction charges paid by IFS LLC vary based on the type of transaction (e.g.,
mutual fund, equity or ETF) and for mutual funds based on whether or not the mutual
fund pays 12b-1 fees and/or recordkeeping fees to LPL. Transaction charges paid by the
Advisor for equities and ETFs are $9. For mutual funds, the transaction charges range
from $0 to $26.50. Because IFS LLC pays the transaction charges in SWM II accounts, there
is a conflict of interest in cases where the mutual fund is offered at both $0 and $26.50.
Clients should understand that the cost to Advisor of transaction charges may be a factor
that IFS LLC considers when deciding which securities to select and how frequently to
account.
place
transactions
in
a
SWM
II
In many instances, LPL makes available mutual funds in a SWM II account that offer
various classes of shares, including shares designated as Class A Shares and shares
designed for advisory programs, which can be titled, for example, as “Class I,”
“institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share
classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund
in SWM II in many cases will not be the least expensive share class that the mutual fund
makes available, and was selected by LPL in certain cases because the share class pays
LPL compensation for the administrative and recordkeeping services LPL provides to the
mutual fund. Client should understand that another financial services firm may offer the
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same mutual fund at a lower overall cost to the investor than is available through SWM
II. In other instances, a mutual fund may offer only Class A Shares, but another similar
mutual fund may be available that offers Platform Shares. Class A Shares typically pay
LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses
(“brokerage-related services”) to the mutual funds. Platform Shares generally are not
subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes,
it is generally more expensive for a client to own Class A Shares than Platform Shares. An
investor in Platform Shares will pay lower fees over time, and keep more of his or her
investment returns than an investor who holds Class A Shares of the same fund.
in
the
IFS LLC has a financial incentive to recommend Class A Shares in cases where both Class
A and Platform Shares are available. This is a conflict of interest which might incline IFS
LLC, consciously or unconsciously, to render advice that is not disinterested. Although
the client will not be charged a transaction charge for transactions, Advisor pays LPL a
per transaction charge for mutual fund purchases and sales in the account. IFS LLC
generally does not pay transaction charges for Class A Share mutual fund transactions
accounts, but generally does pay transaction charges for Platform Share mutual fund
transactions. The cost to IFS LLC of transaction charges generally may be a factor Advisor
considers when deciding which securities to select and whether or not to place
account.
transactions
The lack of transaction charges to IFS LLC for Class A Share purchases and sales, together
with the fact that Platform Shares generally are less expensive for a client to own, presents
a significant conflict of interest between IFS LLC and the client. In short, it costs IFS LLC
less to recommend and select Class A share mutual funds than Platform shares, but
Platform shares will generally outperform Class A mutual fund shares on the basis of
internal cost structure alone. Clients should understand this conflict and consider the
additional indirect expenses borne as a result of the mutual fund fees when negotiating
and discussing with your Advisor the advisory fee for management of an account.
E. Assets Under Management
IFS LLC has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$ 30,000,000.00
$ 210,000,000.00
December 2025
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Item 5: Fees and Compensation
A. Fee Schedule
Portfolio Management Fees
Total Assets Under Management Annual Fees
$100,000 - $500,000
1.50%
$500,001 - $1,000,000
1.25%
$1,000,001 - $3,000,000
1.00%
$3,000,001 - $5,000,000
0.90%
$5,000,001 - AND UP
0.80%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of IFS LLC's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Investment Advisory Contract
immediately upon written notice.
LPL Financial Sponsored Advisory Programs
The account fee charged to the client for each LPL advisory program is negotiable,
subject to the following maximum account fees:
Manager Access Select
3.0%*
OMP
2.5%
MWP
2.65%**
SMS
0.95%***
GWP
1.35%****
* The maximum Manager Access Select account fee for new accounts was reduced to
2.5% effective July 3, 2017.
** The MWP account fee consists of an LPL program fee, a strategist fee (if applicable) and
an advisor fee of up to 2.00%. Accounts remaining under the legacy fee structure may be
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charged one aggregate account fee, for which the maximum account fee is 2.50%. See the
MWP program brochure for more information.
** The SMS fee consists of an LPL program fee of 0.20% (subject to a minimum program
fee of $250), and an advisor fee of up to 0.75%.
