Overview
- Average Client Assets
- $4.7 million
- Minimum Account Size
- $500,000
- SEC CRD Number
- 154131
Fee Structure
Primary Fee Schedule (INTEGRITY IA ADV PART 2A & 2B ANNUAL AMENDMENT V.03.25.26)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.25% |
Minimum Annual Fee: $7,000
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $12,500 | 1.25% |
| $5 million | $62,500 | 1.25% |
| $10 million | $125,000 | 1.25% |
| $50 million | $625,000 | 1.25% |
| $100 million | $1,250,000 | 1.25% |
Clients
- HNW Share of Firm Assets
- 92.20%
- Total Client Accounts
- 512
- Discretionary Accounts
- 494
- Non-Discretionary Accounts
- 18
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Primary Brochure: INTEGRITY IA ADV PART 2A & 2B ANNUAL AMENDMENT V.03.25.26 (2026-04-02)
View Document Text
Item 1 – Cover Page
3275 Twin Heron Ct.
Fort Collins, CO 80528
(303)549-4720
www.IntegrityIA.com
March 25, 2026
This Brochure provides information about the qualifications and business practices of Integrity
Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please
contact us at 303-549-4720 or Invest@IntegrityIA.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.
Integrity Investment Advisors, LLC is an SEC registered investment adviser located in the state
of Colorado. Registration of an Investment Adviser does not imply any level of skill or training.
The oral and written communications of an Adviser provide you with information about which
you determine to hire or retain an Adviser.
Additional information about Integrity Investment Advisors, LLC also is available on the SEC’s
website at www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Annual Update
The Brochure will be updated annually, or when material changes occur since the
previous release of the Firm Brochure. If there are no material changes, Integrity
Investment Adviser will offer to deliver the current Form ADV Part 2 to clients within 120
days of the end of our fiscal year.
Material Changes since the Last Update
Material changes have been made since the Firm’s last annual updating amendment of
March 19, 2025, in Items 4, 5, and 10, pertaining to the use of a sub-adviser for certain
clients’ portfolios and new minimum fee levels for clients receiving both financial planning
and investment management services.
When there are material changes to the information in Integrity Investment Advisors’
Brochure, the Firm will provide clients with an updated Brochure or a summary of the
material changes with an offer of the full Brochure.
Full Brochure Available
Currently, our Brochure may be requested by contacting Todd Moerman, President and
Chief Compliance Officer at (303)549-4720 or Invest@IntegrityIA.com.
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Item 3 -Table of Contents
Item 1 – Cover Page ....................................................................................................................................... i
Item 2 – Material Changes ............................................................................................................................ ii
Item 3 -Table of Contents ............................................................................................................................ iii
Item 4 – Advisory Business ........................................................................................................................... 1
Item 5 – Fees and Compensation ................................................................................................................. 4
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 8
Item 7 – Types of Clients ............................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 9
Item 9 – Disciplinary Information ............................................................................................................... 14
Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 14
Item 11 – Code of Ethics ............................................................................................................................. 16
Item 12 – Brokerage Practices .................................................................................................................... 17
Item 13 – Review of Accounts..................................................................................................................... 18
Item 14 – Client Referrals and Other Compensation .................................................................................. 18
Item 15 – Custody ....................................................................................................................................... 19
Item 16 - Investment Discretion…………………………………………………………………………………………………………….15
Item 17 – Voting Client Securities ............................................................................................................... 20
Item 18 – Financial Information .................................................................................................................. 20
ADV Part 2B Brochure Supplement - Todd J. Moerman.............................................................................21
ADV Part 2B Brochure Supplement - Robert S. Hamilton ......................................................................... 24
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Item 4 – Advisory Business
Integrity Investment Advisors, LLC was founded in 2010 as a Limited Liability Company organized
in the state of Colorado. Integrity Investment Advisors, LLC is an independent investment advisor
registered with the SEC and is majority-owned by Todd Moerman.
Integrity Investment Advisors, LLC, also referred to as the "Company" or “Firm” offers the following
advisory services to individuals, corporations, LLCs, and Trusts.
Integrity Investment Advisors, LLC offers Portfolio Management services by appointment only.
Portfolio Management and Planning Services
For its Core Financial Planning services, depending upon the client’s stated needs, the Firm will
provide ongoing, as-needed advice and recommendations to reach the client’s stated financial
goals. The Firm’s services will include, among others:
Ongoing financial advice on issues of cash management, risk management, education
funding, retirement planning, estate planning and tax planning
Regular updates to client’s financial plan
Meetings, phone calls, and other coordination efforts as requested with the client’s other
Advisors
For the Firm’s Private Wealth Financial Planning services, depending upon client’s needs the Firm
will provide advanced planning strategies for these client’s investments for such investments in
Separately Managed Accounts (“SMA”), private credit, real estate, private equity, hedge funds, and
other alternative investment holdings.
Portfolio Management includes portfolio design, ongoing investment monitoring, contingent
rebalancing, portfolio data management and tax lot accounting, quarterly analysis, and as needed
investment advice. This management is based on the methods and principles described broadly in
Item 8.
Integrity Investment Advisors consults with clients to determine their investment objectives and
their need, ability, and willingness to take investment risks. We then design an asset allocation
based on these parameters, recommend specific
investment vehicles, and discuss the
implementation process. Discretionary Authority - The client typically grants Integrity Investment
Advisors discretionary authority to buy and sell securities and, in most cases, deduct the
management fee from their accounts. Clients may also place restrictions on the kinds of
investments to be made. These restrictions must be in writing. See item 16.
For ongoing monitoring, Integrity Investment Advisors reviews each client's portfolio at least
quarterly and rebalances their agreed-upon allocation on a contingent basis. In general, contingent
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rebalancing relies on an event triggering the process. That event is typically a cash deposit or
withdrawal, a tax loss harvesting trade, or when a particular asset class deviates significantly from
the intended target percentage as stated in the long-term investment objective. Rebalancing is also
subject to the client's particular tax and risk circumstances. We believe the purpose of rebalancing
is to maintain portfolio structure, not to enhance returns, and that performance is directly
attributed to a client's exposure to risk. Rebalancing helps maintain consistent risk exposures over
time. Assets Under Advisement, such as a client’s holdings in a hedge fund, private equity, or illiquid
investments are not continuously overseen and managed by Integrity Investment Advisors and are
only intermittently monitored.
