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Cover Page - Item 1
Interactive Financial Advisors
100 Batson Ct. Suite 104
New Lenox, IL 60451
630-472-1300 phone
800-261-1660 (toll free)
844-270-4905 facsimile
www.someonewhocares.com
February 4, 2026
Form ADV Part 2A Brochure
This brochure provides information about the qualifications and business practices of Interactive Financial
Advisors (“IFA”). If you have any questions about the contents of this brochure, please contact us at (630)
472-1300 or www.someonewhocares.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 Interactive Financial Advisors is also available on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for Interactive Financial Advisors is 125117.
Interactive Financial Advisors is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain level of skill
or training.
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Form ADV Part 2A
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Material Changes - Item 2
Form ADV Part 2 requires registered investment advisers to amend their brochure when information
becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the
adviser is required to notify you and provide you with a description of the material changes.
On March 25, 2025, we submitted our annual updating amendment for fiscal year 2024. There were no
material changes to report.
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Form ADV Part 2A
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Table of Contents - Item 3
Contents
Cover Page - Item 1 ....................................................................................................................................... 1
Material Changes - Item 2 ............................................................................................................................. 2
Table of Contents - Item 3 ............................................................................................................................ 3
Advisory Business - Item 4 ............................................................................................................................ 4
Fees and Compensation - Item 5 ................................................................................................................ 11
Performance-Based Fees and Side-By-Side Management - Item 6 ............................................................ 16
Types of Clients - Item 7 .............................................................................................................................. 16
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ....................................................... 16
Disciplinary Information - Item 9 ................................................................................................................ 20
Other Financial Industry Activities and Affiliations - Item 10 ..................................................................... 20
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ............... 21
Brokerage Practices - Item 12 ..................................................................................................................... 21
Review of Accounts - Item 13 ..................................................................................................................... 22
Client Referrals and Other Compensation - Item 14 .................................................................................. 23
Custody - Item 15 ........................................................................................................................................ 24
Investment Discretion - Item 16 ................................................................................................................. 25
Voting Client Securities - Item 17................................................................................................................ 25
Financial Information - Item 18 .................................................................................................................. 25
Requirements for State-Registered Advisors - Item 19 .............................................................................. 25
Miscellaneous ............................................................................................................................................. 26
Interactive Financial Advisors
Form ADV Part 2A
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Advisory Business - Item 4
Advisory Firm
Interactive Financial Advisors ("IFA") is registered as an investment adviser with United States Securities
and Exchange Commission. IFA is a corporation formed under Illinois law on February 20, 2003. We are
based in New Lenox, IL. IFA has been providing investment advisory services since 2003. OrganizAmerica
is sole owner of IFA. Richard L. Peterbok is the sole owner of OrganizAmerica.
Description of Services and Fees
Interactive Financial Advisors is a fee-only independent financial adviser. We provide money
management for the mid-market client by incorporating financial planning, investment portfolio
management, risk management and other aggregated financial services. We combine industry
experience and comprehensive research to provide quality advisory services to our clients. Currently, we
offer the following investment advisory services, which are personalized to each individual client:
• Portfolio Management Services
• Selection of Third-Party Advisors, Platforms and Programs
• Financial Planning Services
• Advisory Consulting Services
• Advisory Services to Retirement Plans
• Sub-Advisory Services
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. Also, you may see the term Investment Adviser Representative ("IAR") throughout this
Brochure. As used in this Brochure, our IARs are our firm's officers and all individuals providing
investment advice on behalf of our firm. Some of our IARs may have relationships with other firms
(please see Item 5 - Fees and Compensation).
This brochure is not a client agreement and does not create contractual obligations between IFA and its
clients. If you choose IFA as your Advisor, the relationship will be documented with a client agreement.
Portfolio Management Services
We offer portfolio management services to clients and prospective clients. The portfolio management
services are offered on a fully discretionary basis with regard to the allocation and investment
management of client assets among various asset categories such as equity securities, fixed income
securities, mutual funds and exchange traded funds.
IFA's asset allocation models range from conservative short term to aggressive long term, as well as
various specific purpose models. They are developed and managed in accordance with research and
analysis conducted by IFA. Once the client portfolio is constructed, IFA provides ongoing supervision of
the portfolio as changes in market conditions and client circumstances may require.
Working with our clients, IFA tailors investment advice to meet the needs and investment objectives of
its clients. If you retain our firm for portfolio management services, we will meet with you to determine
your investment objectives, risk tolerance, and other relevant information (the "suitability information")
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at the beginning of our advisory relationship. We will use the suitability information we gather from our
initial meeting to develop a strategy that enables our firm to tailor its advice. Through ongoing
interaction with our clients, IFA is able to give you continued focused investment advice and/or to make
investments on your behalf.
Invest With Trust
As part of our portfolio management services, our Invest With Trust service customizes an investment
portfolio for you in accordance with your risk tolerance and investing objectives. We will then allocate
and manage your assets among various asset classes. These asset classes include U.S. Equity, U.S. Fixed
Income, U.S. Government Securities, International Equity and International Fixed Income and
Alternative Investments. These allocations may change from time-to-time with the changing needs of
our clients. It is important, therefore, that our clients continue to inform us of changes in their
investment needs and objectives.
Our Invest With Trust portfolio management service includes assistance in the selection, retention, and
disposition of investment positions. We offer a product line where asset allocation models, ranging from
conservative short term to aggressive long term, are developed and managed based on our proprietary
research and analysis. The Invest With Trust service also offers various specific purpose models; that
may include, but are not limited to, bond distribution and stock distribution. Once we construct an
investment portfolio for you we monitor your portfolio's performance on an ongoing basis, and will
rebalance the portfolio as necessary.
Recommendation of Sub Advisors
As part of our overall portfolio management strategy, we will recommend sub advisors to manage all or
a portion of your account where the allocation meets the needs and investment objectives of clients. All
sub advisors recommended by our firm are registered as investment advisers or exempt from
registration requirements. These sub advisors might specialize in traditional or alternative investments.
Factors that we take into consideration when making our recommendations include, but are not limited
to, the following: the sub adviser’s performance, methods of analysis, fees, your financial needs,
investment goals, risk tolerance, and investment objectives. Once a sub advisory account has been
established, we will provide all administrative duties that are required to service your account. The sub
adviser will have little or no direct contact with you. Our responsibility to you will be to: (i) continuously
evaluate the performance of your portfolio to ensure the sub adviser selected adheres to your asset
allocation guidelines; (ii) make recommendations regarding the sub adviser as market factors and your
personal goals dictate, (iii) assume discretionary authority to hire or fire the sub adviser where such
action is deemed to be in your best interest.
