View Document Text
Secure Retirement Financial &
Insurance Services Corp.
2333. San Ramon
Valley Boulevard
Suite 250
San Ramon, CA 94583
(925) 855-4300
www.secureretire.com
Form ADV, Part 2A Brochure
April 1, 2026
This brochure provides information about the qualifications and business practices of Secure Retirement
Financial & Insurance Services Corp. If you have any questions about the contents of this brochure, please
contact us at (925) 855-4300 or richard@secureretire.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.
Secure Retirement Financial & Insurance Services Corp. is a Registered Investment Adviser. Any reference
to or use of the terms “registered investment adviser” or “registered,” does not imply that Secure
Retirement Financial & Insurance Services Corp. or any person associated with Secure Retirement
Financial & Insurance Services Corp. has achieved a certain level of skill or training.
Additional information about SRF is available on the SEC’s website at www.adviserinfo.sec.gov.
ITEM 2 - MATERIAL CHANGES
The purpose of this page is to inform clients of material changes to the brochure. If you are receiving
this brochure for the first time, this section may not be relevant to you.
There are no material changes in this brochure from the last annual updating amendment of Secure
Retirement Financial & Insurance Services Corp. (“SRF”) on 03/27/2025.
2
SRF Brochure
May 27, 2025
ITEM 3 - TABLE OF CONTENTS
Contents
ITEM 2 - MATERIAL CHANGES ...................................................................................................................2
ITEM 3 - TABLE OF CONTENTS ...................................................................................................................3
ITEM 4 - ADVISORY BUSINESS ...................................................................................................................5
Principal Owners ..............................................................................................................................................5
Types of Advisory Services Offered ..................................................................................................................5
SRF Investment Advisory Services ...................................................................................................................5
SRF Referral Program ......................................................................................................................................5
Retirement Account Advice .............................................................................................................................5
Tailored Services and Client Imposed Restrictions ...........................................................................................6
Assets Under Management ..............................................................................................................................6
ITEM 5 - FEES AND COMPENSATION ..........................................................................................................6
SRF Investment Management Fees ..................................................................................................................6
SRF Referral Program .......................................................................................................................................7
Other Fees and Expenses .................................................................................................................................7
Termination of Account ....................................................................................................................................7
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ....................................................8
ITEM 7 - TYPES OF CLIENTS ........................................................................................................................8
Requirement for Opening Accounts (Minimum Investment Amount) ..............................................................8
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .........................................8
Methods of Analysis .........................................................................................................................................8
Investment Strategies .......................................................................................................................................8
Tactical Allocation Portfolio ............................................................................................................................8
Dividend Focused - Income .............................................................................................................................8
Innovative Growth Portfolio ............................................................................................................................9
Investing Involves Risk ......................................................................................................................................9
ITEM 9 - DISCIPLINARY INFORMATION .......................................................................................................9
Disclosure Events .............................................................................................................................................9
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................... 10
Broker/Dealer Affiliation ............................................................................................................................... 10
Insurance Products ........................................................................................................................................ 10
Selection of Other Investment Advisers ........................................................................................................ 10
3
SRF Brochure
May 27, 2025
Disclosure of Material Conflicts ..................................................................................................................... 10
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING ............................................................................................................................................... 11
Code of Ethics ................................................................................................................................................ 11
Participation/Interest in Client Transactions ................................................................................................. 11
ITEM 12 - BROKERAGE PRACTICES ........................................................................................................... 12
Factors Considered in Selecting Custodians for Client Transactions .............................................................. 12
Research and Other Soft Dollar Benefits ....................................................................................................... 12
Brokerage for Client Referrals ....................................................................................................................... 13
Directed Brokerage........................................................................................................................................ 13
Aggregation of Client Orders ......................................................................................................................... 13
ITEM 13 - REVIEW OF ACCOUNTS ............................................................................................................ 13
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................... 13
Economic Benefit from Non-Clients .............................................................................................................. 13
Compensation for Client Referrals ................................................................................................................. 14
SRF does not compensate non-advisory personnel (solicitors/promoters) for client referrals. .................. 14
ITEM 15 - CUSTODY ................................................................................................................................ 14
ITEM 16 - INVESTMENT DISCRETION ........................................................................................................ 14
ITEM 17 - VOTING CLIENT SECURITIES ...................................................................................................... 14
ITEM 18 - FINANCIAL INFORMATION ....................................................................................................... 14
Privacy Policy ......................................................................................................................................... 16
Privacy Policy Notice ..................................................................................................................................... 16
4
SRF Brochure
May 27, 2025
ITEM 4 - ADVISORY BUSINESS
Secure Retirement Financial & Insurance Services (“SRF”) is a state registered investment adviser firm
established in 2004 to provide investment advisory and financial planning services to individuals,
pensions and profit-sharing plans, trusts, estates, and charitable organizations (“clients”).