Integrity Investment Advisors maintains a client's portfolio data, including security information and
prices, balances, transaction activity, and cost basis information. This data is reconciled on a
continual basis with custodian data.
Integrity Investment Advisors provides portfolio review software through a third-party vendor.
This reporting includes a portfolio performance review, position performance review, asset
allocation, consolidated view of holdings, holdings detail by account. Additionally, custom reports
are available upon request, including reports designed to help a client with tax preparation and
compliance.
Use of Sub-Advisers
For investment management services, we may use an unaffiliated independent investment manager
to manage all or a portion of a clients’ investment account(s) (“Sub-Adviser”). Integrity Investment
Advisors has an arrangement with Focus Partners LLC, an independent registered investment
adviser not affiliated with Integrity Investment Advisors for investment management services to
clients’ accounts. Through this arrangement Integrity Investment Advisors recommends and uses
Focus Partners investment strategies and services for its clients’ accounts, when appropriate, based
on each client’s individual needs.
Integrity Investment Advisors will perform initial and ongoing oversight and due diligence over the
selected independent manager[s] strategies and target allocations remain aligned with its clients’
investment objectives and overall best interests. Integrity Investment Advisors is responsible for
determining a suitable investment strategy and portfolio for the client’s investment needs and goals
with Focus Partners. Integrity Investment Advisors is available to answer questions that the clients
may have regarding their account. Focus Partners will have discretionary authority to determine
the securities to be purchased and sold for the client’s accounts managed by Focus Partners
according to the investment strategy selected by Integrity Investment Advisors. Focus Partners also
provides operational support to Integrity Investment Advisors for the delivery of and reporting of
portfolio management services.
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Clients grant Integrity Investment Advisors and Focus Partners discretionary authority through the
Advisory Agreement or other grant of limited power of attorney to implement transactions with
their custodians on their behalf. Granting Integrity Investment Advisors and Focus Partners
discretionary authority allows them to direct, in their sole discretion, and without first contacting
you, the investment and reinvestment of the assets in your account in stocks, bonds, mutual funds,
exchange traded funds and other securities as well as in cash or cash equivalents.
Insurance Consulting
Our firm has an arrangement with an outside firm, DPL Financial Partners LLC (“DPL”) that enables
us to evaluate insurance products such as life insurance and annuities as part of a client’s overall
financial plan. We compensate DPL directly via a yearly access fee for the information they provide
to us about 3rd party insurance companies and their products. Clients may choose to separately
purchase these products from DPL; if they do, they will incur other fees and costs paid to DPL, the
third-party agency or insurer, not to Integrity Investment Advisors. Integrity Investment Advisors
charges an AUM fee based on cash value feed from the insurance company. For Insurance sub
accounts that are not updated on a regular basis, Integrity Investment Advisors will charge a “held
away asset fee” for the firm’s planning and oversight services to those assets is charged as an annual
fixed fee ranging between $1,000 – $10,000, and is based on the scope and complexity of the
services to those accounts using such factors as the amount and location of assets and their
allocation, investment selection, 2) comprehensive financial planning 3) tax strategy and working
with the Client’s tax advisor, and 4) overall complexity & scope of work.
DPL is a third-party provider of a platform of insurance consultancy services to SEC-registered
investment advisers (“RIAs”) that have clients with a need for insurance products. DPL is licensed
as an insurance producer in Kentucky, and other jurisdictions where required to perform the
platform services. Its representatives are also licensed as insurance producers, appointed as
insurance agents of the insurers offering their products through the platform, and registered
representatives of The Leaders Group.
Company Sponsored 401k plans, Pension Plans and Profit-Sharing Plans
Integrity Investment Advisors provides consulting services to small / medium sized 401k plans,
Pension Plans and Profit-Sharing Plans.
Integrity Investment Advisors, LLC is a limited scope “fiduciary” to the plan as that term is defined
under Section 3(21) of ERISA. Except for any assets contained within any specific asset allocation
programs devised by Integrity Investment Advisors. The Firm does not possess or exercise any
discretionary authority over the plan or any of its investment assets. Moreover, Integrity
Investment Advisors’ fiduciary duty does not, and will not, extend to a participant’s investment
decision making process as to how he/she chooses to allocate any portion of his/her plan assets
among any plan investments, including (to the extent applicable) Integrity Investment Advisors’
investment programs, it being understood that the participant retains all such investment decision
making authority and responsibility.
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Financial Planning
Integrity Investment Advisors provides financial planning services to clients receiving investment
management, and we also provide stand-alone financial planning engagements. The firm may
provide Clients consulting services for special projects for individuals/family offices. These projects
are billed separately from any investment management or oversight fee and based on the service,
time, and complexity of the engagement.
Assets Under Management
As of December 31, 2025, Integrity Investment Advisors managed approximately $385,759,178 in
client assets on a discretionary basis and $8,532,916 on a non-discretionary basis. We also provide
consulting services for assets that are not continuously managed but that are monitored on an
intermittent basis only. These assets consist of consulting services or non-liquid investments. The
Firm’s oversight for these accounts does not meet the definition of regulatory assets under
management because we do not provide continuous and regular supervisory or management
services for these assets.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement
Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts. The way we make money creates some conflicts with your interests, so we
operate under a special rule that requires us to act in your best interest and not put our interest
ahead of yours. Under this special rule’s provisions, we must:
o Meet a professional standard of care when making investment recommendations (give
prudent advice).
o Never put our financial interests ahead of yours when making recommendations (give
loyal advice).
o Avoid misleading statements about conflicts of interest, fees, and investments.
o Follow policies and procedures designed to ensure that we give advice that is in your best
interest.
o Charge no more than is reasonable for our services; and
o Give you information about conflicts of interest.
Item 5 – Fees and Compensation
The following section describes the fees for services for Integrity Investment Advisers. Fees are
negotiable solely at the discretion of the Firm. Integrity Investment Advisors retains the right to
negotiate the fee on assets and scope of services. There are legacy clients that may have a different
fee and/or means of fee calculation than that described below.
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For its investment management services including its planning services, Integrity Investment
Advisors is compensated by an annual fee charged on a quarterly basis, in arrears as described
herein. Unless otherwise indicated, the client will be charged at the end of each calendar quarter for
services rendered. Accounts at the household level will be combined for purposes of determining
the fee.