*** GWP Managed Service clients are charged an account fee consisting of an LPL program
fee of 0.35% and an advisor fee of up to 1.00%. In the future, a strategist fee may apply.
However, LPL Research currently serves as the sole portfolio strategist and does not
charge a fee for its services. FutureAdvisor is compensated directly by LPL for its services,
including the Algorithm and related software, through an annual sub-advisory fee (tiered
based on assets under management by FutureAdvisor, at a rate ranging from 0.10% to
0.17%). As each asset tier is reached, LPL’s share of the compensation shall increase and
clients will not benefit from such asset tiers.
GWP Educational Tool provides access to sample recommendations at no charge to users.
However, if users decide to implement sample recommendations by executing trades,
they will be charged fees, commissions, or expenses by the applicable broker or adviser,
as well as underlying investment fees and expenses.
Account fees are payable quarterly in advance, except that the SMS fee is paid in arrears
on the frequency agreed to between client and IFS LLC.
Excluding SMS and GWP, LPL serves as program sponsor, investment advisor and
broker-dealer for the LPL advisory programs. In the Managed Service of GWP, LPL is
appointed by each client as custodian of account assets and broker-dealer with respect to
processing securities transactions for the accounts. In general, FutureAdvisor, in its
capacity as investment advisor, will submit transactions through LPL; however,
FutureAdvisor may choose to execute transactions through a broker-dealer other than
LPL, subject to its duty to seek to achieve best execution. When securities transactions are
effected through LPL, there are no brokerage commissions charged to the account. If
FutureAdvisor chooses to execute a transaction through a broker-dealer other than LPL,
the execution price may include a commission or fee imposed by the executing broker-
dealer. In evaluating whether to execute a trade through a broker-dealer other than LPL,
Future Advisor will consider the fact that the account will not be charged a commission if
the transaction is effected through LPL.
IFS LLC and LPL may share in the account fee and other fees associated with program
accounts. Associated persons of IFS LLC may also be registered representatives of LPL.
Under SMS, LPL serves as investment advisor but not the broker-dealer. IFS LLC and
LPL may share in the advisory portion of the SMS fee.
Pension Consulting Fees
Total Assets Under Management Annual Fees
$100,000 - $500,000
1.50%
$500,001 - $1,000,000
1.25%
10
Total Assets Under Management Annual Fees
$1,000,001 - $3,000,000
1.00%
$3,000,001 - $5,000,000
0.90%
$5,000,001 - AND UP
0.80%
The advisory fee is calculated using the value of the assets in the Account on the last
business day of the prior billing period.
These fees are generally negotiable and the final fee schedule will be memorialized in the
client’s advisory agreement. Clients may terminate the agreement without penalty for a
full refund of IFS LLC's fees within five business days of signing the Investment Advisory
Contract. Thereafter, clients may terminate the Pension Consulting Agreement
immediately upon written notice.
Financial Planning Fees
Hourly Fees
The hourly fee for these services is between $175 and $250.
Clients may terminate the agreement without penalty, for full refund of IFS LLC’s fees,
within five business days of signing the Financial Planning Agreement. Thereafter, clients
may terminate the Financial Planning Agreement generally upon written notice.
B. Payment of Fees
Payment of Portfolio Management Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis. Fees are paid in advance.
Payment of LPL Financial Sponsored Advisory Program Fees
Account fees are payable quarterly in advance. Fees are collected by LPL, then IFS LLC’s
portion is sent to IFS LLC.
Payment of Pension Consulting Fees
Asset-based portfolio management fees are withdrawn directly from the client's accounts
with client's written authorization on a quarterly basis. Fees are paid in advance.
Payment of Financial Planning Fees
Financial planning fees are paid via check.
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Hourly financial planning fees are paid in arrears upon completion.
C. Client Responsibility For Third Party Fees
Clients are responsible for the payment of all third-party fees (i.e. custodian fees,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and
distinct from the fees and expenses charged by IFS LLC. Please see Item 12 of this brochure
regarding broker-dealer/custodian.
D. Prepayment of Fees
IFS LLC collects fees in advance. Refunds for fees paid in advance but not yet earned will
be refunded on a prorated basis and returned within fourteen days to the client via check,
or return deposit back into the client’s account.
