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hItem 1 – Cover Page
Register Financial Advisors, LLC
3500 Lenox Road, Suite 1700
Atlanta, GA 30326
Phone: (404) 364-2180
Fax: (404) 364-2182
www.registerfinancial.com
CRD# 143884
February 12, 2026
This Brochure provides information about the qualifications and business practices of Register
Financial Advisors, LLC. If you have any questions about the contents of this Brochure, please
contact us at (404) 364-2180. The information in this Brochure has not been approved or verified
by the United States Securities and Exchange Commission or any state securities authority.
Register Financial Advisors, LLC is a Registered Investment Adviser. Registration as an Investment
Adviser does not imply any level of skill or training. This Brochure is designed to provide
information that can be used to make a determination to hire or retain an Investment Adviser.
Additional information about Register Financial Advisors, LLC is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2 – Material Changes
Since our last annual update dated February 13, 2025, there have been no material changes to this Brochure
Our Brochure may be requested by contacting us at our main number. Additional information about Register
Financial Advisors, LLC is available via the SEC’s website, www.adviserinfo.sec.gov. The SEC’s website also
provides information about persons affiliated with Register Financial Advisors, LLC, who are registered or
are required to be registered as investment advisor representatives of Register Financial Advisors, LLC.
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Item 3 - Table of Contents
hItem 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 ............................................................................................................................ 10
Item 10 – Other Financial Industry Activities and Affiliations ................................................................................. 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................... 11
Item 12 – Brokerage Practices ................................................................................................................................. 11
Item 13 – Review of Accounts ................................................................................................................................. 13
Item 14 – Client Referrals and Other Compensation .............................................................................................. 14
Item 15 – Custody .................................................................................................................................................... 14
Item 16 – Investment Discretion ............................................................................................................................. 14
Item 17 – Voting Client Securities ........................................................................................................................... 14
Item 18 – Financial Information .............................................................................................................................. 14
Privacy Policy ........................................................................................................................................................... 15
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Item 4 – Advisory Business
Register Financial Advisors, LLC (“Register Financial” or “RFA”) was established in 2006 and approved as a
Registered Investment Adviser in May of 2007. George Register is CEO and principal owner of Register
Financial Advisors, LLC. Scott Register is Chief Compliance Officer.
For its investment advisory clients, the firm presently offers the following types of advisory services:
Register Financial Investment Management (RFIM)
Register Financial Retirement Plan Consulting
Edelman Turnkey Asset Management Program (TAMP)
I.
II.
III.
IV. Wrap Fee Programs
V.
Financial Planning Consulting Services
I. Register Financial Investment Management (RFIM)
Under the Register Financial Investment Management Program (“RFIM”), Investment Advisors manage
money for Clients on a non-wrap fee basis (see below for wrap-fee option) using investment vehicles suitable
for the Client, including equities, mutual funds, exchange-traded funds, options, and bonds. Through RFIM,
investment adviser representatives of Register Financial provide investment advisory services to Client
Accounts on a discretionary or non-discretionary basis. RFIM Investment Advisors manage portfolios based
on a Client’s investment objectives. RFIM also monitors and reports portfolio performance to Clients on a
periodic basis. Portfolios can include long and short-term purchases of securities, depending on the Client’s
objectives. In special circumstances, Account management may also include margin transactions, options
strategies, or short sale transactions.
II. Register Financial Retirement Plan Consulting
The firm provides non-discretionary Retirement Plan Consulting Services that include one or more of the
following services:
• Review of existing portfolio investments
• Assisting in the development of an Investment Policy Statement
• Mutual Fund Search and Recommendation
• Diversification Review
• Fund Analysis Reports
• Vendor cost analysis and vendor searches
• Plan design and/or plan document reviews
• Assistance with and design of employee education and communications strategies
III. Edelman Turnkey Asset Management Program (“TAMP”)
The TAMP is an investment management program sponsored by Financial Engines Advisors L.L.C. (also known
as Edelman Financial Engines or “EFE”) as a third-party investment manager to manage Client assets based on
style, capitalization levels, or asset classes suitable for a Client’s investment objectives. The Client will
provide Adviser with the information set forth on the Client Profile and represents that such information is
a complete and accurate representation of the Client’s financial position and investment needs, goals, and
objectives, as well as any reasonable restrictions placed on investments made in the Account at the time the
Client enters the TAMP. The Client must promptly inform Register Financial in writing if any financial
information becomes incomplete or inaccurate during the term of the TAMP relationship. TAMP Investment
Advisors manage portfolios based on a Client’s investment objectives. Clients invested through TAMP will
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receive a copy of EFE’s Wrap Fee Program Brochure and are encouraged to review it for more information
about EFE’s practices.