The fee will vary due to changing market values and by any additions or deletions to the account.
When the fee is based on the assets under management the fee is calculated as a percentage of the
value of the Account(s) on the last trading day of the calendar quarter, subject to a minimum fee.
Fees are not charged in advance. Clients who engage Integrity Investment Advisors for only a
portion of the quarter will pay a prorated fee based on the number of days in the quarter in which
services are rendered.
The Firm’s fee is set forth in its investment advisory services agreement with each client The Firm
bases its fee on a percentage of the client’s assets under management and the scope and complexity
of the Firm’s services to be provided to the client using a number of factors, such as the amount of
assets under the Firm’s management, the type of assets being overseen, the planning services
needed, and the potential future revenue from the client relationship.. Fees range from 1.25% to
0.3% of assets under management, subject to a minimum fee. The Firm’s fee applies to cash
balances in the client’s account and alternative investments overseen by the Firm unless negotiated
or agreed upon otherwise.
Clients are subject to the following minimum fee depending upon the level of services being
provided:
Core Wealth Level of Services -- $7,000 annually/billed at $1,750 per quarter minimum
Private Wealth Level of Services- $20,000 annually/ billed at $5,000 per quarter minimum
Sub-Adviser’s Fee
Clients do not pay additional fees to Focus Partners when used for client’s account(s). Integrity
Investment Advisor’s fee encompasses Focus Partners fee for the services provided to clients’
accounts. Clients do not pay brokerage commissions or any other fees to Focus Partners.
Management Fee for “Held Away Asset”
Client assets that are not a part of an account held at a custodian with which Integrity Investment
Advisors has a custodial agreement such securities held in an insurance policy’s investing
subaccount, in a 401k account held at an employer’s retirement plan or a private equity or hedge
fund holdings, restricted stock, or other non-liquid investments are “Held Away Assets.” For Held
Away Assets for which we have continuous, reliable access to account data and valuation, we will
charge an annual fee, paid quarterly, in arrears, based on the percentage of their value on the last
day of the calendar quarter pursuant to the Portfolio Management & Comprehensive Financial
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Planning Fee Schedule set forth in your agreement for the oversight of those assets. When we do
not have continuous, reliable access to account data and valuation for Held Away Assets, we will
charge a fixed, annual fee ranging between $1,000 and $10,000, paid quarterly, in arrears for our
services to those assets. We will determine the fixed fee the fee for Held Away Assets based on the
scope and complexity of the services to those assets using such factors as 1) amount and location of
assets and their allocation, investment selection, 2) financial planning related to those assets 3)
consideration of tax strategies and the extent assisting the client’s tax advisor, and 4) overall
complexity & scope of work.
If our access to account data and valuations for Held Away Assets becomes unreliable after
previously having reliable data and valuations, we will provide the client with notice of a change to
a fixed fee and the amount of that fixed fee; thereafter, we will only bill on those Held Away Assets
as a fixed fee. We will determine any annual, fixed fee for Held Away Assets upon engagement, when
a loss of reliable access to account data and valuation occurs, and no less than annually thereafter.
There may be additional integration fees for the manual integration of assets.
Means of Payment of Advisory Fees
There are 2 options for making payment of Integrity Investment Advisors’ advisory fee. Option 1)
is automatic deduction from an account held at an independent custodian. Clients will provide
written authorization if fees are to be deducted directly from their account in their advisory
agreement. When the fee is deducted, Integrity Investment Advisors will send an invoice to the
account’s custodian and to the Client. The custodian will send monthly or quarterly statements to
Client that detail all disbursements for the account, including the amount of the advisory fees
deducted from the account. Option 2) is direct payment made from Client to Integrity Investment
Advisors. In Integrity Investment Advisors’ sole discretion, advisory fees may also be payable
directly by check, ACH, or wire transfer.
Insurance Consulting
For clients who receive this service through Integrity Investment Advisors as outlined above, we
charge an AUM fee based on cash value feed from the insurance company. For Insurance sub
accounts that are not updated on a regular basis, Integrity Investment Advisors will charge a “held
away asset fee” for the firm’s planning and oversight services to those assets is charged as an annual
fixed fee ranging between $1,000 – $10,000, and is based on the scope and complexity of the
services to those accounts using such factors as the amount and location of assets and their
allocation, investment selection, 2) comprehensive financial planning 3) tax strategy and working
with the Client’s tax advisor, and 4) overall complexity & scope of work.
Employee Benefit Retirement Plan Services – Company Sponsored 401(k) plans/Pension
Plans/ Profit-Sharing Plans
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Standard 401(k) fee schedule for small to medium business 401k plans. In general, Integrity
Investment Advisors’ fees are negotiable, and will range from 0.80% to 0.25% of assets in the plan,
depending on complexity and scope of work. We may also provide consulting services on a flat fee
basis in some cases.
** Additional hourly consulting for 401k or DB Plan
Jr. Advisor at $150 per hour for Zoom meeting
-
- Partner Advisor at $250 per hour for Zoom meeting
Consulting
On the first $5,000,000
On the next $5,000,000
Annual Fee (%)
Depends on scope of work
Depends on scope of work
On amounts above $10,000,000
Depends on scope of work
Financial Planning Fee
When Integrity Investment Advisors provides financial planning services to a client either in
addition to its investment management services or to a client that does not receive the firm’s
investment services, a fixed fee ranging from $500-$15,000+, or an hourly rate will be charged,
depending upon the scope of the planning and the complexity of the planning needed. The specific
fee charged for the services will be set forth in the Client’s agreement with Integrity Investment
Advisors.
Family Office Data Integration Fee
For services to family offices, Integrity Investment Advisors charges a data integration fee ranging
from $300-$4,000 per month when significant manual inputting of data is necessary for the
reporting of outside accounts, processing portfolio accounting, providing performance reporting
and for the overall comprehensive investment management of Client’s assets.
Hourly Fee
Financial planning services/ consulting will be billed an hourly fee ranging from $125 to $700 per
hour, depending on the professional classification, and experience of the individual providing the
service. Administrative staff is charged based on hourly fees ranging from $75 to $165 per hour,
depending on the staffing of the engagement. Any special projects will be based upon mutual
agreement of Scope of Work with the client and shall be due and payable as earned.