For all asset-based fees paid in advance, the fee refunded will be equal to the balance of
the fees collected in advance minus the daily rate* times the number of days elapsed in
the billing period up to and including the day of termination. (*The daily rate is calculated
by dividing the annual asset-based fee rate by 365.)
E. Outside Compensation For the Sale of Securities to Clients
Joseph E. Krichten, Martin E. Leonard, Brent R. Guthrie, Joseph A. Perretta, Kenneth W.
Fry and Andrew K. Fry are insurance agents and registered representatives. In these roles,
they accept compensation for the sale of insurance and securities products to IFS LLC
clients.
1. This is a Conflict of Interest
Supervised persons may accept compensation for the sale of investment products,
including asset-based sales charges or service fees from the sale of mutual funds to IFS
LLC's clients. This presents a conflict of interest and gives the supervised person an
incentive to recommend products based on the compensation received rather than on
the client’s needs. When recommending the sale of insurance and securities products
for which the supervised persons receives compensation, IFS LLC will document the
conflict of interest in the client file and inform the client of the conflict of interest.
2. Clients Have the Option to Purchase Recommended Products From
Other Brokers
Clients always have the option to purchase IFS LLC recommended products through
other brokers or agents that are not affiliated with IFS LLC.
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3. Commissions are not IFS LLC's primary source of compensation for
advisory services
Commissions are not IFS LLC’s primary source of compensation for advisory services.
4. Advisory Fees in Addition to Commissions or Markups
Advisory fees that are charged to clients are not reduced to offset the commissions or
markups on insurance and securities products recommended to clients.
Item 6: Performance-Based Fees and Side-By-Side Management
IFS LLC does not accept performance-based fees or other fees based on a share of capital gains
on or capital appreciation of the assets of a client.
Item 7: Types of Clients
IFS LLC generally provides advisory services to the following types of clients:
❖
❖
❖
❖
Individuals
High-Net-Worth Individuals
Corporations or Business Entities
Government/Municipal
There is an account minimum of $100,000, which may be waived by IFS LLC in its discretion.
Item 8: Methods of Analysis, Investment Strategies, & Risk of
Loss
A. Methods of Analysis and Investment Strategies
Methods of Analysis
IFS LLC’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental
analysis, Modern portfolio theory, Quantitative analysis and Technical analysis.
Charting analysis involves the use of patterns in performance charts. IFS LLC uses this
technique to search for patterns used to help predict favorable conditions for buying
and/or selling a security.
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Cyclical analysis involves the analysis of business cycles to find favorable conditions for
buying and/or selling a security.
Fundamental analysis involves the analysis of financial statements, the general financial
health of companies, and/or the analysis of management or competitive advantages.
Modern portfolio theory is a theory of investment that attempts to maximize portfolio
expected return for a given amount of portfolio risk, or equivalently minimize risk for a
given level of expected return, each by carefully choosing the proportions of various asset.
Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such
as the value of assets, the cost of capital, historical projections of sales, and so on.
Technical analysis involves the analysis of past market data; primarily price and volume.
Investment Strategies
IFS LLC uses long term trading, margin transactions and options trading (including
covered options, uncovered options, or spreading strategies).
IFS LLC always consider tax ramifications of investment actions and strategies. We look
to ensure that investment strategies can easily be changed if warranted for retirement
income or Special Planning needs.
Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
B. Material Risks Involved
Methods of Analysis
Charting Analysis strategy involves using and comparing various charts to predict long
and short-term performance or market trends. The risk involved in using this method is
that only past performance data is considered without using other methods to crosscheck
data. Using charting analysis without other methods of analysis would be making the
assumption that past performance will be indicative of future performance. This may not
be the case.
Cyclical Analysis assumes that the markets react in cyclical patterns which, once
identified, can be leveraged to provide performance. The risks with this strategy are two-
fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors
begin to implement this strategy, then it changes the very cycles these investors are trying
to exploit.
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Fundamental Analysis concentrates on factors that determine a company’s value and
expected future earnings. This strategy would normally encourage equity purchases in
stocks that are undervalued or priced below their perceived value. The risk assumed is
that the market will fail to reach expectations of perceived value.