At the inception of the relationship, we encourage you to complete our CARES Client Confidential
Information Organizer (questionnaire). We use this questionnaire to conduct analysis through the CARES
Process on the data we collected from you. *This analysis is designed to help to determine, the time
horizon for each client's goals, client risk tolerance, and the amount of financial commitment required
for each goal e.g. a lump sum amount or ongoing savings. On completion of the analysis, we prepare the
Making Life Better Official Report (“the Report”). We will then utilize the Report in offering to assist you
in making selections between the various asset allocation products available. Individual investment
portfolios are structured in accordance with pre-established asset allocation models in keeping within
the context of your investment perspective and acceptable degree of risk tolerance. The fee to complete
the analysis, which is separate and distinct from the portfolio management fee described below, will
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range between $48 and $7,500 depending on the scope and complexity of the client's financial
circumstances. This financial analysis fee is negotiable at the discretion of IFA.
Clients will enter into a written Financial Planning agreement which will govern the planning relationship
between the firm and the client. There are a number of different services IFA provides, and clients may
choose to take advantage of some or all of them.
For example, Clients may elect to retain IFA for portfolio management services, but forego the
preparation of the Making Life Better Official Report. The signed acknowledgment will be maintained in
the client master file. IFA images new account docs with ongoing notes and reviews retained by IAR.
We also offer our Invest With Trust portfolio management service through the use of various annuity
products. The assets within the annuity are managed through this portfolio management service. The
annuities may assist in providing protection from the potential of outliving your money.
If the client chooses the “Invest With Trust” service, the client will enter into a written investment
advisory agreement that will govern the relationship with the client and the firm.
If you participate in our discretionary portfolio management services, we require you to grant our firm
discretionary authority to manage your account. Discretionary authorization will allow our firm to
determine the specific securities and the amount of securities, to be purchased or sold for your account
without your approval prior to each transaction. Discretionary authority is typically granted by the
investment advisory agreement you sign with our firm, a power of attorney, or trading authorization
forms. If you enter into non-discretionary arrangements with our firm, we must obtain your approval
prior to executing any transactions on behalf of your account. This service also requires a written
agreement.
Upon entering into an Investment Advisory Agreement for Invest With Trust services, you will open an
account with an independent qualified custodian to hold the account assets. We currently utilize Axos
Advisor Services, (“Axos’), member FINRA/SIPC.
The Legacy Service - Mutual Fund/ETF Strategies
As part of our discretionary asset management services, we offer the Legacy Service (“Legacy”) which
utilizes mutual fund and ETF strategies.
The Legacy accounts are managed to diversify a client’s investments and will generally use mutual fund
securities but may also utilize ETFs. Other types of investments may also be recommended where the
Investment Adviser Representative(s) deem such investments appropriate based on the client’s stated
goals and objectives. Investments and allocations are determined and based upon each client’s
predefined objectives, risk tolerance, time horizon, financial horizon, financial information, and various
other suitability factors. Clients may impose restrictions on the management of the account(s). Account
restrictions and guidelines imposed by clients may affect the composition and performance of a client’s
portfolio. For these reasons, performance of the portfolio may not be identical with other clients of IFA.
On an ongoing basis, the IARs assigned to you will review your financial circumstances and investment
objectives and will make any adjustments to your portfolio as may be necessary to achieve the desired
results.
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Upon entering into an Investment Advisory Agreement, you will open an account with an independent
qualified custodian to hold the Account assets. We currently utilize Axos Advisor Services, member
FINRA/SIPC ("Axos"), an unaffiliated and independent qualified custodian and its clearing firm.
Selection of Third-Party Advisors, Platforms and Programs
IFA offers clients a variety of different investment management programs, each particularly suited to
individual needs. These programs are offered through various arrangements with third party advisors,
model providers and platform services. In order to assist clients in the selection of investment
management programs, we will typically gather information from you about your financial situation,
investment objectives, and reasonable restrictions you want imposed on the management of the
account. Your investment adviser representative will work with you to customize a portfolio that meets
these objectives. Your customized portfolio may include IFA managed models as described above, third
party advisory arrangements and/or utilization of specific model providers.
Third-Party Advisors – We have entered into agreements with various third-party investment advisors
for the provision of certain investment advisory services. Factors considered in the selection of a third-
party advisor include but may not be limited to: i) Our firm’s preference for a particular third-party
advisor; ii) the client’s risk tolerance, goals and objectives, as well as investment experience; and, iii) the
amount of client assets available for investment.
The third party advisors are registered investment advisors who offer investment advisory and
investment management programs. A complete description of the services provided, the amount of
total fees, the payment structure, termination provisions and other aspects of the third-party advisor’s
advisory business are detailed and disclosed in: i) the third-party advisor’s Form ADV Part 2A; ii) the
program wrap brochure (if applicable) or other applicable disclosure documents; iii) the disclosure
documents of the portfolio manager(s) selected; or, iv) the third-party advisor’s account opening
documents. A copy of all relevant disclosure documents of the third-party advisor and of the individual
portfolio manager(s) will be provided to anyone interested in these programs/managers. You will be
required to sign an agreement directly with recommended third party advisor(s).
Model Portfolio Selection – IFA offers model portfolio selection services which allows IFA to exercise
discretion to select model portfolios managed by IFA and third party non-affiliated investment advisors,
collectively referred to as “model providers”. We will select the model portfolio(s) that align with your
risk tolerance and investment objectives. The model providers are available to IFA through the Axos
Advisory Services platform. The platform provides IFA with discretionary authority to implement
selected model providers on your behalf. Securities transactions will be decided upon and executed by
the model provider on a discretionary basis. This means that the model provider selected will have the
ability to buy and sell securities in your account without obtaining your approval. Generally, clients may
not impose restrictions on investing in certain securities or types of securities in accounts managed by a
third-party advisor.
We will have the discretionary authority to select the model provider and the model portfolio(s) as well
as the ability to reallocate funds from or to a model provider and/or model portfolio(s). You should be
aware that there may be other model providers not recommended by our firm, that are suitable for you
and that may be less costly than arrangements recommended by our firm. No guarantees can be made
that your financial goals or objectives will be achieved through the selection of model providers or by a
recommended/selected model portfolio.
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We will periodically review reports provided to clients. We will contact clients at least annually, or more
often to review your financial situation and objectives, and, to assist you in understanding and
evaluating the services provided by a third-party advisor and/or model provider. Please notify us of any
changes in your financial situation, investment objectives, or account restrictions.
Family and Employee Access Program
We offer access to our portfolio management services to the family and employees of our Firm at a
reduced asset management fee. Family/Employee pricing for asset management services is available to
spouses, children, step-children, and guardianship relationships. Employees eligible for reduced asset
management pricing include any employees who have been employed for at least one year through our
Firm. The account requirements and fees are negotiable and will be specified in a service agreement.
Financial Planning Services
We offer goal oriented financial planning advice, which is primarily designed to supplement our portfolio
management services, as described above. Financial planning services are offered through our CARES
Client Confidential Information Organizer which will result in a Making Life Better Official Report. We
offer broad-based, modular, and consultative financial planning services to our clients and prospective
clients. We may use financial planning software to determine your current financial position and to
define and quantify your long-term goals and objectives.