Principal Owners
The principal owners of SRF are Richard R. Morey, who owns 70%, and Jeffrey Michael Warren, who
owns 30%.. The firm’s management and control rests solely in the hands of Richard R. Morey.
Types of Advisory Services Offered
SRF Investment Advisory Services
SRF offers clients investment advisory services as covered in the Investment Advisory Agreement (“IAA”)
where each client’s investment account and portfolio is managed on a regular and continuous basis.
SRF may assist clients in determining, among other things, suitability, investment objectives, goals, time
horizons, and risk tolerances. As part of the investment advisory services, SRF may provide personalized
or corporate financial planning services as segmented (limited) financial plans, investment plans, and/or
individual consultations regarding a client’s financial affairs. Financial planning is complimentary to
investment advisory clients who make use of the service and a written financial plan is not delivered in
every engagement. The design and implementation of a financial plan may begin with the process of
gathering data regarding income, expenses, taxes, insurance coverage, retirement plans, wills, trusts,
investments and/or other relevant information pertaining to a client’s overall financial situation. This
information is carefully analyzed, taking into account a client’s goals and stated objectives, and a series
of recommendations and/or alternative strategies will be developed.
SRF Referral Program
SRF may also provide investment advisory services to clients referred by independent investment
advisors. SRF will enter into an agreement directly with the client to provide these services.
Retirement Account Advice
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Securities Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. The receipt of our advisory fee for making a recommendation creates a
conflict of interest under ERISA/IRC with your interests, so we operate under a special rule that requires
us to act in your best interest and not put our interest ahead of yours. For example, if we recommend
that you rollover assets from one retirement account to another and we will receive increased
5
SRF Brochure
May 27, 2025
compensation as a result of that recommendation, we have a conflict that requires us to operate under
this special rule.
Tailored Services and Client Imposed Restrictions
SRF will tailor its advisory services to the specific needs and objectives of each advisory client. Clients
may also impose restrictions on investing in certain securities or types of securities. Restrictions are
generally covered in the client’s investment advisory agreement and must be made in writing.
SRF does not participate in a wrap fee program at this time.
Assets Under Management
SRF manages client assets in discretionary accounts on a continuous and regular basis. As of
12/2025, the total amount of assets under our management was:
Discretionary Assets
Non-Discretionary Assets
Total Assets
$ 101,995,843
$
0
$ 101,995,843
ITEM 5 - FEES AND COMPENSATION
SRF Investment Management Fees
Fees are based on a percentage of assets under management, and in no case will fees exceed 2% of
assets under management. Additionally, fees are not collected more than six (6) months in advance of
the services for those fees.
Fees based on assets under management are as follows:
Annual Fee
Market Value of Portfolio
The balance of 0 - $1,000,000 1.00%
0.75%
The balance over $1,000,001
Generally, fees are payable quarterly, in advance. The initial fee for a new account will be based on the
opening account balance and will be pro-rated for the number of days in the quarter that the account is
under SRF’s management. Subsequent quarterly fees will be based on the account’s market value as of
the close of business on the last business day of the previous quarter for which the fee is due.
SRF’s fee range and billing terms for each particular service is subject to negotiation and could vary
depending upon various circumstances, including the scope of the services to be provided (e.g., fees and
fee ranges for existing clients may differ from those indicated). With client authorization, SRF will
instruct the custodian to withdraw our advisory fee from the client’s account. SRF will send an
6
SRF Brochure
May 27, 2025
informational copy of the invoice to the client concurrent with the instructions to the custodian showing
the amount of the fee due, the value of the account on which the fee is based, and how the fee was
calculated. All clients will receive brokerage statements from the custodian no less frequently than
quarterly. The custodian statement will show the deduction of the advisory fee.
SRF Referral Program
Clients that have been referred to SRF will pay a fee based on assets under management with a
maximum total fee of 2.00% for portfolios up to $1,000,000 and 1.50% for portfolios over $1,000,000.
The sample Referral Program Fee schedule below displays the maximum fees allowed and may not
include certain fees charged by the broker or custodian used. In that case, those fees will be disclosed
separately to the client.
The standard fee schedule for such services is as follows, but may be negotiable in individual cases.
AUM $0 - $1,000,000
AUM over $1,000,000
SRF
.75
.50
RF/RF Rep*
.25+1.00
.25+0.75
Total*
2.00% (Maximum fee)
1.50% (Maximum fee)
*RF/RF Rep= Referral Firm and Representative fees
Fees are billed quarterly from the client’s account(s) with Charles Schwab & Co.