IV. Wrap Fee Programs
Register Financial makes available to its Clients the following investment advisory wrap fee programs (the
“Programs”), sponsored by Wells Fargo Clearing Services, LLC and Register Financial. The Programs provide
investment advice, brokerage, and custodial services under a “wrap fee” arrangement. Generally, in a wrap
fee arrangement, the Account pays a combined fee for investment advice, brokerage services, clearance and
settlement services, and custodial services. The Account may also be charged for expenses or services not
covered by the wrap fee; these will be described in the Program’s separate “Wrap Brochure” provided to the
client or in the client’s separate agreement with Wells Fargo Clearing Services, LLC. In a non-wrap account,
the Client will pay a separate fee for advice in addition to brokerage services, clearance and settlement
services, and custodial services.
Register Financial offers the following Programs sponsored by WFCS. Clients should be aware that the
available Programs may be changed, canceled, or revised anytime.
• Personalized UMA Program
o Allocation Advisors
o Private Advisor Network
• Wells Fargo COMPASS® Asset Allocation strategies
• Customized Portfolios
• FundSource®
Further information regarding these WFCS-sponsored programs is available in Wells Fargo Clearing
Service’s Wrap Fee Program Disclosure. Clients will receive a copy of the WFCS Wrap Fee Program Brochure
prior to opening an account sponsored by WFCS. RFA receives a portion of the wrap fee from WFCS.
Register Financial sponsors the following wrap fee programs through Wells Fargo Clearing Services, LLC.
• Asset Advisor
• CustomChoice
• Private Investment Management (PIM®)
• Private Advisor Network.
Further information regarding these Wells Fargo Clearing Services, LLC Programs, including the fee schedule,
is available in RFA’s Wrap Fee Program Disclosure. The Client should refer to the respective manager’s
Disclosure Document, as appropriate, to determine the minimum and maximum account sizes permitted.
Under certain limited circumstances, the minimum may be waived. Clients and prospective Clients will be
provided a copy of the appropriate Disclosure Document when the Representative presents the Program to
them. WFCS may act as a sub-adviser for the advisory programs. Copies of the Disclosure Documents can also
be obtained by contacting a Register Financial Representative or Register Financial at the address shown on
this Brochure or by contacting the respective program manager, which should be contained in the separate
brochure.
FundSource®, PIM®, and Wells Fargo COMPASS® are registered service marks of Wells Fargo & Company and
are used under license.
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The Representative will review the client’s personal and financial situation, the Account’s investment
objectives, tolerance for risk, and investment time horizon, and with that information, will assist the client in
selecting an appropriate Program, investment manager, and portfolio from sponsors’ approved lists. The
client’s portfolio selection is communicated to the third-party manager (if applicable), who is also provided
with appropriate profile information regarding the client.
In certain programs, the client may choose to receive investment recommendations on a non-discretionary
basis, which the client may accept or reject. Some programs also permit the client to elect to have the
Account’s assets rebalanced automatically at pre-determined intervals to ensure the portfolio continues to
reflect its intended asset allocations.
The managers available through the programs employ various investment strategies depending on the
particular program, the size of the account, the needs of the client, and the account’s objectives. Ordinarily,
the managers’ strategies include long or short-term purchases of securities and, sometimes, include
supplemental covered option writing, where appropriate, depending on the Account’s objectives and the
manager’s style. Some strategies include margin transactions, other option or trading strategies, or short-
sale transactions. Investment decisions in some Programs are guided by model portfolios intended to reflect
the investment objectives and needs of the Client.
The sponsor will pay Register Financial a portion of the fees from the accounts participating in the programs.
Clients should consider whether the fees they pay under the program are more or less than they would pay
if they obtained investment advisory, brokerage, and custodial services separately (an “unbundled”
arrangement). When deciding to participate in a program, Clients or prospective Clients should consider the
many economic incentives that Register Financial (including the Representative) has that influence its
decision to recommend these Programs (or not to recommend other programs or investment alternatives).
ERISA and Individual Retirement Accounts Disclosure
When we provide investment advice to you regarding your retirement plan or individual retirement account,
we are fiduciaries under Title I of the Employee Retirement Income Security Act and/or the Internal Revenue
Code, as applicable, which govern retirement accounts. How we make money creates conflicts with your
interests, so we operate under a special rule that requires us to act in your best interest and not put our
interests ahead of yours.
Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice).
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
• Avoid misleading statements about conflicts of interest, fees, and investments.
• Follow policies and procedures designed to ensure that we give advice in your best interest.
• Charge no more than is reasonable for our services.
• Give you basic information about conflicts of interest.
IV. Financial Planning Consulting Services
Register Financial offers advice in the form of a Financial Plan. Clients receive a written plan that provides
them with a detailed financial plan designed to achieve their stated financial goals and objectives.
Register Financial will typically work with other professionals, such as attorneys, Certified Public
Accountants, trust officers, Mortgage Analysts, etc., to offer financial and estate planning advice. The financial
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management process begins with an in-depth evaluation of the client’s current financial goals and objectives.
Once the overall objectives have been established, Advisor will focus on the client’s specific goals. Services
may include the following, as specified in the Financial Planning Consulting Services Agreement:
Investment Analysis (review of asset allocation and evaluation of individual investments)
•
• Development of an Investment Policy Statement
• Retirement Analysis and Planning
• Company and Employee Benefits Review
• Business Continuation Planning
• Education Funding Analysis
• Wealth Preservation Strategies
• Cash Flow Analysis and Management
• Charitable Planning Review
•
Insurance Analysis
As of December 31, 2025, Register Financial held $394,647,693 in discretionary assets under management
and $93,806,627 in non-discretionary assets under management.