Financial planning will typically involve providing a variety of advisory services to clients regarding the
management of their financial resources based upon an analysis of their individual needs. If you retain
our firm and sign the Financial Planning agreement which governs the relationship between the client
and the firm for financial planning services, we will meet with you to gather information about your
financial circumstances and objectives. We may also use financial planning software to determine your
current financial position and to define and quantify your long-term goals and objectives. Once we
specify those long-term objectives, (both financial and non-financial) we will develop shorter-term,
targeted objectives. After we review and analyze the information you provide to our firm and the data
derived from our financial planning software, we will deliver a written report to you, designed to help
you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to our firm. You must promptly notify our firm if your financial
situation, goals, objectives, or needs change.
Per the Financial Planning agreement, you are under no obligation to act on our financial planning
recommendations. Should you choose to act on any of our recommendations, you are not obligated to
implement the financial plan through our firm, our advisory representatives, or any of our other
investment advisory services. Moreover, you may act on our recommendations by placing securities
transactions with any brokerage firm.
Advisory Consulting Services
We offer Advisory Consulting services through a combination of in-house services, contracted third
party vendors and referral arrangements. These services are provided through our firm and non-
affiliated entities. This integrated suite of services is designed to complement our Making Life Better
Official Report by providing a full range of financial services and products.
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The Firm's Making Life Better Official Report development begins with a Client CARES Client Confidential
Information Organizer (questionnaire) and utilizes proprietary products and tools to analyze a client's
financial and investment goals. The process defines how the impact of one financial decision or
investment may affect the overall financial goals or objectives of the client. Through this proprietary
method, IFA is able to evaluate, prioritize and balance financial values with a client's personal situation.
The Advisory Consulting service involves the following four steps:
1. Discovery: Interactive discussion where we listen to discover what is really important to you.
Essential information will be gathered to clarify your financial objectives and what you feel
would make life better for you.
2. Analysis: Review the analysis prepared to understand your unique situation which measures and
clarifies your specific goals. This helps you determine your priorities and your appropriate
financial commitment.
3. Solutions: Based on your situation analysis and the priorities you have identified; appropriate
solutions will be presented. These solutions will provide you the best value. This will begin the
implementation stage of your plan.
4. Service: Establish a well-structured communications and service schedule of future meetings
with you as appropriate, to stay on track and make any necessary future adjustments.
Through this process additional services may be suggested, such as:
• Insurance Solutions. Life insurance evaluations and strategies, asset and liability risk analysis,
disability insurance assessments and long-term care needs.
• Education Planning. Assistance in selecting, applying, and funding options for college education.
IFA has partnered with SAGE Scholars and participates in its Tuition Rewards program.
• Advisory Services to 401k and 529 Plans. 529 Plans are national advisor-sold savings plan(s) that
give parents, grandparents, and others a tax-advantaged way to save for a child's college
education. The Savings Plans and/or 401k Plans feature flexible portfolio solutions using ETFs or
mutual funds. We will provide assistance with recommendations as to how to allocate your
investments among the ETFs/mutual funds investment choices.
Advisory Services to Retirement Plans
We offer advisory services to employee benefit plans ("Plan") and to the participants of such plans
(“Participants”). The services are designed to assist plan sponsors in meeting their management and
fiduciary obligations to Participants under the Employee Retirement Income Securities Act (“ERISA”).
Pursuant to adopted regulations of the U.S. Department of Labor under ERISA Section 408(b)(2), we are
required to provide the Plan's responsible plan fiduciary (the person who has the authority to engage us
as an investment adviser to the Plan) with a written statement of the services we provide to the Plan,
the compensation we receive for providing those services, and our status (which is described below).
The services we provide to your Plan and the corresponding compensation are described above, and in
the service agreement that you have previously signed with our firm. We may, with consent of the Plan,
and in accordance with Plan documents, bill out-of-pocket expenses (such as overnight mailings,
messenger, translation fees, etc.) at cost. We do not reasonably expect to receive any other
compensation, direct or indirect, for the services we provide to the Plan or Participants. Nonetheless,
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since Associated Persons of our firm are registered representatives of broker/dealers and/or licensed
insurance agents, these individuals may receive 12b-1 fees, revenue sharing or other forms of indirect
compensation in connection with mutual fund investments allowable under applicable authority
through Fortune Financial Services, Inc. (refer to Items 5, 10, 12 and 14 for additional disclosures). If we
receive any other compensation for such services, we will (i) offset the compensation against our stated
fees, and (ii) we will promptly disclose the amount of such compensation, the services rendered for such
compensation and the payer of such compensation to you.
In providing services to the Plan and Participants, our status is that of an investment adviser registered
under the Investment Advisers Act of 1940, and we are not subject to any disqualifications under
Section 411 of ERISA. In performing fiduciary services, we are acting either as a non-discretionary
fiduciary of the Plan as defined in Section 3(21) under ERISA, or as a discretionary fiduciary of the plan as
defined in Section 3(38) under ERISA.
Sub-Advisory Services
We offer sub-advisory services to unaffiliated, third party investment advisers and broker/dealers. As
part of these services, we will provide certain proprietary investment services called ‘Invest with Trust
Asset Management Services’. While we are responsible for the overall management of the assets
delegated to our firm, we will not communicate investment recommendations or selections directly to
the third-party investment adviser(s) and/or broker/dealer(s). Fees and payment arrangements are
negotiable and will vary on a case-by-case basis.
Types of Investments
Pursuant to the agreement you enter into with IFA, we will primarily offer advice on exchange traded
funds (ETFs) and mutual funds. We offer advice on equity securities, corporate, municipal and
government debt securities, MLPs (master limited partnerships), certificates of deposit, and variable
annuities.
Additionally, we may advise you on any type of investment that we deem appropriate based on your
stated goals and objectives. We may also provide advice on any type of investment held in your portfolio
at the inception of our advisory relationship.
Wrap Fee Programs
IFA is neither the sponsor nor portfolio manager of a wrap fee program in regard to the investment
advisory services provided directly to you through IFA.
However, most third-party money management programs are considered “wrap fee” programs in which
the client pays a specified fee for portfolio management services and trade execution. Wrap fee
programs differ from other programs in that the fee structure for wrap programs is all-inclusive,
whereas non-wrap fee programs assess trade execution costs that are in addition to the investment
advisory fees. To compare the cost of the wrap fee program with non-wrap fee portfolio management
services, you should consider the frequency of trading activity associated with investment strategies and
the brokerage commissions charged by the third-party money manager’s clearing firm or other broker-
dealers, and the advisory fees charged by other investment advisers. Please refer to the recommended
third-party money manager’s Form ADV Part 2A – Appendix 1, the Wrap Fee brochure for a complete
description of the programs and services provided, the amount of total fees, the payment structure,
termination provisions and other aspects of wrap fee program.