Modern Portfolio Theory assumes that investors are risk averse, meaning that given two
portfolios that offer the same expected return, investors will prefer the less risky one.
Thus, an investor will take on increased risk only if compensated by higher expected
returns. Conversely, an investor who wants higher expected returns must accept more
risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The
implication is that a rational investor will not invest in a portfolio if a second portfolio
exists with a more favorable risk-expected return profile – i.e., if for that level of risk an
alternative portfolio exists which has better expected returns.
Quantitative Analysis Investment strategies using quantitative models may perform
differently than expected as a result of, among other things, the factors used in the models,
the weight placed on each factor, changes from the factors’ historical trends, and technical
issues in the construction and implementation of the models.
Technical Analysis attempts to predict a future stock price or direction based on market
trends. The assumption is that the market follows discernible patterns and if these
patterns can be identified then a prediction can be made. The risk is that markets do not
always follow patterns and relying solely on this method may not take into account new
patterns that emerge over time.
Investment Strategies
IFS LLC's use of margin transactions and options trading generally holds greater risk, and
clients should be aware that there is a material risk of loss using any of those strategies.
Long Term Trading is designed to capture market rates of both return and risk. Due to its
nature, the long-term investment strategy can expose clients to various types of risk that
will typically surface at various intervals during the time the client owns the investments.
These risks include but are not limited to inflation (purchasing power) risk, interest rate
risk, economic risk, market risk, and political/regulatory risk.
Margin Transactions use leverage that is borrowed from a brokerage firm as collateral.
When losses occur, the value of the margin account may fall below the brokerage firm’s
threshold thereby triggering a margin call. This may force the account holder to either
allocate more funds to the account or sell assets on a shorter time frame than desired.
Options Transactions involve a contract to purchase a security at a given price, not
necessarily at market value, depending on the market. This strategy includes the risk that
an option may expire out of the money resulting in minimal or no value, as well as the
possibility of leveraged loss of trading capital due to the leveraged nature of stock options.
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Investing in securities involves a risk of loss that you, as a client, should be prepared
to bear.
C. Risks of Specific Securities Utilized
IFS LLC's use of margin transactions and options trading generally holds greater risk of
capital loss. Clients should be aware that there is a material risk of loss using any
investment strategy. The investment types listed below (leaving aside Treasury Inflation
Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other
government agency.
Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may
lose money investing in mutual funds. All mutual funds have costs that lower investment
returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity”
nature.
Equity investment generally refers to buying shares of stocks in return for receiving a
future payment of dividends and/or capital gains if the value of the stock increases. The
value of equity securities may fluctuate in response to specific situations for each
company, industry conditions and the general economic environments.
Fixed income investments generally pay a return on a fixed schedule, though the amount
of the payments can vary. This type of investment can include corporate and government
debt securities, leveraged loans, high yield, and investment grade debt and structured
products, such as mortgage and other asset-backed securities, although individual bonds
may be the best-known type of fixed income security. In general, the fixed income market
is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond
prices usually fall, and vice versa. This effect is usually more pronounced for longer-term
securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and
credit and default risks for both issuers and counterparties. The risk of default on treasury
inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting
(extremely unlikely); however, they carry a potential risk of losing share price value, albeit
rather minimal. Risks of investing in foreign fixed income securities also include the
general risk of non-U.S. investing described below.
Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges,
similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100%
loss in the case of a stock holding bankruptcy). Areas of concern include the lack of
transparency in products and increasing complexity, conflicts of interest and the
possibility of inadequate regulatory compliance. Risks in investing in ETFs include
trading risks, liquidity and shutdown risks, risks associated with a change in authorized
participants and non-participation of authorized participants, risks that trading price
differs from indicative net asset value (iNAV), or price fluctuation and disassociation from
the index being tracked. With regard to trading risks, regular trading adds cost to your
portfolio thus counteracting the low fees that one of the typical benefits of ETFs.
Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even
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paid fund managers struggle to do this every year, with the majority failing to beat the
relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same
level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading
conditions are more accurately reflected in implied liquidity rather than the average daily
volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded
in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks
of their underlying securities, which may include the risks associated with investing in
smaller companies, foreign securities, commodities, and fixed income investments (as
applicable). Foreign securities in particular are subject to interest rate, currency exchange
rate, economic, and political risks, all of which are magnified in emerging markets. ETFs
that target a small universe of securities, such as a specific region or market sector, are
generally subject to greater market volatility, as well as to the specific risks associated with
that sector, region, or other focus. ETFs that use derivatives, leverage, or complex
investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold,
Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically
may be negatively impacted by several unique factors, among them (1) large sales by the
official sector which own a significant portion of aggregate world holdings in gold and
other precious metals, (2) a significant increase in hedging activities by producers of gold
or other precious metals, (3) a significant change in the attitude of speculators and
investors. The return of an index ETF is usually different from that of the index it tracks
because of fees, expenses, and tracking error. An ETF may trade at a premium or discount
to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The
degree of liquidity can vary significantly from one ETF to another and losses may be
magnified if no liquid market exists for the ETF’s shares when attempting to sell them.
Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar
material, which should be considered carefully when making investment decisions.
Real Estate funds (including REITs) face several kinds of risk that are inherent in the real
estate sector, which historically has experienced significant fluctuations and cycles in
performance. Revenues and cash flows may be adversely affected by: changes in local real
estate market conditions due to changes in national or local economic conditions or
changes in local property market characteristics; competition from other properties
offering the same or similar services; changes in interest rates and in the state of the debt
and equity credit markets; the ongoing need for capital improvements; changes in real
estate tax rates and other operating expenses; adverse changes in governmental rules and
fiscal policies; adverse changes in zoning laws; the impact of present or future
environmental legislation and compliance with environmental laws.
Annuities are a retirement product for those who may have the ability to pay a premium
now and want to guarantee they receive certain monthly payments or a return on
investment later in the future. Annuities are contracts issued by a life insurance company
designed to meet requirement or other long-term goals. An annuity is not a life insurance
policy. Variable annuities are designed to be long-term investments, to meet retirement
and other long-range goals. Variable annuities are not suitable for meeting short-term
goals because substantial taxes and insurance company charges may apply if you
withdraw your money early. Variable annuities also involve investment risks, just as
mutual funds do.
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Private Placements carry a substantial risk as they are subject to less regulation than are
publicly offered securities, the market to resell these assets under applicable securities
laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial
discount to the underlying value or result in the entire loss of the value of such assets.
Venture Capital Funds invest in start-up companies at an early stage of development in
the interest of generating a return through an eventual realization event; the risk is high
as a result of the uncertainty involved at that stage of development.
Commodities are tangible assets used to manufacture and produce goods or services.
Commodity prices are affected by different risk factors, such as disease, storage capacity,
supply, demand, delivery constraints and weather. Because of those risk factors, even a
well-diversified investment in commodities can be uncertain.
Options are contracts to purchase a security at a given price, risking that an option may
expire out of the money resulting in minimal or no value. An uncovered option is a type
of options contract that is not backed by an offsetting position that would help mitigate
risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss
for an uncovered call option is limitless. Spread option positions entail buying and selling
multiple options on the same underlying security, but with different strike prices or
expiration dates, which helps limit the risk of other option trading strategies. Option
transactions also involve risks including but not limited to economic risk, market risk,
sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk
and interest rate risk.
Non-U.S. securities present certain risks such as currency fluctuation, political and
economic change, social unrest, changes in government regulation, differences in
accounting and the lesser degree of accurate public information available.
Past performance is not indicative of future results. Investing in securities involves a
risk of loss that you, as a client, should be prepared to bear.
Item 9: Disciplinary Information
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
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C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and Affiliations
A. Registration as a Broker/Dealer or Broker/Dealer Representative
Neither IFS LLC nor its representatives are registered as, or have pending applications to
become, a broker/dealer or a representative of a broker/dealer.
As registered representatives of LPL, Joseph E. Krichten, Martin E. Leonard, Brent R.
Guthrie, Joseph A. Perretta, Kenneth W. Fry and Andrew K. Fry accept compensation for
the sale of securities.
B. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
Neither IFS LLC nor its representatives are registered as or have pending applications to
become either a Futures Commission Merchant, Commodity Pool Operator, or
Commodity Trading Advisor or an associated person of the foregoing entities.
C. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Joseph E. Krichten, Martin E. Leonard, Brent R. Guthrie, Joseph A. Perretta, Kenneth W.
Fry and Andrew K. Fry are independent licensed insurance agents. This activity creates a
conflict of interest since there is an incentive to recommend insurance products based on
commissions or other benefits received from the insurance company, rather than on the
client’s needs. Additionally, the offer and sale of insurance products by supervised
persons of IFS LLC are not made in their capacity as a fiduciary, and products are limited
to only those offered by certain insurance providers. IFS LLC addresses this conflict of
interest by requiring its supervised persons to act in the best interest of the client at all
times, including when acting as an insurance agent. IFS LLC periodically reviews
recommendations by its supervised persons to assess whether they are based on an
objective evaluation of each client’s risk profile and investment objectives rather than on
the receipt of any commissions or other benefits. IFS LLC will disclose in advance how it
or its supervised persons are compensated and will disclose conflicts of interest involving
any advice or service provided. At no time will there be tying between business practices
and/or services (a condition where a client or prospective client would be required to
accept one product or service conditioned upon the selection of a second, distinctive tied
product or service). No client is ever under any obligation to purchase any insurance
product. Insurance products recommended by IFS LLC’s supervised persons may also be
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available from other providers on more favorable terms, and clients can purchase
insurance products recommended through other unaffiliated insurance agencies.
Joseph E. Krichten, Martin E. Leonard, Brent R. Guthrie, Joseph A. Perretta, Kenneth W.
Fry and Andrew K. Fry are registered representatives of LPL. From time to time, they will
offer clients advice or products from those activities. Clients should be aware that these
services pay a commission or other compensation and involve a conflict of interest, as
commissionable products conflict with the fiduciary duties of a registered investment
adviser. IFS LLC always acts in the best interest of the client, including with respect to the
sale of commissionable products to advisory clients. Clients always have the right to
decide whether or not to utilize the services of any IFS LLC representative in such
individual’s outside capacities.
D. Selection of Other Advisers or Managers and How This Adviser
is Compensated for Those Selections
IFS LLC does not utilize nor select third-party investment advisers.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
IFS LLC has a written Code of Ethics that covers the following areas: Prohibited Purchases
and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions,
Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality,
Service on a Board of Directors, Compliance Procedures, Compliance with Laws and
Regulations, Procedures and Reporting, Certification of Compliance, Reporting
Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual
Review, and Sanctions. IFS LLC's Code of Ethics is available free upon request to any
client or prospective client.
B. Recommendations Involving Material Financial Interests
IFS LLC does not recommend that clients buy or sell any security in which a related person
to IFS LLC or IFS LLC has a material financial interest.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of IFS LLC may buy or sell securities for themselves
that they also recommend to clients. This may provide an opportunity for representatives
of IFS LLC to buy or sell the same securities before or after recommending the same
securities to clients resulting in representatives profiting off the recommendations they
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provide to clients. Such transactions may create a conflict of interest. IFS LLC will always
document any transactions that could be construed as conflicts of interest and will never
engage in trading that operates to the client’s disadvantage when similar securities are
being bought or sold.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of IFS LLC may buy or sell securities for themselves at
or around the same time as clients. This may provide an opportunity for representatives
of IFS LLC to buy or sell securities before or after recommending securities to clients
resulting in representatives profiting off the recommendations they provide to clients.
Such transactions may create a conflict of interest; however, IFS LLC will never engage in
trading that operates to the client’s disadvantage if representatives of IFS LLC buy or sell
securities at or around the same time as clients.
Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Custodians/broker-dealers will be recommended based on IFS LLC’s duty to seek “best
execution,” which is the obligation to seek execution of securities transactions for a client
on the most favorable terms for the client under the circumstances. Clients will not
necessarily pay the lowest commission or commission equivalent, and IFS LLC may also
consider the market expertise and research access provided by the broker-
dealer/custodian, including but not limited to access to written research, oral
communication with analysts, admittance to research conferences and other resources
provided by the brokers that may aid in IFS LLC's research efforts. IFS LLC will never
charge a premium or commission on transactions, beyond the actual cost imposed by the
broker-dealer/custodian.