Other Expenses and Fees
Integrity Investment Advisors, LLC is a fee-only advisor. Integrity Investment Advisors’ fees are
exclusive of brokerage commissions, transaction fees, and other related costs and expenses which
shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers,
third party investment managers, SMA managers, Direct Indexing providers, and other third parties
such as fees charged by third party managers, insurance providers such as DPL Financial, platform
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providers like iCapital or CAIS, custodial fees, deferred sales charges, odd-lot differentials, transfer
taxes, wire transfer and electronic fund fees, termination fees, account closing fees and other fees
and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded
funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such
charges, fees and commissions are exclusive of and in addition to Integrity Investment Advisors’
fee, and Integrity Investment Advisors shall not receive any portion of these commissions, fees, and
costs.
No employee or officer of Integrity Investment Advisors accepts compensation of any kind for the
sale of securities or any other investment products. Item 12 further describes the factors that
Integrity Investment Advisors considers in selecting or recommending broker-dealers for client
transactions and determining the reasonableness of their compensation.
In addition to the assets under management fee, client will reimburse Integrity Investment
Advisors for any reasonable travel expenses incurred by Integrity Investment Advisors on behalf of
client while providing asset management services. Integrity Investment Advisors will obtain client’s
authorization before incurring such travel expenses and provide documentation of such expenses
upon request by the client. The client may pay the travel expenses owed by submitting payment
directly by check.
Fees at Termination
Clients may terminate their engagement by providing Integrity Investment Advisors with 30-day
written notification. If Integrity Investment Advisors decides to terminate relationship, termination
will be effective 30 days after notice is delivered to Client. Upon termination of any agreement, any
prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and
payable. Integrity Investment Advisors will prorate unpaid fees based on the date of the notification.
Item 6 – Performance-Based Fees and Side-By-Side Management
Integrity Investment Advisors does not charge performance-based fees and will not be
compensated based on a share of capital gains or on capital appreciation of the funds or any portion
of the funds of the client.
Item 7 – Types of Clients
Integrity Investment Advisors provides services to individuals, high net worth individuals,
corporate pension and profit-sharing plans, 401k plans, trusts, business entities, charitable
institutions, foundations, endowments, and other institutions.
Integrity Investment Advisors generally requires a minimum account size of $500,000 to establish
an investment management relationship; however, the Firm can, in its sole discretion, modify or
waive that amount.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Investing in securities involves the risk of loss that clients should be prepared to bear. These losses
can be persistent over long periods of time and extreme at times of crisis. Integrity Investment
Advisors, LLC will invest a client's assets based on the following principles:
• Markets are efficient, and assets are fairly priced. Any market timing is pure speculation.
• Risk and Return are directly related. Priced risk factors determine expected return.
• Investors should not expect to be compensated for taking risks that can be easily reduced
through diversification.
• Portfolio structure (asset allocation) is the primary determinant of performance for a
broadly diversified portfolio.
• Undisciplined and/or emotional behavior is the enemy of a successful investment
experience.
Our philosophy embraces the tenets of Modern Portfolio Theory, The Efficient Markets Hypothesis,
and the Fama/French 5-Factor Model.
We believe an efficient and cost-effective method of implementing a portfolio structured around
priced risk factors is to use passively managed funds. The use of actively managed funds is not
recommended because these funds may have holdings that vary across dimensions of risk, making
portfolio structure difficult to maintain.
Our goal is to efficiently- capture market returns commensurate with a client's chosen level of risk.
Integrity Investment Advisors should be judged by how well we maintain a client's asset allocation
to its intended structure, minimize the cost of investing, prioritize tax efficiency, and help a client
avoid behavioral mistakes.
An Integrity Investment Advisors client is primarily invested in open‐end Mutual Funds and/or
Exchange‐Traded Funds. The risk and performance of these investment vehicles is driven primarily
by the market risk exposures found in each fund.
Risk of Loss:
Please Note: Investment Risk. Different types of investments involve varying
degrees of risk, and it should not be assumed that future performance of any specific
investment or investment strategy (including the investments and/or investment
strategies recommended or undertaken by Integrity Investment Advisors) will be
profitable or equal any specific performance level(s). The primary risk for Integrity
Investment Advisors clients is market risk. Their portfolio performance is primarily
driven by market returns and their portfolio volatility and risk of loss is directly
related to their exposure to market risk factors.
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Investing in securities involves risks of loss that you should be prepared to bear.
Investing in foreign stock markets involves additional risks including political,
economic, and currency risks, as well as differences in accounting methods. Investing
in fixed income instruments may involve certain costs and risks such as liquidity risk,
interest rate risk, and credit risk. There can be no guarantee that an investment
strategy will meet its investment objectives or that it will not suffer losses. Below are
some of the specific risks clients face related to Integrity Investment Advisors’
investment strategies:
Risks Investing in Mutual Funds and ETFs
Your account(s) bear all the risks of the investment strategies employed by the
mutual funds and ETFs held in your account(s), including the risk that a mutual fund
or ETF will not meet its investment objectives. For the specific risks associated with
certain mutual funds or ETFs, please see the investment prospectus.
Unique Risks Investing in ETFs
An ETF is a security that trades on an exchange during market hours and typically
seeks to track an index, commodity, or a basket of assets like an index fund. However,
some ETFs are actively managed and do not seek to track a certain index or basket
of assets. ETFs may trade at a premium or discount to their Net Asset Value (“NAV’)
and may also be affected by market fluctuations of their underlying investment
holdings. They may also have unique risks depending on their structure and
underlying investments. These risks can become significant during times of high
market volatility or temporary crashes in the underlying liquidity of the investments.
Risks Investing in Stock Funds
Stock markets are volatile and can decline significantly and quickly over short or
even long periods in response to adverse issuer, political, regulatory, market, or
economic developments. In a diversified stock fund overall systematic (market risk)
poses the greatest potential for losses in your account(s). In addition, stock
investments may be subject to risk related to market capitalization as well as
company-specific risk. Foreign stock investing involves risks not typically associated
with U.S. domestic investments, and the risks may be further amplified in emerging
market countries. These risks may include, among others, adverse fluctuations in
foreign currency values, as well as adverse political, social and economic
developments affecting one or more foreign countries. In addition, foreign investing
may involve less publicly available information and more volatile or less liquid
securities markets, particularly in markets that trade a small number of securities,
have unstable governments, or involve limited industry.