Item 5 – Fees and Compensation
The specific manner in which fees are charged by Register Financial is established in a client’s written
agreement. For its investment advisory clients, the firm presently offers the following types of advisory
services:
Register Financial Investment Management (RFIM)
Register Financial Retirement Plan Consulting
Edelman Turnkey Asset Management Program (TAMP)
I.
II.
III.
IV. Wrap Fee Programs
V.
Financial Planning Consulting Services
I. Register Financial Investment Management (RFIM) (Non-Wrap)
Register Financial will debit the investor accounts on a quarterly basis for the fee described below unless the
client requests to be invoiced for advisory fees. All commissions will be borne by the client and passed
through at cost. The following are the negotiable fees for managing client’s accounts:
RFIM Non - Wrap Fee Schedule
Total Account Value
$0 to $250,000
$250,001 to $500,000
$500,001 to $1,000,000
$1,000,001 to $2,000,000
$2,000,001 & above
Annualized RFIM Fee
2.50%
2.00%
1.80%
1.50%
Negotiable
All advisory management agreements are to specify the fees charged to the account and may be charged in
advance or in arrears of service.
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II. Register Financial Retirement Plan Consulting
Fees for Retirement Plan Consulting Services are negotiable and vary depending on the level of services to
be provided. Fees may be based on the assets of the Plan, the number of Plan participants and/or the number
of Plan investment options. Fees may be based on a percentage of assets or as a fixed annual fee. Fees are to
be clearly stated in all advisory contracts and may be either in advance or in arrears. Under this program,
30-days written notice is required for termination of any Retirement Plan Consulting Agreements.
III. Edelman Turnkey Asset Management Program (TAMP)
Fees for the TAMP program are based on a percentage of assets. Fees are to be clearly stated in all advisory
contracts and are billed quarterly in arrears. The minimum account size is $5,000; however, this may be
reduced at the discretion of management. Clients authorize their Custodian, on behalf of EFE and Register
Financial, to deduct wrap fees from their accounts. Wrap fees include the advisory fee, third-party
investment manager’s fee, and brokerage execution costs. Fees are based on the average daily balance of the
relevant account based on the fee schedule below:
TAMP Fee Schedule
Total Account Value
$0 to $400,000
$400,001 to $750,000
$750,001 to $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $10,000,000
$10,000,001 to $25,000,000
$25,000,001 and above
Annualized Fee
1.75%
1.25%
1.00%
0.75%
0.60%
0.50%
Negotiable
The minimum annual fee is $100. Accordingly, a client may pay an effective rate greater than the rate
specified in the fee schedule shown above. Register Financial, in its sole discretion, may waive its minimum
fee and/or charge a lesser investment advisory fee.
The first payment is calculated based on the number of days assets are placed in the account during a
calendar quarter. Subsequent fees are determined based on the average daily balance for the quarter ending
on the last day of each calendar quarter. Fees are deducted from the client’s account in arrears. When
calculating fees, accounts within the household may be aggregated to determine the lowest fee if all accounts
are managed as one relationship.. EFE, Register Financial, or the Client may terminate the advisory
agreement upon 30 days written notice. If an account is terminated prior to the end of a calendar quarter,
the terminating client will pay prorated fees due up to the termination date.
Underlying mutual funds held in Client accounts incur their own internal expenses such as management,
transfer agent, shareholding servicing, and 12b-1 fees, no portion of which are received by EFE or Register
Financial or reduce the Client’s fees payable to EFE or Register Financial.
IV. Wrap Fee Programs
Each Program or strategy has a maximum Program Fee can vary depending on the particular investment
strategies or portfolios selected by the client, the particular manager selected by the client, and the individual
Representative, among other factors. Generally, the Representative may, in his or her discretion, negotiate
the portion of the program fee that is payable to the Representative or the Firm but does not negotiate the
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portion payable to the third-party manager. Fees will be charged in advance, and the Client‘s Advisory
Agreement will state the specific program fee applicable to client’s Account.
Please see the applicable Wrap Fee Brochure for a more detailed fee schedule.
The program fees are subject to exclusions, calculations, and conditions contained in each Program’s
Disclosure Document and Advisory Agreement. Additionally, most programs have a minimum quarterly
Program Fee ($250 per quarter or more), which may cause the effective Program Fee (expressed as a
percentage) to be greater than the fee rates shown above. The Disclosure Document for each program
contains important information regarding conflicts of interest, compensation, risks, potential benefits, and
other information that prospective investors should review and consider.
V. Financial Planning Consulting Services
Register Financial charges either a fixed agreed-upon rate or an hourly rate for any agreed-upon financial
planning work. This rate will vary depending on the requested task; however, client will be provided an
estimate in advance.