Other Fees and Expenses
SRF’s fees do not include custodian fees. Clients pay all brokerage commissions, margin charges, and/or
other charges incurred in connection with transactions in accounts, from the assets in the account.
These charges are in addition to the fees the client pays to SRF. In addition, any mutual fund shares held
in a client’s account may be subject to deferred sales charges, 12b-1 fees, early redemption fees, and
other fund-related expenses. The fund’s prospectus fully describes the fees and expenses. All fees paid
to SRF for investment advisory services are separate and distinct from the fees and expenses charged by
mutual funds. Mutual funds pay advisory fees to their managers, which are indirectly charged to all
holders of the mutual fund shares.
Termination of Account
Within five (5) business days of executing the client agreement, the client may terminate the agreement
in writing without fee or penalty. Such termination may be verbal with written notice to follow within
the next twenty-four (24) hours. After the initial five (5) business days, clients may terminate the
agreement at any time in writing; and the client will be responsible for payment of fees for the number
of days services are provided by SRF prior to receipt of the written notice of termination. Fees will be
prorated to the date of termination and any paid but unearned portion will be refunded to the client.
7
SRF Brochure
May 27, 2025
ITEM 6 - PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Neither SRF or any of its supervised persons accepts performance-based fees and therefore
does not engage in side-by-side management.
ITEM 7 - TYPES OF CLIENTS
SRF provides investment advisory and financial planning services to individuals, pensions and
profit sharing plans, trusts, estates, and charitable organizations (“clients”).
Requirement for Opening Accounts (Minimum Investment Amount)
SRF does not impose requirements for opening and/or maintaining an account, such as a
minimum account size or minimum fees and fee ranges. All initial investment amounts are
negotiable and accepted on an individual basis at SRF’s discretion.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Methods of Analysis
SRF’s securities analysis methods may include fundamental analysis, technical analysis, and the
use of cyclical analysis and monitoring of investment cycles and trends.
Investment Strategies
SRF provides its clients with a range of investment advisory services. SRF generally offers the following
specific advisory portfolios: Tactical Allocation Portfolio; Dividend Focused- Income; and Innovative
Growth Portfolio. Client portfolios may vary based on individual needs and client directed
investments.
Tactical Allocation Portfolio
Objective is capital preservation and to capitalize on macroeconomic trends through robust
research and analysis.
This is an actively managed investment portfolio. A wide range of asset classes are considered
on a continual basis.
Dividend Focused - Income
Objective is to provide investors with current income from dividends. The portfolio will invest in
a combination of fixed income/bonds, equities, real estate and utilities. The fund is actively
managed and seeks to hedge volatility.
8
SRF Brochure
May 27, 2025
Innovative Growth Portfolio
Objective is to invest in growth industries and sectors with emphasis on Climate Change
solutions and the Energy transition, sustainable materials and agriculture.
The digital economy and essential infrastructure.
For SRF to determine the appropriate portfolio for the client, the client must provide SRF with pertinent
financial and demographic information. SRF will analyze the information and recommend an appropriate
strategy based on the client’s needs and objectives, investment time horizon, risk tolerance and any other
pertinent factors. SRF will then propose an overall strategy that includes asset allocation and investment
style allocation recommendations. SRF will select a portfolio based on SRF’s recommended investment
strategy that corresponds to the individual client’s goals and objectives.
Investing Involves Risk
Prior to entering into an agreement with SRF, the client should carefully consider the following:
1. That investing in securities involves risk of loss which clients should be prepared to bear;
2. That securities markets experience varying degrees of volatility;
3. That over time the client’s assets may fluctuate and at any time be worth more or less than the
amount invested; and
4. That clients should only commit assets that they feel are available for investment on a long-term
basis.
ITEM 9 - DISCIPLINARY INFORMATION
Disclosure Events
On June 19, 2020, SRF entered into a Consent Order with the Department of Business Oversight of the
State of California (“DBO”), effective September 30, 2020 now called the Department of Financial
Protection and Innovation (“DFPI”). The order states that SRF acted in contradiction of state rules. SRF
released a client’s funds without authorization or proper consent from the account holder by taking
disbursement instructions from the client’s spouse and releasing the funds to the spouse. The spouse of
the client perpetrated fraud. Upon the finding by the DBO, SRF established an Identify Theft and Client
Disbursement Request policy. Further, the order states that SRF loaned money to a client in
contradiction of state rules. Richard Morey made a short-term, interest-free loan to a friend who was
also a client for the purchase of private offering. The order further states that SRF failed to maintain
current client suitability records. SRF has established Client Suitability policies. Lastly, the order states
that SRF did not establish an unearned income account on its financial records. A new employee still
learning the accounting system had not entered the unearned income account on the financial records.