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Risks Investing in Bond Funds
In general, the bond 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.) The ability of an issuer of a
bond to repay principal prior to a security’s maturity can cause greater price
volatility if interest rates change, and, if a bond is prepaid, a bond fund may have to
invest the proceeds in securities with lower yields. Fixed income securities also carry
inflation risk, credit risk (the risk of changes in the financial condition of an issuer)
and default risk (the risk that the issuer may fail to pay its debts) for both issuers and
counterparties. Unlike investing in individual bonds, typically bond funds do not
have a maturity date, so holding them until maturity to avoid losses caused by price
volatility is not possible. In addition, investments in certain bond structures may be
less liquid than other investments and therefore may be more difficult to trade
effectively.
Risks Investing in Municipal Bond Funds
Investing in the municipal bond market can be affected by adverse tax, legislative, or
political changes, and by the financial condition of the issuers of individual municipal
securities. Municipal bond funds normally seek to earn income and pay dividends
that are expected to be exempt from federal income tax. If you are a resident in the
state of issuance of the bonds held by the fund, interest dividends may also be exempt
from state and local income taxes. Income exempt from regular federal income tax
(including distributions from tax-exempt, municipal, and money market funds) may
be subject to state, local, or federal alternative minimum tax. Certain municipal bond
funds normally seek to invest only in municipal securities generating income exempt
from both federal income taxes and the federal alternative minimum tax; however,
outcomes cannot be guaranteed, and the funds may sometimes generate income
subject to these taxes. You should consult with an accountant, CPA, or tax attorney
regarding the unique tax consequences of investing in municipal bond funds.
Risks Investing in Alternative Investments, Private Funds & Illiquid Strategies
Investments in Alternative Funds, including but not limited to hedge funds, private
equity funds, private credit funds, private real estate funds, trend following funds,
leveraged funds, long/short funds, managed futures funds, blockchain or digital
asset funds, thematic private funds, and other privately offered pooled investment
vehicles (collectively, “Alternative Funds”) involve substantial risks, including the
risk of loss of principal. Alternative Funds are not suitable for all investors.
Risks associated with investments in Alternative Funds include:
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Valuation Risk and Infrequent Pricing
Many Alternative Funds:
Are valued only monthly or quarterly
Provide account statements based on manager-reported net asset values (NAV)
Rely on estimates, models, appraisals, or internally determined valuations
May hold securities or assets for which market quotations are not readily
available
As a result:
Reported values may not reflect the amount that could be realized upon
liquidation
Valuations may be revised or adjusted by the fund manager
Pricing may be “stale” between reporting periods
Performance reporting may be based on estimated or unaudited valuations
Clients should understand that interim values may not represent realizable value
and may differ materially from final audited valuations.
Impose lock-up periods
Liquidity Restrictions and Redemption Risk
Alternative Funds are typically illiquid and may:
Restrict withdrawals to quarterly, annual, or longer intervals
Limit redemptions through gates
Suspend redemptions during periods of market stress
Permit in-kind distributions
Use side pockets for illiquid investments
Require advance redemption notices
Delay or stagger distributions.
Accordingly:
Clients may be unable to access invested capital for extended periods
Redemption proceeds may be delayed
Liquidity may be materially reduced during market disruptions
Clients should not invest funds needed for near-term liquidity requirements.
Capital Call and Commitment Risk
Certain private equity, private credit, and real asset funds operate on a capital
commitment basis and may:
Issue capital calls on short notice
Impose penalties for failure to meet capital calls
Distribute capital unpredictably over multi-year periods.
Clients must maintain sufficient liquidity to meet capital commitments when due.
Use of Leverage and Derivatives
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Increased volatility
Alternative Funds may use leverage, derivatives, forward contracts, futures
contracts, swaps, structured products, commodities exposure, or other complex
instruments. These strategies involve additional risks including:
Counterparty risk
Liquidity risk
Pricing risk
Operational risk
Losses exceeding invested capital in certain structures.
Leverage magnifies both gains and losses.
Short Selling Risk
Funds that engage in short selling borrow securities and sell them in anticipation of
price declines. If the price of a security increases after it is sold short, the fund may
incur significant losses when repurchasing the security. Losses on short positions
may be theoretically unlimited. Short selling also involves additional transaction,
borrowing, and financing costs.
Concentration Risk
Certain Alternative Funds may concentrate investments by strategy, asset class,
sector, geography, or manager. Concentration increases exposure to adverse market,
economic, or regulatory events affecting those areas and may result in greater
volatility.
Limited Transparency
Alternative Funds may provide limited transparency regarding:
Portfolio holdings
Strategy implementation
Risk exposures
Underlying leverage
Clients must rely on the skill and integrity of the fund manager.
Fee and Expense Risk
Alternative Funds typically charge:
Management fees
Performance or incentive fees
Organizational and operating expenses
Administrative and audit costs.
These fees are in addition to advisory fees charged by our firm and reduce overall
investment returns.
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Custody and Operational Risk
Many Alternative Funds:
Do not provide daily custodial reporting
Use third-party administrators
Operate outside of registered investment company frameworks
May not be registered under the Investment Company Act of 1940
Operational failures, fraud, or internal control weaknesses may result in losses.
Interim reports may not reflect current realizable value
Performance Reporting Considerations
Because many Alternative Funds are valued monthly or quarterly:
Performance reporting may lag public markets
Reported returns may rely on manager-supplied data
Adjustments may occur after audits
Clients should evaluate long-term performance rather than short-term fluctuations.
Item 9 – Disciplinary Information
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of Integrity Investment Advisors, LLC
or the integrity of Integrity Investment Advisors management. Integrity Investment Advisors has
no information applicable to this item (i.e., there are no relevant legal or disciplinary events to
disclose).
Item 10 – Other Financial Industry Activities and Affiliations
Integrity Investment Advisors (and its management) are not registered, or have an application
pending to register, as a broker‐dealer or a registered representative of a broker dealer.
Integrity Investment Advisors (and its management) are not registered, or have an application to
register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or an associated person of the foregoing entities.
Todd J. Moerman, managing member of Integrity Investment Advisors, LLC, has a fifty percent
(50%) ownership interest in 365 Tax Strategy, LLC (“365”). 365 provides tax preparation services,
which presents a potential conflict of interest to clients of Integrity Investment Advisors when Mr.