Financial planning fees will be charged on an agreed-upon fixed fee, ranging from $500 to $5,000, depending
on the nature and complexity of each client's circumstances. Fees may be payable in advance or arrears of
service. If in arrears, all fees are due 30 days after services have been rendered. If in advance, an estimate
for the total hours will be determined at the start of the advisory relationship, with the balance (based on
actual hours) due upon presentation of the plan to the client.
Typically, the financial plan will be presented to the client within 90 days of the contract date, provided that
all of the relevant information needed to prepare the financial plan has been promptly provided by the client.
The client may terminate its arrangement at any time, in writing, and will be refunded any prepaid and
unearned fees based upon a pro-rated calculation related to the time and expense expended by the firm.
WRAP FEE DISCLOSURES
For all wrap fee programs, the fee is charged for Register Financial’s consulting and Register Financial’s or
its agent’s brokerage services, as well as the services of any advisor hired to provide portfolio advice and
administrative services to the particular account. Clients acknowledge that commissions or fees charged to
their accounts may be considered in excess of the industry norm. All-inclusive wrap fees charged may be
higher than those otherwise available if the services were provided separately for a discrete fee or if an
Investment Advisor were to select brokerage and negotiate commissions in the absence of the extra
consulting service provided. All Register Financial investment consulting standard fee schedules and
commissions described herein are subject to negotiation depending on a range of factors including, but not
limited to, account size and overall range of services requested. Clients should consider the value of the
additional consulting services when making such comparisons. The combination of custodial, consulting,
and brokerage services may not be available separately or may require multiple accounts, documentation,
and fees. In addition, certain advisors may not be available to certain clients outside the consulting
relationship because of minimum account sizes, fee schedules, geographic availability, or other factors.
TERMINATION OF ADVISORY SERVICES
Client and/or the firm may initiate termination of the contract at any time by sending written notice to the
contra party and will be accepted the day that it is received by the contra party. Termination of the contract
will not affect any liabilities or obligations of the parties from transactions initiated before termination of
this Agreement or a client's obligation to pay advisory fees if paid in arrears (pro-rated through the end of
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the month in which termination is effective). If fees are paid in advance, the client will receive a refund for
any unearned fees calculated from the 1st of the following month in which the contract was terminated
through the last day of the calendar quarter. A full refund will be provided without penalty if the client
terminates the contract within 5 business days of signing with the firm.
Upon written receipt of notice to terminate its Client Agreement with any of Register Financial’s investment
advisory programs, and unless specific transfer instructions are received, Register Financial and its agent
will, in an orderly and efficient manner, proceed with liquidation of the client’s account. There will not be a
separate charge by us for such redemption; however, the client should be aware that certain mutual funds
impose redemption fees as stated in each company’s fund prospectus in certain circumstances, and broker
and clearing firm charges will apply to any redemptions. Clients must keep in mind that the decision to
liquidate security issues or mutual funds may result in tax consequences that should be discussed with the
client’s tax advisor. Factors that affect the orderly and efficient manner would be size and types of issues,
liquidity of the markets, and market makers’ abilities. Should the necessary securities’ markets be unavailable
and trading suspended, efforts to trade will be made as soon as possible following their reopening. Due to the
administrative processing time needed to terminate Client’s investment advisory service and communicate the
instructions to Client’s investment advisor, termination orders received from clients are not market orders;
it may take several business days under normal market conditions to process Client’s request. During
this time, Client’s account is subject to market risk. Register Financial and its agent are not responsible for
market fluctuations of the client’s account from time of written notice until complete liquidation. All efforts will
be made to process the termination in an efficient and timely manner.
General Fee Details
Quarterly fees are based on the Account Asset Value, which includes the sum of all cash, cash equivalents,
Money Market Funds, and market value of all securities (both long and short). Margin debit balances, where
applicable, will not reduce the value of the Account.
Although the fees listed above are “default” fees, they are, in some circumstances, negotiable, if the firm is
assessed a transaction fee, such fee will be passed on to the client at cost.
All Advisory Contracts will specify how fees are to be billed. Generally, fees are either paid in advance or in
arrears of service.
If paid in advance, the initial fee payment is due in full on the date the client’s account is accepted and
opened by the firm (the “Opening Date”) and will be based on the asset value of the account on that date.
If paid in arrears, the fee payment is due following the 1st calendar quarter. The period for which such
payment will be made will run from the opening date through the last day of the full calendar quarter and
will be prorated. Thereafter, the quarterly fee is based on the account asset value on the last day of the
respective calendar quarter.
Fees will be debited from the account specified in the advisory agreement. The amount of the fee will be shown
on the statement received by the Custodian. Register Financial urges clients to carefully review such
statements. Upon request, Register Financial will bill a client for advisory services. If requested, billing
information must be in writing in the advisory agreement. Advisory fees are due upon receipt. Client will
maintain or deposit sufficient funds in the account to cover payment of all fees authorized by the contract,
and the client authorizes the firm, clearing firm, and/or custodian to debit the account balances or redeem
money market fund shares in the amount equal to the fee that is due. If there are not funds to cover the fees,
then the firm will liquidate assets to cover fees.