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Assets Under Management
As of January 31, 2025, we managed $337,782,613 in client assets on a discretionary basis and $0.00 in
client assets on a non-discretionary basis.
Fees and Compensation - Item 5
Portfolio Management Services
Our fee for portfolio management services is based on a percentage of your assets we manage and is set
forth in the following fee schedule:
Fee Schedule - Invest With Trust®
Non 403b Accounts
• Account Size $0 - $24,999
403b Accounts
• Account Size: $0 - $24,999
0.95% - 2.45% of Account Value
1.02% – 2.52% of Account Value
• Account Size $25,000 - $49,999
0.90% - 2.40% of Account Value
• Account Size: $25,000 - $49,999
0.97% – 2.47% of Account Value
• Account Size $50,000 - $249,999
0.80% - 2.30% of Account Value
• Account Size: $50,000 - $249,999
0.87% – 2.37% of Account Value
• Account Size $250,000 - $499,999
0.71% - 1.91% of Account Value
• Account Size: $250,000 - $499,999
0.72% – 1.92% of Account Value
• Account Size $500,000 - $999,999
0.62% - 1.82% of Account Value
• Account Size: $500,000 - $999,999
0.57% – 1.77% of Account Value
• Account Size $1,000,000 Plus
• Account Size: $1,000,000 +
0.42% – 1.62% of Account Value
0.50% - 1.70% of Account Value
Sub-advisory strategies are generally based on model portfolios provided by the sponsoring sub-advisor.
Certain model portfolios will only include mutual funds and/or exchange traded products that are
affiliated with the sub-advisor and which pay fees and other compensation to the sub-advisor and its
affiliates. Therefore, the sub-advisor and its affiliates will receive compensation in connection with the
management of the affiliated mutual funds and exchange traded products (Funds) included in these
model portfolios. Because the sub-advisor and its affiliates are compensated through the use of the sub-
advisor’s sponsored Funds, the account level management fee for these model portfolios is waived.
Therefore, we have an incentive to recommend these model portfolios over other model portfolios
where we have a less favorable compensation arrangement. Clients are not required to use the services
of any sub-advisor model portfolio or strategy recommended by us.
Certain strategies will have minimum account size requirements ranging from $2,000 to $25,000.
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Account Services Fees
An account service fee is charged to each account in the above strategies based on the daily average
balance for the prior quarter. Accounts $24,999.99 and under will be charged $10 per quarter. Accounts
$25,000 or more will be charged $18.75 per quarter. These fees are prorated and charged monthly
Account size may start at $0 when systematic contributions are elected; otherwise, account minimum is
$1,000.
The Legacy Service
The portfolio management fee for the Legacy service is based on a percentage of the assets we manage.
The Legacy fee pertains only to assets managed within the Legacy service and is set forth in the
following fee schedule:
Fee Schedule – The Legacy Service
• Account Size $1,000 - $24,999*
1.35% of Account Value
• Account Size $25,000 - $49,999
1.30% of Account Value
• Account Size $50,000 - $249,999
1.25% of Account Value
• Account Size $250,000 - $499,999
1.21% of Account Value
• Account Size $500,000 +
1.00% of Account Value
*The Mutual Fund strategies have a minimum account size requirement of $1,000. Each account will be
charged a $12.50 per quarter service fee, which is prorated and charged monthly.
Portfolio Management Terms
Our portfolio management fees are calculated on a monthly basis based on the client’s daily average
account balance for the preceding month at 1/12th of the account’s predetermined annual fee rate.
Portfolio management fees are paid in advance and will be deducted automatically from client's account
monthly until the Agreement is terminated.
For 401K and/or 403b accounts our annual portfolio management fee is billed and payable either
monthly or quarterly in advance or in arrears and based upon either market value of account or the
average daily balance depending upon the agreement you signed with us. The scope of these services,
the fees, and the terms of the agreement for these services will be negotiated on a case-by-case basis
with each Sponsor.
If the Investment Advisory Agreement is executed at any time other than the first day of a calendar
month, our fees will apply on a pro rata basis, which means that the advisory fee is payable in
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proportion to the number of days in the month for which you are a client. Our advisory fee is negotiable
for the Invest With Trust services, depending on individual client circumstances. The Legacy service fee
is not negotiable.
Householding of Axos Accounts
Our practice is to seek to combine the values of accounts custodied at Axos for family members living in
the same household to determine the applicable advisory fee. For example, we may combine account
values for you and your minor children, joint accounts with your spouse, and other types of related
accounts. Householding is determined by primary account Tax Identification Number and then by
address. Combining account values may increase the asset total, which may result in your paying a
reduced advisory fee based on the available breakpoints in our fee schedule stated above.
As paying agent for our firm, Axos will deduct the investment advisory fee directly from your account.
The fee is deducted only when you have given us written authorization permitting the fees to be paid
directly from your account. If insufficient cash is available to pay such fees, securities in an amount equal
to the balance of unpaid fees will be liquidated to pay for the unpaid balance. Further, the qualified
custodian will deliver an account statement to you at least quarterly. These account statements will
show all disbursements from your account. You should review all statements for accuracy. We will also
receive a duplicate copy of your account statements. We encourage you to reconcile our invoices with
the statement(s) you receive from the qualified custodian. If you find any inconsistent information
between our invoice and the statement(s) you receive from the qualified custodian please call our main
office number located on the cover page of this brochure.
You may terminate the Investment Advisory Agreement upon a 30 day notification to our firm. We are
compensated monthly in advance and you are required to give us a 30 day notification to terminate the
Agreement.
Upon termination of accounts held at Axos, the custodian will deliver securities and funds held in the
account as instructed by client, unless client requests that the account be liquidated. After the
Agreement has been terminated, transactions are processed at the prevailing brokerage rates. You are
then responsible for monitoring your own assets and IFA has no further obligation to act or provide
advice with respect to those assets.
Selection of Third-Party Advisors, Platforms and Programs
We will share in the fee paid to the third-party advisor. The management fee is disclosed in the third-
party advisor’s disclosure documents. These fees may or may not be negotiable. Our compensation may
differ depending upon our individual agreement with each third-party advisor. As such, we have an
incentive to recommend one third-party advisor over another third-party advisor with whom we have a
less favorable compensation arrangement or other advisory programs offered by third-party advisors
with which we have no compensation arrangements. Clients are not required to use the services of any
third-party advisor recommended by us.
In some arrangements you will be required to sign an agreement directly with the recommended third
party advisor(s). You may terminate your advisory relationship with the third party advisor according to
the terms of your agreement with the third party advisor. You should review each third party advisor's
disclosure brochure for specific information on how you may terminate your advisory relationship with
the advisor and how you may receive a refund, if applicable. You should contact the third party advisor
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directly for questions regarding your advisory agreement with the third party advisor.