Moerman recommends 365 to them due to the increased compensation he receives when clients
use the services of 365. This conflict is mitigated as clients of Integrity Investment Advisors are not
required to engage 365 for tax preparation services, and any recommendations related to tax
preparation services are made strictly in the best interest of clients of Integrity Advisors, LLC, which
mitigates any potential conflicts.
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The sub-adviser that the Firm uses for clients’ accounts, Focus Partners, is not affiliated, nor jointly
owned with Integrity Investment Advisors, LLC. When Integrity Investment Advisors uses an
external manager to create and maintain a client’s investment account, the Firm will first ensure
that this adviser is appropriately registered and/or notice-filed within your state of residence. As
referenced in Item 5 of this brochure, Focus Partners is compensated for their respective services
by Integrity Investment Advisors.
Integrity Investment Advisors does not receive compensation directly or indirectly from any such
advisors that creates a material conflict of interest. Integrity Investment Advisors does not have any
other business relationships with other advisors that create a material conflict of interest. As a
fiduciary, Integrity Investment Advisors has certain legal obligations, including the obligation to act
in clients’ best interest. Integrity Investment Advisors maintains a Business Continuity and
Succession Plan and seeks to avoid a disruption of service to clients in the event of an unforeseen
loss of key personnel, due to disability or death. To that end, Integrity IA has entered into a
succession agreement with Focus Partners Wealth, LLC, effective 1/2018. Integrity IA can provide
additional information to any current or prospective client upon request to Todd Moerman, CEO at
303-549-4720 or todd@integrityia.com.
Integrity Investment Advisors, LLC has a relationship with DPL Financial Partners, LLC (“DPL”) to
provide clients insurance reviews/analyses, education, and insurance solutions. DPL Financial
Partners, LLC (“DPL”) is a third-party provider of a platform of insurance consultation services to
investment advisers with clients who have current or future needs for insurance products.
Integrity Investment Advisors receives access to DPL’s platform for a fixed annual fee. Through its
licensed insurance agents, who are also registered representatives of The Leaders Group, Inc. (“The
Leaders Group”), an unaffiliated SEC-registered broker-dealer and FINRA member, DPL offers
members a variety of services relating to commission free insurance products. These services
include, among others, providing members with analyses of their current methodology for
evaluating client insurance needs, educating and acting as a resource to members regarding
insurance products generally and specific insurance products owned by their clients or that their
clients are considering purchasing, and providing members access to, and marketing support for,
commission free products that insurers have agreed to offer to members’ clients through DPL’s
platform.
For providing platform services to RIAs and ERAs, DPL receives service fees from the insurers that
offer their commission free products through the platform. These service fees are based on the
insurance premiums received by the insurers from DPL members’ clients. DPL is licensed as an
insurance producer in Kentucky, and other jurisdictions where required to perform the platform
services. Its representatives are also licensed as insurance producers, appointed as insurance
agents of the insurers offering their products through the platform, and registered representatives
of The Leaders Group.
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Item 11 – Code of Ethics
As a fiduciary, Integrity Investment Advisors has a duty of utmost good faith to act solely in the best
interests of each of our clients. Our clients entrust us with their funds, which in turn place a high
standard on our conduct and integrity. Our fiduciary duty compels all employees to act with the
utmost integrity in all our dealings. This fiduciary duty is the core principle underlying our Code of
Ethics policy and represents the expected basis of all our dealings with our clients. Our Code of
Ethics is intended to meet the requirements of Rule 240A‐1 under the Investment Advisers Act of
1940 and is included in our internal Compliance Manual and is available upon request. In short, it
requires Integrity Investment Advisors’ Employees to behave as a fiduciary toward clients, avoid
conflicts of interest, and protect client personal information.
Integrity Investment Advisors is also committed to complying with the Code of Ethics and
Professional Responsibility issued by the Certified Financial Planner Board of Standards, Inc. A
complete copy of the CFP Code of Ethics and Professional Responsibility is available at
http://www.cfp.net/for-cfp-professionals/professional-standards-enforcement/standards-of-
professional-conduct/code-of-ethics-professional-responsibility
Integrity Investment Advisors does not recommend to clients – or buy or sell for client accounts –
securities in which it or a related person has material financial interest.
Integrity Investment Advisors’ members, officers, and employees may buy or sell securities that it
also recommends to clients. Integrity Investment Advisors’ CCO will ensure that any such
transaction does not create an advantageous situation for any member, officer, or employee over
any client in accordance with its Code of Ethics.
Protection of Material Non-Public Information – Privacy Notice
Employees are expected to exercise diligence and care in maintaining and protecting our client's
non-public, confidential information. Employees are also expected to not divulge information
regarding the Company's securities recommendations or client securities holdings to any individual
outside the Company, except: as necessary to complete transactions or account changes; as
necessary to maintain or service a client or his/her account; with various service providers who
provide administrative functions for the Company, only after we have entered into a contractual
agreement that prohibits the service provider from disclosing or using confidential information
except as necessary to carry out its assigned responsibilities and only for that purpose or such
provider has supplied us with a privacy statement which meets our requirements; or as permitted
by law.
Personal Conduct
Employees are prohibited from receiving any gift, gratuity, hospitality, or other offering of more
than de minimis value from any person or entity doing business with the Company or client of the
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Company. The Company defines de minimis as the typical cost of dinner for two at an elegant
restaurant. This gift policy generally excludes items or events where the employee has reason to
believe there is a legitimate business purpose.
Item 12 – Brokerage Practices
Investment or Brokerage Discretion.
Integrity Investment Advisors has a custodial relationship with Schwab Institutional Services and
recommends discount brokerage firms and trust companies (qualified custodians), such as Charles
Schwab for its clients’ accounts. Integrity Investment Advisors only recommends custodians based
on the proven integrity and financial responsibility of the firm and the best execution of orders at
reasonable commission rates. Integrity Investment Advisors DOES NOT receive fees or
commissions from any of these arrangements. Integrity Investment Advisors does not have any
affiliation with product sales firms. When a client directs brokerage, we cannot ensure best
execution in the account.