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Although Register Financial believes its fees are reasonable in light of the services provided, clients should
be aware that such fees may be more or less than the fees and commissions associated with investment
advisory and brokerage services purchased separately. The comparison is dependent upon a number of
factors, including the frequency of brokerage activity in the client’s account, the size of the account under
management, and any negotiated fee arrangements with respect to the account. An investor should consider
these factors prior to opening an Advisory Account.
The advisory fees and transaction charges do not cover charges imposed by third-parties for investments
held in the account, such as contingent deferred sales charges or 12b-1 trails on mutual funds. In addition,
each mutual fund or third-party investment manager charges asset management fees, which are in addition
to the advisory fees charged by the firm. The fees charged by such funds or managers are disclosed in each
fund’s prospectus or Manager’s ADV Part 2A. Accounts may require a minimum advisory fee or quarterly
maintenance fee that will be detailed in the applicable advisory agreement. The Management Fee also does
not cover fees and charges in connection with: debit balances; margin interest; odd-lot differentials; IRA fees;
transfer taxes; exchange fees; wire transfers; extensions; non-sufficient funds; mailgrams; legal transfers;
bank wires; postage; costs associated with exchanging foreign currencies; and SEC fees or other fees or taxes
required by law.
Generally, Register Financial purchases no-load mutual funds that do not generate sales charges. Load and
no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. 12b-1 fees
come from mutual fund assets, including money market funds (therefore, indirectly, from Client Accounts).
In most instances, 12b-1 fees are automatically rebated to the client’s account. In the rare occurrence that
the Custodian does not rebate such fees (i.e., the mutual fund is not on the Custodian’s system), the 12b-1
fees are paid initially to Register Financial’s affiliated broker-dealer, with a portion of those fees passed to
Investment Advisors. The receipt of such fees represents an incentive for Investment Advisors to recommend
mutual funds for which the Custodian does not rebate 12b-1 fees.
Investment adviser representatives trade on margin for client‘s accounts, when consistent with the client’s
suitability profile and risk tolerance or at the client’s directive. This could result in a high portfolio turnover
ratio and higher transaction charges in accounts with such charges. Additionally, the use of margin results in
interest charges as well as all other fees and expenses associated with the security or account involved.
Item 12 further describes the factors that Register Financial considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
Item 6 – Performance-Based Fees and Side-By-Side Management
Register Financial does not charge any performance-based fees (fees based on a share of the realized capital
gains). Register Financial does not manage hedge funds. Accordingly, a discussion regarding side-by-side
management is unnecessary.
Item 7 – Types of Clients
Register Financial provides portfolio management services to individuals, corporations and business
entities, pension and profit-sharing plans, charitable institutions, foundations, endowments, and estate and
trusts. The minimum account size is generally $50,000 for fee based Accounts; the minimum account size for
TAMP accounts is $5,000. Account minimums may be waived at the discretion of management.
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Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Our investment strategy begins with an understanding of a Client’s investment objectives and financial goals.
Investment Advisors use information provided by the Client to assess the Client’s risk profile and investment
objectives in determining an appropriate plan for the Client’s assets. Investment strategies may include, but
are not limited to, long- and short-term purchases of stocks, mutual funds, fixed income securities, options,
short sales, and margin transactions.
Investment recommendations are based on an analysis of the Client’s investment objectives and are drawn
from research and analysis. Security analysis methods may include fundamental analysis, technical analysis,
charting, and cyclical analysis. Information for this analysis is drawn from financial newspapers and
magazines, research materials prepared by others, annual reports, corporate filings, prospectuses, company
press releases, and/or corporate ratings services.
It is important to note that investing in securities involves certain risks that the investor bears. For
information on risks associated with investment company products, please refer to the products' respective
prospectuses. Our investment approach constantly keeps the risk of loss in mind. Potential risks to consider
include but are not limited to:
•
Interest-Rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For
example, when interest rates rise, lower yields on existing bonds become less attractive,
causing their market values to decline.
•
• Market Risk: The price of a security may drop in reaction to tangible or intangible events or
conditions. This type of risk is caused by external factors independent of an individual
security’s particular circumstances. For example, political, economic, and social conditions may
trigger market risk.
Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a
dollar next year because purchasing power is eroding at the rate of inflation.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to be
reinvested at a potentially lower rate of return (i.e., interest rate). This type of risk primarily
affects fixed-income securities.
• Business Risk: Business Risk is associated with a particular industry or a particular company
within an industry. For example, oil-drilling companies depend on finding oil and then refining
it – a lengthy process – before they can generate a profit. Accordingly, they carry a higher risk
of profitability than an electric company that generates its income from a steady stream of
customers who buy electricity no matter what the economic environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally,
assets are more liquid if many traders are interested in a standardized product. For example,
Treasury Bills are highly liquid, while real estate properties are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of
unprofitability because the company must meet the terms of its debt obligations in good
economic times and bad. During periods of financial stress, a business’s inability to meet its
loan obligations may result in bankruptcy or a declining market value.