IFS LLC will require clients to use LPL Financial.
IFS LLC receives support services and/or products from LPL Financial, many of which
assist the IFS LLC to better monitor and service program accounts maintained at LPL
Financial; however, some of the services and products benefit IFS LLC and not client
accounts. These support services and/or products may be received without cost, at a
discount, and/or at a negotiated rate, and may include the following:
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
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computer hardware and/or software
• attendance at conferences, meetings, and other educational and/or social events
• marketing support
•
• other products and services used by IFS LLC in furtherance of its investment advisory
operations
business
LPL Financial may provide these services and products directly, or may arrange for third
party vendors to provide the services or products to Advisor. In the case of third party
vendors, LPL Financial may pay for some or all of the third party’s fees.
These support services are provided to IFS LLC based on the overall relationship between
IFS LLC and LPL Financial. It is not the result of soft dollar arrangements or any other
express arrangements with LPL Financial that involves the execution of client transactions
as a condition to the receipt of services. IFS LLC will continue to receive the services
regardless of the volume of client transactions executed with LPL Financial. Clients do not
pay more for services as a result of this arrangement. There is no corresponding
commitment made by the IFS LLC to LPL or any other entity to invest any specific amount
or percentage of client assets in any specific securities as a result of the arrangement.
However, because Advisor receives these benefits from LPL Financial, there is a potential
conflict of interest. The receipt of these products and services presents a financial incentive
for Advisor to recommend that its clients use LPL Financial’s custodial platform rather
than another custodian’s platform.
1. Research and Other Soft-Dollar Benefits
While IFS LLC has no formal soft dollars program in which soft dollars are used to
pay for third party services, IFS LLC may receive research, products, or other services
from custodians and broker-dealers in connection with client securities transactions
(“soft dollar benefits”). IFS LLC may enter into soft-dollar arrangements consistent
with (and not outside of) the safe harbor contained in Section 28(e) of the Securities
Exchange Act of 1934, as amended. There can be no assurance that any particular client
will benefit from soft dollar research, whether or not the client’s transactions paid for
it, and IFS LLC does not seek to allocate benefits to client accounts proportionate to
any soft dollar credits generated by the accounts. IFS LLC benefits by not having to
produce or pay for the research, products or services, and IFS LLC will have an
incentive to recommend a broker-dealer based on receiving research or services.
Clients should be aware that IFS LLC’s acceptance of soft dollar benefits may result in
higher commissions charged to the client.
2. Brokerage for Client Referrals
IFS LLC receives no referrals from a broker-dealer or third party in exchange for using
that broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
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IFS LLC will require clients to use a specific broker-dealer to execute transactions. Not
all advisers require clients to use a particular broker-dealer.
B. Aggregating (Block) Trading for Multiple Client Accounts
IFS LLC does not aggregate or bunch the securities to be purchased or sold for multiple
clients. This may result in less favorable prices, particularly for illiquid securities or during
volatile market conditions.
Item 13: Review of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
All client accounts for IFS LLC's advisory services provided on an ongoing basis are
reviewed at least quarterly by Joseph Krichten, Managing Member, with regard to clients’
respective investment policies and risk tolerance levels. All accounts at IFS LLC are
assigned to this reviewer.
All financial planning accounts are reviewed upon financial plan creation and plan
delivery by Joseph Krichten, Managing Member. Financial planning clients are provided
a one-time financial plan concerning their financial situation. After the presentation of the
plan, there are no further reports. Clients may request additional plans or reports for a
fee.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
Reviews may be triggered by material market, economic or political events, or by changes
in client's financial situations (such as retirement, termination of employment, physical
move, or inheritance).
With respect to financial plans, IFS LLC’s services will generally conclude upon delivery
of the financial plan.
C. Content and Frequency of Regular Reports Provided to Clients
Each client of IFS LLC's advisory services provided on an ongoing basis will receive a
quarterly report detailing the client’s account, including assets held, asset value, and
calculation of fees. This written report will come from the custodian.
Each financial planning client will receive the financial plan upon completion.