Soft Dollars
The Firm does not have any formal soft-dollar arrangements, but the Firm does participate in the
Schwab Institutional (SI) services program offered to independent investment advisers by Charles
Schwab & Company, Inc. (“Schwab”), a FINRA-registered broker dealer. Integrity Investment
Advisors recommends Schwab to clients needing brokerage and custodial services. While there is
no direct linkage between the investment advice given and participation in the SI program,
economic benefits are received which would not be received if Integrity Investment Advisors did
not give investment advice to clients. These benefits include: receipt of duplicate client
confirmations and bundled duplicate statements; access to a trading desk serving SI participants
exclusively; access to block trading which provides the ability to aggregate securities transactions
and then allocate the appropriate shares to client accounts; ability to have investment advisory fees
deducted directly from client account; access, for a fee, to an electronic communication network for
client order entry and account information; receipt of compliance publications; and access to
mutual funds which generally require significantly higher minimum initial investments or are
generally available only to institutional investors. The benefits received through participation in the
SI program may or may not depend upon the number of transactions directed to, or amount of
assets held at Schwab.
Participation in the SI program results in a potential conflict of interest for our firm, as the receipt
of the above benefits creates an incentive for us to use Schwab for the execution of client trades.
Nonetheless, we have reviewed the services of Schwab and recommend the services based on
several factors. These factors include the professional services offered, commission rates, and the
custodial platform provided to clients.
As part of its fiduciary duties to clients, Integrity Investment Advisors endeavors at all times to put
the interests of its clients first. Clients should be aware, however, that the receipt of economic
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benefits by Integrity Investment Advisors or its related persons in and of itself creates a potential
conflict of interest and may indirectly influence Integrity Investment Advisors’ choice of Schwab for
custody and brokerage services.
Trade Error Policy. Integrity Investment Advisors shall reimburse accounts for losses resulting
from Integrity Investment Advisors, LLC’s trade errors, but shall not credit accounts for such errors
resulting in market gains. The gains and losses are reconciled within Integrity Investment Advisors’
custodian firm account and any gain is donated to charity or if requested by the client paid over to
the client.
Trade Aggregation. As a matter of policy, depending on market conditions, Integrity Investment
Advisors may aggregate the purchase or sale of securities for clients.
Item 13 – Review of Accounts
Integrity Investment Advisors provides portfolio reporting on a as needed basis. This reporting
includes a portfolio performance review, position performance review, current asset allocation,
consolidated view of holdings, holdings detail by account. Additionally, custom reports are available
upon request, including reports designed to help a client with tax preparation and compliance.
Although the exact review process depends upon the nature and terms of the specific engagement,
the following description of the review process generally applies:
For clients with accounts at Schwab, portfolios are reviewed by Todd Moerman, President, on a
regular basis. Comprehensive portfolio reviews are conducted on at least a quarterly basis and
rebalanced on a contingent basis. Accounts held outside of Schwab or performance reporting
software or for assets that we do not provide continuous oversight to (illiquid holdings) are not
provided ongoing and continuous oversight by us and are not regularly reviewed.
The client's account’s custodian provides monthly or quarterly statements reflecting the market
value, quantity of securities held within the client's accounts, and transaction activity conducted
within the account(s) since the last statement. We urge clients to compare the information
contained in our reports to the information contained in the account custodian’s statements.
Item 14 – Client Referrals and Other Compensation
Integrity Investment Advisors, LLC is a fee-only firm and receives no money or other economic
benefit from anybody except clients as a result of providing investment advice or other advisory
services to its clients.
Integrity Investment Advisors and its employees do not receive any financial compensation from
brokerage referrals, nor does it receive any targeted or customized research, etc. Integrity
Investment Advisors, LLC, as part of its relationship with a discount broker, may receive general
research reports and newsletters that all such advisors receive. Any research services provided by
a discount broker may be of benefit to all the Company's clients and not only clients having accounts
with that broker.
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Item 15 – Custody
Integrity Investment Advisors does not maintain physical custody of clients’ funds or securities.
A client should receive monthly or quarterly statements from their custodian. Integrity Investment
Advisors urges clients to carefully review these statements and compare them to the account
statements that we may provide. Our statements may vary from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies of certain securities.
The Firm has constructive custody of assets to the extent it uses Standing Letters of Authorizations
(“SLOA’s”) for third-party money transfers.
Item 16 – Investment Discretion
Integrity Investment Advisors usually receives discretionary authority from a client at the outset of
an advisory relationship to select the identity and amount of securities to be bought or sold. In all
cases, however, such discretion is to be exercised in a manner consistent with the stated investment
objectives for the client’s account. When selecting securities and determining amounts, Integrity
Investment Advisors observes the investment policies, limitations, and restrictions of the clients for
which it advises. Investment guidelines and restrictions must be provided to Integrity Investment
Advisors in writing.
If discretionary authority is granted, it is explicitly authorized in a written agreement with Integrity
Investment Advisors, LLC. For discretionary accounts, a Limited Power of Attorney (“LPOA”) is
executed by the client, giving Integrity Investment Advisors the authority to carry out various
activities in the account, generally including the following: trade execution; the ability to request
checks on behalf of the client; and the withdrawal of advisory fees directly from the account.
Integrity Investment Advisors then directs investment of the client’s portfolio using its
discretionary authority. The client may limit the terms of the LPOA to the extent consistent with the
client’s investment advisory agreement with Integrity Investment Advisors and the requirements
of the client’s custodian.
the client,
Integrity
Investment Advisors does not
implement
For non-discretionary accounts, the client also generally executes an LPOA, which allows Integrity
Investment Advisors to carry out trade recommendations and approved actions in the portfolio.
However, in accordance with the investment advisory agreement between Integrity Investment
Advisors and
trading
recommendations or other actions in the account unless and until the client has approved the
recommendation or action. As with discretionary accounts, clients may limit the terms of the LPOA,
subject to Integrity Investment Advisors’ agreement with the client and the requirements of the
client’s custodian.
Please Note: Non-Discretionary Service Limitations. Clients that engage Integrity Investment
Advisors on a non-discretionary investment advisory basis must be willing to accept that Integrity
Investment Advisors cannot affect any account transactions without obtaining prior verbal consent
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to any such transaction(s) from the client. Thus, in the event of a market correction during which
the client is unavailable, Integrity Investment Advisors will be unable to affect any account
transactions (as it would for its discretionary clients) without first obtaining the client’s verbal
consent.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, Integrity Investment Advisors does not have any authority
to and does not vote proxies or corporate actions on behalf of advisory clients. Clients retain the
responsibility for receiving and voting proxies for all securities maintained in client portfolios.
Integrity Investment Advisors, LLC may provide advice to clients regarding the clients’ voting of
proxies.