• Options: Certain types of option trading are permitted in order to generate income or hedge a
security held in the program account; namely, the selling (writing) of covered call options or
the purchasing of put options on a security held in the program account. Client should be aware
that the use of options involves additional risks. The risks of covered call writing include the
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potential for the market to rise sharply. In such case, the security may be called away and the
program account will no longer hold the security. The risk of buying long puts is limited to the
loss of the premium paid for the purchase of the put if the option is not exercised or otherwise
sold by the program account.
• Margin Risk: When you purchase securities, you may pay for the securities in full or you may
borrow part of the purchase price from your brokerage firm. If you choose to borrow funds
through a margin account, securities purchased are the firm's collateral for the loan to you. If
the securities in your account decline in value, so does the value of the collateral supporting
your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell
securities or other assets in any of your accounts held with the member, in order to maintain
the required equity in the account.
Investing with margin is characterized by unique risks, including amplified losses due to
increased leverage, margin calls, forced liquidations, and additional fees, including margin
interest charges and increased advisory fees (See Item 5 for more information). In order to
manage margin risk, the FPC recommends leveraging responsibly (borrowing less than the
amount available), keeping a diversified portfolio, monitoring the account, and evaluating risk
regularly. Before investing on margin, be sure to read the Margin Disclosure Statement
provided by your broker-dealer or custodian.
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 a client’s evaluation of Registered Financial or the integrity of Registered
Financial’s management. Register Financial has no information applicable to this Item.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer: Register Financial is affiliated through common ownership with the Register Financial
Associates, Inc. (“RFA”), which is registered as a broker-dealer with the Securities and Exchange Commission,
FINRA, and various state regulatory agencies. Register Financial maintains separate financial records from
the RFA.
Most Investment Advisors are also Registered Representatives of RFA and recommend brokerage products
or services. All related compensation is separate from advisory services. Although the Broker-Dealer has
controls in place to limit trading errors, such errors may occur from time to time and may result in profit or
loss to Register Financial. Individual Investment Advisors will not participate in any profits resulting from
such errors.
RFA acts as Introducing Broker to WFCS. WFCS provides an annual extension award for up to five years RFA
contingent on the annual renewal of the clearing agreement. The terms of the clearing agreement are
negotiable. WFCS was selected based on a number of factors, including their historical relationship with the
Firm, their financial strength, reputation, execution capabilities, pricing and services offered, and not the
annual award. Revenue sharing may occur from time to time from WFCS, our clearing agent and Investment
Companies to RFA. Clients may incur certain charges imposed by third party investment and other third
parties such as the Wells Fargo Bank Deposit Sweep, margin interest charged on debit balances which are
shared with RFA. The Firm does not limit our recommendations to these products that generate third party
payment.
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Insurance Company: RFA is licensed as an insurance agency in order to sell insurance products, including
fixed and variable annuities and variable life insurance. Investment Advisors who hold insurance licenses
may offer insurance products for a separate fee or other compensation.
Investment Advisors may spend from 25% to 75% of their time on business activities other than Investment
Advisory activities. Advisory clients are under no obligation to purchase brokerage or insurance products
recommended by their Investment Advisor.
Please see the discussion under Item 12, below, for additional information regarding brokerage practices
and related disclosures.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading
Register Financial has adopted a Code of Ethics for all supervised persons of Register Financial. The Code of
Ethics describes Register Financial’s high standards of business conduct and its fiduciary duty to its Clients.
The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on
insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the
reporting of certain gifts and business entertainment items, and guidance on personal securities trading
procedures, among other things. All supervised persons at Register Financial must acknowledge the terms
of the Code of Ethics annually, or as amended, and are required to follow the Code of Ethics’ provisions.
The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of
the employees of Register Financial will not interfere with (i) making decisions in the best interests of
advisory Clients or (ii) implementing such decisions while, at the same time, allowing Register Financial
employees to invest for their own Accounts. Under the Code of Ethics, Investment Advisors of Register
Financial may buy or sell securities that are recommended to Clients. Subject to the Code of Ethics guidelines
and applicable security industry laws, officers, directors, and employees of Register Financial and its affiliates
may trade for their own Accounts securities that are recommended to or purchased for Register Financial’s
Clients.
Certain classes of securities have been designated as exempt transactions, based upon a determination that
trading in those securities will not materially interfere with the best interests of Register Financial’s Clients.
In addition, the Code requires pre-approval of some transactions. Nonetheless, because the Code of Ethics in
some circumstances would permit Register Financial’s employees to invest in the same securities as Clients,
there is a possibility that employees might benefit from market activity by a Client. Employee trading is
continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Register
Financial and its Clients.
Register Financial may give advice to others that is different from the advice given to Program Clients.
Register Financial’s Clients or prospective Clients may request a copy of Register Financial's Code of Ethics
by contacting Scott Register at our main number.