Financial Planning Services
We charge a fixed fee for financial planning services, which generally ranges from $48 to $7,500. The fee
is negotiable depending upon the complexity and scope of the plan, your financial situation, and your
objectives. Fixed fee financial planning services are not continuous advisory services, and electing our
financial planning services only does not create a portfolio management relationship between you and
our firm.
If you request specific consulting services and do not desire a written financial plan, we offer modular
financial planning or general consulting services on an hourly basis. Our rate for such services ranges
from $100 to $400 per hour. This rate is negotiable depending on the scope and complexity of the plan,
your financial situation, and your objectives. An estimate of the total time/cost will be determined at the
start of the advisory relationship. In limited circumstances, the cost/time could potentially exceed the
initial estimate. In such cases, we will notify you in advance and request that you approve the additional
fee.
We require that you pay 100% of the fee in advance for a full financial plan. We will not require
prepayment of a fee more than six months in advance and in excess of $1,200. Hourly based financial
planning/consulting-based fees are calculated and payable at the completion of each session. In some
cases, the hourly fees may be paid weekly, monthly or periodically in arrears.
You may terminate the financial planning agreement by providing written notice to our firm. You will
incur a pro rata charge for services rendered prior to the termination of the agreement. If you have pre-
paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees.
As a normal extension of financial advice, we provide education or recommendations related to the
rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several
options. Each choice offers advantages and disadvantages, depending on desired investment options
and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment,
and the investor's unique financial needs and retirement plans. The complexity of these choices may
lead an investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement
Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in
the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA.
In most cases, fees and expenses will increase to the investor as a result because the above-described
fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these
assets.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice
to you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best
interests and not put our interest ahead of yours. At the same time, the way we make money creates
some conflicts with your interests.
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Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
traded funds (described in each fund's prospectus) to their shareholders. These fees will generally
include a management fee and other fund expenses.
You will also incur transaction charges and/or brokerage fees when purchasing or selling securities.
These charges and fees are typically imposed by the broker-dealer or custodian through whom your
account transactions are executed. The broker-dealer or custodian may also charge your account for
custodial fees, retirement account fees, trust fees, exchange fees, redemption fees that may be assessed
on mutual fund shares, transfer fees, account termination fees or other special service fees and charges.
We do not share in any portion of the brokerage fees/transaction charges/administrative fees imposed
by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all
the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our
brokerage practices, please refer to the "Brokerage Practices" section of this Disclosure Brochure.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact
investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result,
the Associated Person servicing your account may charge more or less for the same service than another
Associated Person of our firm. Further, our annual investment management fee may be higher than that
charged by other investment advisors offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly,
unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds,
etc.) are included as part of assets under management for purposes of calculating the firm’s advisory
fee. At any specific point in time, depending upon perceived or anticipated market conditions/events
(there being no guarantee that such anticipated market conditions/events will occur), the firm may
maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets
are maintained in cash or cash equivalents, such amounts could miss market advances and, depending
upon current yields, at any point in time, the firm’s advisory fee could exceed the interest paid by the
client’s cash or cash equivalent positions.
Compensation for the Sale of Securities or Other Investment Products
IARs providing investment advice on behalf of our firm may be registered representatives with Fortune
Financial Services, Inc. ("Fortune"), a securities broker/dealer and member of the Financial Industry
Regulatory Authority and the Securities Investor Protection Corporation. However, not all of our IARs
are also registered representatives with a broker-dealer.
In their capacity as registered representatives, the IARs who are registered representatives will receive
commission-based compensation in connection with the purchase and sale of securities, including 12b-1
fees for the sale of investment company products through their broker-dealer. Compensation earned by
these IARs in their capacity as a registered representative is separate and in addition to our advisory
fees. This practice presents a conflict of interest because IARs providing investment advice on behalf of
our firm who are registered representatives have an incentive to effect securities transactions for the
purpose of generating commissions rather than solely based on your needs. However, you are under no
obligation, contractually or otherwise, to purchase securities products through any Associated Person
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affiliated with our firm.
IARs providing investment advice on behalf of our firm may be licensed as independent insurance
agents. These IARs will earn commission-based compensation for selling insurance products, including
insurance products they sell to you. Insurance commissions earned by these IARs are separate and in
addition to our advisory fees. This practice presents a conflict of interest because persons providing
investment advice on behalf of our firm who are insurance agents have an incentive to recommend
insurance products to you for the purpose of generating commissions rather than solely based on your
needs. However, you are under no obligation, contractually or otherwise, to purchase insurance
products through any Associated Person affiliated with our firm. Not all of our IARs are also insurance
agents.
Any material conflicts of interest between you and our firm, or our IARs are disclosed in this Disclosure
Brochure. If at any time, additional material conflicts of interest develop, we will provide you with
written notification of the material conflicts of interest or an updated Disclosure Brochure.
Performance-Based Fees and Side-By-Side Management - Item 6
We do not accept performance-based fees or participate in side-by-side management. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees
while at the same time managing accounts that are not charged performance-based fees. Performance-
based fees are fees that are based on a share of capital gains or capital appreciation of a client's
account. Our fees are calculated as described in the Advisory Business section above, and are not
charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your
advisory account.
Types of Clients - Item 7
We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates,
and charitable organizations.
In general, we require a minimum of $1,000 to open and maintain an Invest with Trust or a Legacy
advisory account. At our discretion, we may waive this minimum account size, such as when an account
is set up for systematic contributions. Additionally, we charge an ongoing service fee for accounts
invested in our Invest with Trust service. For accounts with a valuation of $24,999 and under will be
charged $10 per quarter. For accounts with a valuation of $25,000 and higher will be charged $18.75 per
quarter. For each account in our Legacy program a $12.50 quarterly charge will be applied. The service
fee is prorated and collected monthly.
Certain strategies will have minimum account size requirements ranging from $2,000 to $25,000.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
We use a fundamental method of analysis and Modern Portfolio Theory as our core investment
strategies.
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Modern Portfolio Theory is a sophisticated investment decision approach that theoretically permits an
investor to classify, estimate, and control both the kind and the amount of expected risk and return.
IFA utilizes a computerized analytical tool such as TIFIN Wealth Risk that account for risk in quantitative
analysis and decision making. TIFIN Wealth Risk provide a risk profile for investors and their portfolios,
as well as a range of possible outcomes and the probabilities that may occur for any choice of action. It
shows the extreme possibilities—the outcomes of choosing aggressively and conservatively—along with
all possible consequences for middle-of-the-road decisions.
Our investment strategies and advice may vary depending upon each client's specific financial situation.
As such, we determine investments and allocations based upon your predefined objectives, risk
tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
We may use short-term trading (in general, selling securities within 30 days of purchasing the same
securities) as an investment strategy when managing your account(s). Short-term trading is not a
fundamental part of our overall investment strategy, but we may use this strategy occasionally when we
determine that it is suitable given your stated investment objectives and tolerance for risk.
Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the
management of your assets. Regardless of your account size or any other factors, we strongly
recommend that you continuously consult with a tax professional prior to and throughout the investing
of your assets. We do not offer tax advice.
Moreover, as a result of revised IRS regulations, custodians and broker-dealers report the cost basis of
equities acquired in client accounts. Our firm uses the FIFO accounting method for calculating the cost
basis of your investments. You are responsible for contacting your tax advisor to determine if this
accounting method is the right choice for you. If your tax advisor believes another accounting method is
more advantageous, please provide written notice to our firm immediately and we will alert your
account custodian of your individually selected accounting method. Please note that decisions about
cost basis accounting methods will need to be made before trades settle, as the cost basis method
cannot be changed after settlement.
Risk of Loss
Investing in securities involves risk of loss. You should be prepared to bear the risk of financial losses.
We do not represent or guarantee that our services or methods of analysis can or will predict future
results, successfully identify market tops or bottoms, or insulate clients from losses due to market
corrections or declines. We cannot offer any guarantees or promises that your financial goals and
objectives will be met. Past performance is in no way an indication of future performance.
Recommendation of Particular Types of Securities
In our Invest with Trust service we primarily recommend exchange traded funds ("ETFs"). For our Legacy
service we primarily recommend mutual funds. You should be advised of the following risks when
investing in these types of securities:
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Characterization Risk
ETFs and mutual funds don't always hold the types of stocks or bonds you may expect. For instance,
some sector funds may identify the entire sector yet only represent a portion of the sector. At the same
time, similar sector funds may have very different percentages of components. These characterization
risks can impact overall performance.
Tracking Error Risk
ETFs and mutual funds, do not always track the index they are designed to mimic. Often two funds
tracking the same index may take two different approaches to tracking the same index. One fund may
use full replication, meaning the fund buys every stock in the index in exactly the right weights. Another
fund may use optimization, whereby computer algorithms select a subset of the broader index to track
the index as a whole. In general, funds that optimize have a greater risk of tracking error than funds that
fully replicate their index.
Liquidity Risk
ETFs and mutual funds are not always easily bought and sold. Liquidity risk is the risk stemming from the
lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or
minimize a loss.
Spreads Risk
ETFs are purchased and sold like stocks and, therefore, have bid and ask spreads. The average bid/ask
spreads on every ETF is directly correlated to the fund's size, trading liquidity and average spread. Most
ETFs have spreads of less than 10 basis points; however, thinly traded ETFs may have spreads greater
than 50 basis points. The spreads risk of a thinly traded ETF and/or a volatile market may result in
increased transaction costs.
Inverse ETFs Risk
Inverse ETFs are designed to replicate the opposite direction of market indices, often at a multiple which
may include the use of leverage. These ETFs often use a combination of futures, swaps, short sales, and
other derivatives to achieve these objectives. Most inverse ETFs are designed to achieve these results on
a daily basis only. This means that over periods longer than a trading day, the value of these ETFs can
and usually do deviate from the performance of the index they are designed to track. Over longer
periods of time or in situations of high volatility, these deviations can be substantial.
Manager Risk
The risk of the chance that poor security selection or focus on securities in a particular asset class,
sector, category, or group of companies will cause a client’s portfolio to underperform relevant
benchmarks.
Direct Indexing
Direct indexing strategies seek to replicate the performance of a market index by directly holding the
individual securities, or a representative sample of the individual securities, that make up the index.
Direct indexing can provide a more tax efficient means of investing, and allows for more customized
investment allocations, than investing in a fund or other commingled product that seeks to replicate the
index. The potential benefits of direct indexing, however, will not necessarily be realized if a client does
not take advantage of tax planning or impose account restrictions, such as account level security or
sector-based restrictions or customizations based on specific tax, Environmental, Social, and Governance
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or other preferences. Fees and expenses for the direct indexing strategy in some cases will be higher
than the fees and expenses associated with alternative index products. Higher fees and expenses could
adversely impact account performance. The size of the account and the number of securities in the
index the account seeks to replicate also limit the ability of the account to replicate the index. As a
result, the direct indexing strategy introduces the risk of tracking error relative to the index and can
cause a portfolio to underperform the index, including as a result of customization.
Securities Backed Lines of Credit (SBLOCs)
SBLOCs are non-purpose loans where you pledge assets in your account as collateral in return for a loan.
The loan proceeds can be used for purposes other than to purchase or trade securities. Depending on
your objectives, we can help you apply for a SBLOC. This can be a strategic alternative to liquidating
assets to pay for unexpected expenses, a business opportunity, or a personal goal, any of which could
trigger capital gain taxes. While we do not receive a fee for arranging these loans, our assistance in this
process presents a conflict of interest, as we have an incentive for you to maintain these assets in your
account instead of liquidating them, as liquidation could decrease the asset-based fees that we earn for
managing your account. To address this conflict, we only make recommendations to obtain such loans
when we believe obtaining a SBLOC is in the best interests of clients. Clients should note that they retain
the ultimate decision to obtain such loans. The following are some of the primary risks associated with
obtaining a SBLOC:
Interest rate payments on the principal balance of the loan are not fixed and may increase;
If the value of the securities pledged as collateral decrease, you will be liable for any deficiency;
•
•
• The lender can force the sale or liquidation of securities held as collateral without contacting
you in advance to meet collateral requirements and you are not entitled to choose which
securities are liquidated or sold;
• You are only entitled to draw on the line to the extent there is credit availability; and
• There may be additional risks when money funds or similar investments may produce less
interest income or other yield than the interest you are paying on the loan.
We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or
non-purpose loan. While we can assist in the application process, we are not involved in the approval
process.
Political Risk
Each administration presents its own set of policy risks that could impact investors. One of the policy
tools that an administration can implement is the imposition of tariffs, or the threats thereof. The scope,
implementation, and duration of tariffs can create uncertainty domestically and globally. Industries that
rely on imported raw material or that have heavily integrated cross-border manufacturing practices may
be most impacted by the imposition of tariffs. However, it is challenging to predict the impact of actual
and/or threatened tariffs and impossible to predict future policy decisions. When tariffs are imposed,
there is also a higher probability that retaliatory tariffs could be imposed, which could further impact
industries and products. Tariffs in general can also permanently alter global supply chains and have far-
reaching indirect impacts. Tariffs can hurt economic growth and add to inflation, which can lead to rising
interest rates.
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Artificial Intelligence ("AI") Risk
We may rely on programs and systems that utilize AI, machine learning, probabilistic modeling, and
other data science technologies ("AI Tools") when delivering our services. AI Tools are also used to
record and transcribe client meetings. Clients should note that AI Tools are highly complex, and are
known to have been flawed, hallucinate, reflect biases included in the data on which such tools are
trained, be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk. The U.S. and
global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving,
and could require changes in the firm’s implementation of AI Tools and increase compliance costs and
the risk of non-compliance. Further, the firm may rely on AI Tools developed by third parties, and the
firm has limited control over the accuracy and completeness of such AI Tools. Clients who do not want
us to record their meetings have the option to opt out at the time of the meeting.