Item 18 – Financial Information
Registered investment advisors are required in this Item to provide clients with certain financial
information or disclosures about Integrity Investment Advisors, LLC financial condition. Integrity
Investment Advisors has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients and has not been the subject of bankruptcy proceedings.
Integrity Investment Advisors does not require or solicit prepayment fees of more than $1200, per
client, for services provided six months or more in advance.
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Item 1 Cover Page – ADV Part 2B Brochure Supplement
Todd J. Moerman, AWMA®
CRD# 5806129
3275 Twin Heron Ct.
Fort Collins, CO 80528
303-549-4720
invest@integrityia.com
March 25, 2026
This Brochure Supplement provides information about Todd J. Moerman that supplements the
Integrity Investment Advisors, LLC Brochure. You should have received a copy of that Brochure.
Please contact Todd J. Moerman, Chief Compliance Officer, if you did not receive Integrity
Investment Advisors, LLC’s Brochure or if you have any questions about the contents of this
supplement.
information about Todd J. Moerman
is available on the SEC’s website at
Additional
www.adviserinfo.sec.gov.
21
Item 2 Education Background and Business Experience
Todd J. Moerman was born in 1969. Mr. Moerman graduated from Miami University in 1991, with
a Bachelor of Science degree in Finance. Mr. Moerman is the Founder and President of Integrity
Investment Advisors, LLC founded in 2010. In 2012, Mr. Moerman earned his Accredited Wealth
Management Advisor (AWMA®) designation from the College for Financial Planning. This
accreditation is the CFP558 curriculum and covers the below.
3/2012 - Accredited Wealth Management Advisor (AWMA®) – minimum requirements include the
below subject matter, passing a final exam and 16 hours of continuing education every two years.
The Asset Management Process
Investors, Policy & Change
Risk, Return & Investment Performance
Asset Allocation & Selection
Investment Strategies
Taxation of Investment Products
Investment Opportunities for an Individual’s Retirement
Investment Considerations for Small-Business Owners
Insurance Products for Investment Clients
Income Tax & Executive Benefits Planning for High-Net-Worth Clients
Deferred Compensation & Other Benefit Plans for Key Executives
Estate Planning for Investment Clients
Regulatory & Ethical Issues for the Investment Professional
Risk Management & Investment Issues for High-Net-Worth Clients
Estate Planning for High-Net-Worth Clients
Item 3 Disciplinary Information
None.
Item 4 Other Business Activities
Mr. Moerman is the managing member of Integrity Investment Advisors, LLC, has a fifty percent
(50%) ownership interest in 365 Tax Strategy, LLC (“365”), which provides tax preparation
services. Clients of Integrity Investment Advisors, LLC are not required to engage 365 for tax
preparation services, and any recommendations related to tax preparation services are made
strictly in the best interest of clients of Integrity Advisors, LLC, which mitigates any potential
conflicts. Mr. Moerman’s involvement with 365 takes up approximately 10 percent of his time.
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Item 5 Additional Compensation
None.
Item 6 Supervision
Integrity Investment Advisors’ Chief Compliance Officer, Todd J. Moerman, is responsible for
overseeing the activities of the firm and himself. Should a client have any questions regarding
Integrity Investment Advisors’ supervision or compliance practices, please contact Mr. Moerman at
(303) 549-4720.
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Item 1 Cover Page – ADV Part 2B Brochure Supplement
Robert Samuel “Sam” Hamilton, CFP®
CRD# 6331348
3275 Twin Heron Ct.
Fort Collins, CO 80528
303-549-4720
invest@integrityia.com
March 25, 2026
This Brochure Supplement provides information about Robert S. Hamilton that supplements the
Integrity Investment Advisors, LLC Brochure. You should have received a copy of that Brochure.
Please contact Todd J. Moerman, Chief Compliance Officer, if you did not receive Integrity
Investment Advisors, LLC’s Brochure or if you have any questions about the contents of this
supplement.
Additional information about Robert S. Hamilton is available on the SEC’s website at
www.adviserinfo.sec.gov.
24
Item 2 Education Background and Business Experience
Robert Samuel Hamilton was born in 1995. Mr. Hamilton graduated from the University of Denver
in 2017 with a Bachelor of Science degree in Accounting and a Master of Accountancy. Mr. Hamilton
is the Lead Planner of Integrity Investment Advisors, LLC. In 2021, Mr. Hamilton earned his Certified
Financial Planner (CFP®) Certification.
Designations/Certifications:
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP (with flame design)
marks (collectively, the “CFP® marks”) are professional certification marks granted in the United
States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification
is a voluntary certification; no federal or state law or regulation requires financial planners to hold
CFP® certification. It is recognized in the United States and other countries for its (1) high standard
of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical
requirements that govern professional engagements with clients.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following
requirements:
Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services and attain a bachelor’s degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk management,
employee benefits planning, investment planning, income tax planning, retirement planning, and
estate planning.
Examination – Pass the comprehensive CFP® Certification Examination. The 6-hour examination
includes case studies and client scenarios designed to test one’s ability to correctly diagnose
financial planning issues and apply one’s knowledge of financial planning to real world
circumstances.
Experience – Complete at least three years of full-time financial planning-related Financial Planning
experience (or the equivalent, measured as 2,000 hours per year); and
Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to maintain the right to continue to use the CFP® marks:
Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to
maintain competence and keep up with developments in the financial planning field; and
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Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the
best interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject
to the CFP Board’s enforcement process, which could result in suspension or permanent revocation
of their CFP® certification.
Item 3 Disciplinary Information
None.
Item 4 Other Business Activities
Mr. Hamilton is a lead tax advisor with 365 Tax Strategy, LLC (“365”), which provides tax
preparation services. Clients of Integrity Investment Advisors, LLC are not required to engage 365
for tax preparation services, and any recommendations related to tax preparation services are
made strictly in the best interest of clients of Integrity Advisors, LLC, which mitigates any potential
conflicts. Mr. Hamilton’s involvement with 365 takes up approximately 20% of his time.
Item 5 Additional Compensation
None.
Item 6 Supervision
Integrity Investment Advisors’ Chief Compliance Officer, Todd J. Moerman, is responsible for
overseeing the activities of Mr. Hamilton. Should a client have any questions regarding Integrity
Investment Advisors’ supervision or compliance practices, please contact Mr. Moerman at
(303)549-4720.
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