Item 12 – Brokerage Practices
Register Financial typically recommends the brokerage and custodial services of Wells Fargo Clearing
Services, LLC (the “Custodian”). When recommending a custodian, a number of factors are considered,
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including their historical relationship with Register Financial, financial strength, reputation, execution
capabilities, pricing and services offered.
As noted herein, the Custodian generally does not charge Client Accounts separately for custody services. It
offers products and services that benefit Register Financial but may not directly benefit Register Financial's
Clients’ Accounts. Those products and services are used to service most Register Financial Accounts and
include software and other technology that (i) provides access to Client Account data (such as trade
confirmations and Account statements); (ii) facilitates trade execution and allocates aggregated trade orders
for multiple Client Accounts; (iii) provides research, pricing, and other market data; (iv) facilitates payment
of Register Financial's quarterly fees from its Clients’ Accounts; and (v) assists with back-office functions,
recordkeeping, and reporting.
Registered Investment Advisers recommend the services of affiliated broker-dealer Register Financial
Associates, Inc. (“RFA”) to provide services to Client Accounts. In such cases, RFA’s commissions may be
higher or lower than those of other broker-dealers. However, RFA strives to serve the best interests of
Register Financial's Clients. Register Financial believes that the overall level of services and support provided
to its Clients by the RFA outweighs the potentially lower transaction cost available under other brokerage
arrangements. Register Financial will make all trading recommendations independent of such fee
considerations and based solely on its obligations to consider a Client’s objectives and needs.
If cash is swept into a money market fund, Register Financial will receive compensation based on the value
of money market fund assets. Thus, Register Financial has an incentive to recommend that Clients select
money market funds as a sweep vehicle.
Register Financial allows clients to direct where their accounts are custodied and/or which broker-dealer
they wish to utilize for their account. However, if clients choose to do this, Register Financial may be unable
to achieve the most favorable execution of client transactions. This may cost clients money because, without
the ability to direct brokerage, Register Financial will not be able to aggregate orders to reduce transaction
costs, resulting in higher brokerage commissions and less favorable prices.
For TAMP accounts utilizing EFE as a third-party investment manager, Register Financial does not direct
brokerage. Clients must establish an account through Charles Schwab & Co. (“Schwab”). Schwab is
compensated by account holders through commissions and other transaction-related or asset-based fees for
securities trades that are executed, which are included when wrap fees are charged. Please see EFE’s
Brochure for additional information regarding their brokerage practices.
When consistent with our duty to obtain best execution, we may aggregate multiple client transactions into
a single order in order to obtain the best price for our clients. In such circumstances, receive securities at a
total average price. Register Financial will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed
orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-
rata basis. Any exceptions will be explained on the order.
Register Financial may execute transactions as principal or riskless agent. This is typically done in fixed-
income trading when Register Financial buys securities from your account for its own account or when
Register Financial sells securities from its account to your account. Depending on the circumstances,
advisory clients can benefit from principal transactions by obtaining a more favorable transaction price for
the securities being purchased or sold than otherwise available. Register Financial engages in principal
transactions only when they serve clients’ best interests. Principal transactions pose the potential for
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conflicts between the interests of the investment adviser and those of the client. In all such cases, Register
Financial will provide separate disclosure that includes details about the trade when acting in a principal
capacity or riskless agent and obtain the client’s consent. Register Financial receives no additional brokerage
commission or compensation when acting as principal or agent.
DESCRIPTION OF REGISTER FINANCIAL AND WELLS FARGO CLEARING SERVICES, LLC AGREEMENT
The agreement between Register Financial and WFCS is applicable to clients with accounts held at WFCS. It
provides, among other things, the following:
• Register Financial has entered into a brokerage clearing agreement with the Clearing Agent to
execute and perform the clearance on a fully disclosed basis of all purchase and sale orders directed
to it by Register Financial for the Programs selected by a client.
• Clearing Agent or its agent shall generally maintain, in a Register Financial account, custody of all
account assets. Pursuant to a clearing agreement between Register Financial and Clearing Agent,
Clearing Agent performs for Register Financial such custodial functions, which, among other things,
will include crediting of interest and dividends on account assets and crediting of principal on called
or matured securities in the account, together with other custodial functions customarily performed
with respect to securities brokerage accounts.
• Clearing Agent or its agent will also perform cashiering and invoicing responsibilities for the
Programs, which shall include the charging and collecting account fees and the processing, according
to Register Financial instructions, of deposits to and withdrawals from Program accounts. Clients
expressly authorize Clearing Agent or its agent to debit fees of Register Financial, WFCS, Clearing
Agent, and any applicable investment advisors.
• Clearing Agent provides Register Financial with certain administrative, computer software, and
documentation services in order that Register Financial may provide the Program services described
below. Clearing Agent does not provide any of the consulting, advisory, or evaluation services to
Register Financial’s clients with respect to any program described herein. Register Financial
compensates Clearing Agent pursuant to a brokerage clearance fee schedule. Register Financial may
utilize an investment planning tool, Envision®, as part of its investment planning process. Envision®
is a registered service mark of Wells Fargo & Company and is used under license. This tool takes into
account a variety of information about a client’s financial situation, performs a “Monte Carlo” analysis
to test for possible future outcomes, and is utilized in determining a model asset allocation for the
client. Such software is provided to Register Financial (and its clients) by WFCS as part of its services
and there is no additional fee for Register Financial for this software.