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Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
Other than soft dollar benefits as described in Item 12 above, outside compensation of
investment adviser representatives in Item 5E above, and the below in Item 14 IFS LLC
does not receive any economic benefit, directly or indirectly from any third party for
advice rendered to IFS LLC 's clients.
IFS LLC and/or its Dually Registered Persons are incented to join and remain affiliated
with LPL Financial and to recommend that clients establish accounts with LPL Financial.
LPL also provides other compensation to IFS LLC 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.
LPL Financial makes available to IFS LLC various products and services designed to assist
IFS LLC in managing and administering client accounts. Many of these products and
services may be used to service all or a substantial number of IFS LLC’s accounts,
including accounts not held with LPL Financial. These include software and other
technology that provide access to client account data (such as trade confirmation and
account statements); facilitate trade execution (and aggregation and allocation of trade
orders for multiple client accounts); provide research, pricing information and other
market data; facilitate payment of IFS LLC’s fees from its clients’ accounts; and assist with
back-office functions; recordkeeping and client reporting.
LPL Financial also makes available to IFS LLC other services intended to help IFS LLC
manage and further develop its business. Some of these services assist IFS LLC to better
monitor and service program accounts maintained at LPL Financial, however, many of
these services benefit only IFS LLC, for example, services that assist IFS LLC in growing
its business. These support services and/or products may be provided without cost, at a
discount, and/or at a negotiated rate, and include practice management-related
publications; consulting services; attendance at conferences and seminars, meetings, and
other educational and/or social events; marketing support; and other products and
services used by IFS LLC in furtherance of the operation and development of its
investment advisory business.
Where such services are provided by a third party vendor, LPL Financial will either make
a payment to IFS LLC to cover the cost of such services, reimburse IFS LLC for the cost
associated with the services, or pay the third party vendor directly on behalf of IFS LLC.
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The products and services described above are provided to IFS LLC as part of its overall
relationship with LPL Financial. While as a fiduciary IFS LLC endeavors to act in its
clients’ best interests, the receipt of these benefits creates a conflict of interest because IFS
LLC’s requirement that clients custody their assets at LPL Financial is based in part on the
benefit to IFS LLC 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 Financial.
IFS LLC’s receipt of some of these benefits may be based on the amount of advisory assets
custodied on the LPL Financial platform.
B. Compensation to Non – Advisory Personnel for Client Referrals
IFS LLC may, via written arrangement, retain third parties to act as solicitors for IFS LLC’s
investment management services. All compensation with respect to the foregoing will be
fully disclosed to each client to the extent required by applicable law. IFS LLC will ensure
each solicitor is properly registered in all appropriate jurisdictions. All such referral
activities will be conducted in accordance with Rule 206(4)(1) under the Advisers Act,
where applicable.
Item 15: Custody
When advisory fees are deducted directly from client accounts at client's custodian, IFS LLC will
be deemed to have limited custody of client's assets and must have written authorization from
the client to do so. Clients will receive all account statements and billing invoices that are required
in each jurisdiction, and they should carefully review those statements for accuracy.
Item 16: Investment Discretion
IFS LLC provides discretionary and non-discretionary investment advisory services to clients.
The advisory contract established with each client sets forth the discretionary authority for
trading. Where investment discretion has been granted, IFS LLC generally manages the client’s
account and makes investment decisions without consultation with the client as to when the
securities are to be bought or sold for the account, the total amount of the securities to be
bought/sold, what securities to buy or sell, or the price per share. In some instances, IFS LLC’s
discretionary authority in making these determinations may be limited by conditions imposed
by a client (in investment guidelines or objectives, or client instructions otherwise provided to
IFS LLC.
Item 17: Voting Client Securities (Proxy Voting)
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IFS LLC will not ask for, nor accept voting authority for client securities. Clients will receive
proxies directly from the issuer of the security or the custodian. Clients should direct all proxy
questions to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
IFS LLC neither requires nor solicits prepayment of more than $1,200 in fees per client, six
months or more in advance, and therefore is not required to include a balance sheet with
this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither IFS LLC nor its management has any financial condition that is likely to
reasonably impair IFS LLC’s ability to meet contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
IFS LLC has not been the subject of a bankruptcy petition in the last ten years.
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