Disciplinary Information - Item 9
Interactive Financial Advisers has been registered and providing investment advisory services since
2003. There are no legal or disciplinary events that are material to the evaluation of our advisory
business or the integrity of our management.
Other Financial Industry Activities and Affiliations - Item 10
Registrations with Broker-Dealer
IARs of IFA may be registered representatives offering securities through Fortune Financial Services, Inc.
("Fortune; an unaffiliated securities broker-dealer and member of the Financial Industry Regulatory
Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). However, not all of our
IARs are also registered representatives of a broker-dealer.
IFA's clients are advised that they have total freedom to implement recommendations through any
broker-dealer of their choosing. If the client implements recommendations made by IFA by purchasing
securities or other products through Fortune, the representative will receive additional compensation in
the form of commissions, including 12b-1 fees for the sale of investment company products.
Arrangements with Affiliated Entities
We are wholly owned by OrganizAmerica, a holding company. Richard L. Peterbok, Chief Executive
Officer of Interactive Financial Advisors is the sole owner of OrganizAmerica.
OrganizAmerica also owns Rightway Life, Inc. (RWL), a life insurance distributor that sells life insurance
products to mid-market consumers. Associated Persons of IFA, who are separately licensed as insurance
agents, can effect transactions in various life insurance products and earn commissions for these
activities. Clients are instructed that the fees paid to the firm for advisory services are separate and
distinct from the commissions earned for placing client(s) in insurance products. The sale of insurance
instruments and other commissionable products offered by Associated Persons are intended to
complement IFA’s advisory services. However, a conflict of interest exists due to the potential receipt of
dual forms of compensation. Clients to whom the firm offers advisory services are informed that they
are under no obligation to use RWL for insurance services and may use the insurance brokerage firm
and agent of their choice.
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Recommendation of Other Advisers
We may recommend that you use a third-party money manager ("MM") based on your needs and
suitability. We will receive compensation from the MM for recommending that you use their services.
These compensation arrangements present a conflict of interest because we have a financial incentive
to recommend the services of the third-party money manager. You are not obligated, contractually or
otherwise, to use the services of any MM we recommend.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code
of Ethics includes guidelines for professional standards of conduct for our IARs. Our goal is to protect
your interests at all times and to demonstrate our commitment to our fiduciary duties of honesty, good
faith, and fair dealing with you. All of our IARs are expected to adhere strictly to these guidelines. Our
Code of Ethics also requires that certain persons associated with our firm submit reports of their
personal account holdings and transactions to a qualified representative of our firm who will review
these reports on a periodic basis. Persons associated with our firm are also required to report any
violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably
designed to prevent the misuse or dissemination of material, non-public information about you or your
account holdings by persons associated with our firm.
Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by
contacting Richard Peterbok at rick@swcares.com.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to
you or securities in which you are already invested. A conflict of interest exists in such cases because we
have the ability to trade ahead of you and potentially receive more favorable prices than you will
receive. To eliminate this conflict of interest, it is our policy that neither our firm nor our associated
persons shall have priority over your account in the purchase or sale of securities.
Brokerage Practices - Item 12
We maintain relationships with a limited number of broker-dealers. While you are free to choose any
broker-dealer or other service provider, we recommend that you establish an account with a brokerage
firm with which we have an existing relationship. Such relationships may include benefits provided to
our firm, including but not limited to, research, market information, administrative services that help
our firm manage your account(s) and financial support of advisor educational meetings. We believe the
recommended broker-dealers provide quality execution services for our clients at competitive prices.
Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the
brokerage services provided by recommended broker-dealers, including the value of provided research,
the firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and
our firm. In recognition of the value of research services and additional brokerage products and services
the recommended broker-dealers provide, you may pay higher commissions and/or trading costs than
those that may be available elsewhere.
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Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for using the referring broker-
dealer's execution, clearing or custodial services.
Directed Brokerage
We require our Invest With Trust and Legacy Service(s) clients to direct us to execute transactions and
custody investment assets through facilities of Axos Advisor Services ("Axos"), member FINRA and SIPC.
IARs providing investment advice on behalf of our firm who are also registered representatives of
Fortune, will recommend Fortune to you for brokerage services. These individuals are subject to
applicable rules that restrict them from conducting securities transactions away from Fortune unless
Fortune provides the registered representative with written authorization to do so. Therefore, these
individuals are generally limited to conducting securities transactions through Fortune. It may be the
case that Fortune charges higher transaction costs and/or custodial fees than another broker charges for
the same types of services. If transactions are executed though Fortune these individuals (in their
separate capacities as registered representatives of Fortune) may earn commission-based compensation
as result of placing the recommended securities transactions through Fortune. This practice presents a
conflict of interest because these registered representatives have an incentive to effect securities
transactions for the purpose of generating commissions rather than solely based on your needs. You
may utilize the broker-dealer of your choice and have no obligation to purchase or sell securities
through such broker as we recommend. However, if you do not use Fortune we may not be able to
accept your account. Please see the "Fees and Compensation" section in this Brochure for more
information on the compensation received by registered representatives who are affiliated with our
firm.
Block Trades
We combine multiple orders for shares of the same securities purchased or sold for the Invest With
Trust advisory accounts we manage. This practice is commonly referred to as "block trading". We will
then distribute the shares to participating accounts in a fair and equitable manner. The distribution of
the shares purchased is typically proportionate to the size of the account, but it is not based on account
performance or the amount or structure of management fees. Subject to our discretion regarding
factual and market conditions, when we combine orders, each participating account pays an average
price per share for all transactions and pays a proportionate share of all transaction costs. Accounts
owned by our firm or persons associated with our firm may participate in block trading with your
accounts; however, they will not be given preferential treatment.
Review of Accounts - Item 13
Richard L. Peterbok, Chief Executive Officer and Chief Compliance Officer, of Interactive Financial
Advisors will monitor the models and strategies on an ongoing basis. Account reviews are performed by
the client’s Advisory Representative at least once annually. The Chief Compliance Officer and other
designated compliance staff oversee the process and provide supervisory review.
We will notify you in writing to contact us or the Representative if there have been changes in your
financial situation or investment objectives, or if you wish to impose or modify any reasonable account
restrictions for a Legacy account. Such notification shall occur at least annually.
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Our reviews ensure that the advisory services provided to you and/or the portfolio mix of your portfolio
is consistent with your investment needs and objectives. Additional reviews may be conducted based on
various circumstances, including, but not limited to:
• state of the economic markets
• changes in the clients' financial situation
• tax considerations
• upon your request
We do not provide you with additional or regular written reports in conjunction with account reviews.