Item 13 – Review of Accounts
The Investment Advisor will provide Clients with Account performance reviews annually or more frequently
as per Client’s request. The performance review will include a written statement reflecting the assets in the
Client’s Account, the purchase date, the cost basis, the current market value, and other applicable
performance data for the period (or since the opening of the Account). The Client will also receive monthly
or quarterly account statements, tax-related reports, and trade confirmations directly from the Custodians.
Factors that are considered in the performance review process include but are not limited to, the following:
investment objectives, targeted allocation, current allocation, suitability, performance, monthly
distributions, concentrated positions, diversification, and outside holdings. The Client agrees to inform
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Register Financial in writing of any material changes in the Client's investment objectives that might affect
the manner in which Client’s assets should be invested. The Client may contact Register Financial during
normal business hours to consult with Register Financial concerning the management of the Client’s Account.
Item 14 – Client Referrals and Other Compensation
Register Financial Advisors, in some instances, will compensate employees of the affiliated broker-dealer,
Register Financial Associates, Inc., for referring clients to Register Financial. In all such cases, the referral fee
will comply with Section 206(4)-1 of the Investment Advisers Act of 1940. Compensation will be based on a
percentage of referred clients’ account value managed by Register Financial and paid pursuant to a written
agreement between Register Financial and the promoter. Any referral fees will be based on Register
Financial’s normal fee schedule; clients will not be charged any additional fees or expenses as a result of any
referral.
Item 15 – Custody
Clients should receive statements at least quarterly from the Custodians that hold and maintain the Account's
assets. Clients should carefully review such statements and compare those records to the Account statements
prepared and provided to you by Register Financial. Our statements may vary from the Custodian’s
statements based on accounting procedures, reporting dates, or valuation methodologies of certain
securities. Clients should bring any such discrepancies to Register Financial's attention promptly.
Item 16 – Investment Discretion
Register Financial may provide investment advisory and brokerage services to Client Accounts on a
discretionary basis. Such discretion usually is granted at the outset of the advisory relationship and must be
in writing. When a Client grants investment discretion to an Investment Advisor, the Advisor will have
authority to supervise and direct the Client’s investments without prior consultation with the Client.
Pursuant to this discretionary authority, the Investment Advisor will determine which securities are bought
and sold for the Account and the total amount of such purchases and sales. The Investment Advisor will make
investment decisions for Client Accounts in accordance with the Client’s investment objectives, guidelines,
or such reasonable restrictions as the Client may impose on the Investment Advisor in writing and to which
the Investment Advisor has agreed. Pursuant to the Client’s instructions, a Client’s cash may be invested in a
money market mutual fund managed by the Account’s Custodian, which charges a fee. Clients should contact
their Custodian for more information about this investment of their cash.
Item 17 – Voting Client Securities
As a matter of policy and practice, Register Financial does not vote proxies on any Client’s behalf. A Client
can authorize Investment Advisors to vote proxies on the Client's behalf by adding such a provision to the
advisory agreement that governs the relationship between the Client and the Investment Advisor. Clients
should refer to the Investment Advisor's Form ADV for a full disclosure of its proxy voting policies and
procedures and should contact their Investment Advisor if they have any questions about those policies.
Clients will receive their proxies or other solicitations directly from the Custodian.
Item 18 – Financial Information
Registered Investment Advisers are required to provide clients with certain financial information or
disclosures about Register Financial’s financial condition. Register Financial has no financial commitment
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that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject
of any bankruptcy proceedings.
Privacy Policy
We collect nonpublic personal information about you from the following sources:
Information we receive on applications, new account forms, website, questionnaires, or other forms and
information about your transactions. We do not disclose any non-public information about our current or
former customers to anyone, except as permitted by law or to provide the current services. Our employees
have limited access to your personal information based on their responsibilities to provide products or
services to you. Be assured that we maintain physical, electronic, and procedural safeguards in compliance
with federal standards to protect your information.
We do not disclose any non-public personal information about you to any non-affiliated third parties, except
as permitted by law. While servicing your account, we may share some information with our service
providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys.
If your Financial Advisor should join another firm, he or she is permitted to retain copies of your information
so that he or she can assist with the transfer of your account and continue to serve you at their new firm.
“Opting-out” of Third-Party Disclosures
If you do not want your Financial Advisor to retain copies of your client’s sensitive information, should they
leave Register Financial, you may contact our Compliance Department by calling our toll-free number (800)
765-8062.
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 annually. Contact our main
office at (800) 765-8062 or (404) 364-2180 if you have any questions regarding this policy.
If you do not want your Investment Advisor to retain copies of your client-specific information if he leaves
us to join another firm, you may notify our Compliance Department by calling.
Securities offered through Register Financial Associates, Inc. Advisory Services offered through Register
Financial Advisors, LLC
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