You will receive trade confirmations and monthly or quarterly statements from your account
custodian(s).
For our financial planning clients, we recommend, at a minimum, an annual review of your progress with
the financial plan. We will provide our financial planning clients with updates to their financial plan,
when appropriate, based on and in accordance with a review of the plan.
For accounts managed through sub-advisory services the Representative responsible for your account
will, at least annually, review the performance and suitability of the account(s). The Representative will
review your objectives and suitability needs and determine whether you would be better suited to a
different service or other non-advisory investment. Your Representative will be responsible for
communicating and documenting recommendations to you.
Client Referrals and Other Compensation - Item 14
As disclosed under the "Fees and Compensation" section in this Brochure, persons providing investment
advice on behalf of our firm may also be licensed insurance agents, and may also be registered
representatives with Fortune Financial Services, Inc. ("Fortune"), a securities broker-dealer and member
of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. For
information on the conflicts of interest this presents, and how we address these conflicts, please refer to
the "Fees and Compensation" section of this Brochure. However, not all of our IARs are also registered
representatives and/or insurance agents.
As described in Item 12 above, we receive economic benefits from our custodial broker dealer in the
form of support products and services they make available to us and other independent investment
advisors whose clients maintain their accounts at these custodial broker dealers. The availability of
custodial products and services is not dependent upon or based on the specific investment advice we
provide our clients, such as buying or selling specific securities or specific types of securities for our
clients. The products and services provided by the custodial broker dealer, how they benefit us, and the
related conflicts of interest are described above (see Item 12 – Brokerage Practices).
Independent Contractor Compensation:
We have entered into contractual arrangements with our Investment Adviser Representatives, who are
independent contractors. Representatives of Interactive Financial Advisors receive compensation from
our firm for the recruitment of new Investment Adviser Representatives and their establishment of a
relationship with our firm. Recruitment compensation of the referring Representative ranges between
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Form ADV Part 2A
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0.05% and 0.25% of the client assets of each referred Representative that becomes an IAR of IFA. The
recruitment based compensation level will depend upon circumstances and management activities.
Representatives may also receive additional benefits including subsidized travel expenses and cash
bonuses to be used for the reimbursement of expenses related to our Annual Conference. Such
Agreements will comply with the requirements as set forth in Rule 206(4)-3 of the Investment Advisers
Act of 1940, and/or applicable state statutes, to the extent they apply. Under these arrangements, the
client does not pay higher fees than IFA's normal/typical advisory fees.
Referral Programs
We may receive recruitment referrals of new Investment Adviser Representatives through Agreements
with Fortune Financial Services, Inc. ("Fortune"), a securities broker/dealer and member of the Financial
Industry Regulatory Authority and the Securities Investor Protection Corporation.
We will pay Fortune a recruitment referral fee ranging from 0.00% to 0.10% of client assets generated
from the accounts opened through this program. The client accounts opened through this recruitment
program will not be charged any additional fees or costs in excess of our standard fee schedule.
Representatives referred to our firm must comply with the requirements of the jurisdictions where they
operate. Representatives under this arrangement have a financial incentive to recommend our firm for
advisory services. This creates a conflict of interest; however, clients are not obligated to retain our firm
for advisory services. Comparable services and/or lower fees may be available through other firms.
Ramsey Solutions –SmartVestor™
We have entered into an advertising and endorsement agreement with Ramsey Solutions (“RS”)
whereby in exchange for a flat monthly marketing fee RS provides online advertising services and refers
potential clients to IFA advisors. The services include advertising space on RS’s web-based
SmartVestor™, client referrals based on particular geographic markets, use of the SmartVestor™ marks
in advertising, and the provision of other marketing materials. Potential clients using the SmartVestor™
site may request that an advisor associated with SmartVestor contact the client. RS SmartVestor screens
the requests and, based upon geographic proximity, provides potential clients with contact information
on SmartVestor advisors. SmartVestor advisors also receive contact information on the potential clients.
No guarantees of performance or success are offered.
Custody - Item 15
Axos Advisor Services, the qualified custodian used in our Invest With Trust and Legacy portfolio
management services will calculate and directly debit your account(s) for the payment of our advisory
fees. The ability to deduct our advisory fees from your accounts causes our firm to exercise limited
custody over your funds and/or securities. We do not have physical custody of any of your funds and/or
securities. Your funds and securities will be held with Axos Advisor Services. You will receive account
statements from these independent, qualified custodian(s) holding your funds and securities at least
quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees
deducted from your account(s) each billing period. You should carefully review account statements for
accuracy.
If you have a question regarding your account statement or if you did not receive a statement from your
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custodian, please contact us at 630-472-1300.
Investment Discretion - Item 16
Before we can take discretionary authority over the decisions to buy or sell securities on your behalf,
you must first sign our discretionary management agreement. By signing our discretionary management
agreement, you are granting our firm the limited right to make certain investment decisions on your
behalf.
Discretionary
You may grant our firm discretion over the selection and amount of securities to be purchased or sold
for your account(s) without obtaining your consent or approval prior to each transaction. You may
specify investment objectives, guidelines, and/or impose certain conditions or investment parameters
for your account(s). For example, you may specify that the investment in any particular stock or industry
should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions
of transactions in the securities of a specific industry or security. Please refer to the "Advisory Business"
section in this Brochure for more information on our discretionary management services.
Voting Client Securities - Item 17
Proxy Voting
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common
stock or mutual funds, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the
event we receive any written or electronic proxy materials specific to your account(s), we will forward
them directly to you by mail. The sole exception exists where you have authorized our firm to contact
you by electronic mail, in which case, we would forward any electronic solicitation to you to vote
proxies.
Financial Information - Item 18
We are not required to provide financial information to our clients because we do not:
• require the prepayment of more than $1,200 in fees and six or more months in advance, or
• take custody of client funds or securities, or
• have a financial condition that is reasonably likely to impair our ability to meet our
commitments to you.
Requirements for State-Registered Advisors - Item 19
We are a federally registered investment adviser; therefore, we are not required to respond to this item.
Interactive Financial Advisors
Form ADV Part 2A
Page 26
Miscellaneous
Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any non-public personal information about you to any non-affiliated third parties,
except as permitted by law. In the course of servicing your account, we may share some information
with our service providers, such as transfer agents, custodians, broker-dealers, accountants, consultants,
and attorneys.
We restrict internal access to non-public personal information about you to employees, who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your non-public personal information and to
ensure our integrity and confidentiality. We will not sell information about you or your accounts to
anyone. We do not share your information unless it is required to process a transaction, at your request,
or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with
our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis.
Please contact Richard Peterbok at 630-472-1300 or via email at rick@swcares.com if you have any
questions regarding this policy.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position
it should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. The
gains and losses may be reconciled within IFA’s custodian firm account and IFA or the custodian may
retain the net gains and losses.