No clients were financially harmed.
9
SRF Brochure
May 27, 2025
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Broker/Dealer Affiliation
Neither SRF nor any of its management persons are registered or have an application pending
to register as a broker-dealer.
Neither SRF nor any of its management persons are registered, or have an application pending
to register, as a futures commission merchant, commodity pool operator, a commodity trading
advisor, or an associated person of the foregoing entities.
As a supervised person of SRF, Jeff Warren is also currently licensed as a securities salesperson
for Vanderbilt Financial Group (CRD#5953), a FINRA member broker/dealer. As such, Mr.
Warren may recommend securities products for a commission. This presents a conflict of
interest in that Mr. Warren could receive fees and commissions if the client chooses to
implement recommendations made in his capacity as a registered representative. Mr. Warren
will make such recommendations when he deems them to be in the best interest of the client.
The client always has the right to decide whether to purchase any recommended securities and
the person through whom to make a purchase. All material conflicts of interest are disclosed
regarding Mr. Warren and other IARs and/or SRF which could be reasonably expected to impair
the rendering of unbiased and objective advice.
Insurance Products
SRF is also licensed as an insurance agency in California selling fixed annuities and life insurance
products. As such, SRF or its supervised persons may recommend, on a fully disclosed basis, the
purchase of certain insurance-related products for which SRF or its supervised persons receive
commissions. This presents a conflict of interest between SRF’s interests and those of its
advisory clients. SRF will make insurance recommendations when we deem them to be in the
best interest of the client. The client always has the right to decide whether to purchase any
recommended insurance and the person through whom to make a purchase.
Selection of Other Investment Advisers
SRF does not recommend or select other investment advisers for its clients or receive
compensation directly or indirectly from those advisers as a result of such a recommendation or
selection by SRF.
Disclosure of Material Conflicts
All material conflicts of interest under CCR Section 260.238(k) are disclosed regarding SRF, its
representatives or any of its employees, which could be reasonably expected to impair the
rendering of unbiased and objective advice.
10
SRF Brochure
May 27, 2025
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
SRF has adopted the following Code of Ethics:
Fiduciary Responsibility- SRF and its staff shall exercise the highest standard of care in protecting
and promoting the interests of its clients and will provide a written disclosure containing any
conflicts of interest that may compromise their impartiality or independence.
Integrity- All professional services shall be rendered with the highest level of integrity.
Objectivity- SRF and its staff shall provide advice that is objective and in the best interest of the
client and seek to eliminate or mitigate conflicts of interest.
Competence- SRF and its staff shall maintain the necessary knowledge and skills to provide our
clients with competent advice and services.
Fairness- All professional services shall be performed by SRF and its staff in a manner that is fair
and reasonable to its clients.
Confidentiality- SRF and its staff shall maintain and safeguard all confidential client information
in accordance with applicable laws.
Diligence- SRF and its staff shall ensure the accuracy and completeness of records, information,
and data collected, used and managed, and will take necessary steps to correct any
discrepancies.
Regulatory Compliance- SRF and its staff shall comply fully with appropriate laws and internal
regulations.
SRF will provide a copy of this Code of Ethics to any client or prospective client upon request.
Participation/Interest in Client Transactions
Neither SRF nor any of its related persons recommend to clients, or buys or sells for client accounts,
securities in which SRF or a related person has a material financial interest.
SRF or its related persons may invest in the same securities (or related securities, e.g., warrants, options
or futures) that SRF or any of its related persons recommend to clients.
SRF and its related persons may recommend securities to clients, or may buy or sell securities for client
accounts, at or about the same time that SRF or any of its related persons buy or sell the same securities
for SRF’s own (or the related person's own) account. However, as a preventative measure, client
transactions will be conducted and implemented before any such transaction relating to any personal
accounts of any affiliated persons of SRF, except when such transactions are aggregated with client
transactions as outlined in Item 12 below under aggregation of client orders. In addition to this measure,
11
SRF Brochure
May 27, 2025
all of the aforementioned advisory representatives of SRF will act in accordance will applicable securities
laws and conduct their business to ensure overall compliance with applicable securities laws.
ITEM 12 - BROKERAGE PRACTICES
Factors Considered in Selecting Custodians for Client Transactions
Clients open one or more custodian accounts in their own name at a qualified custodian. SRF
recommends the use of Schwab Advisor Services™, a division of Charles Schwab & Co., Inc. (“Schwab”),
to act as custodian and broker for the client’s account. The client will enter into a separate agreement
with the custodian to custody the assets. SRF also requires that clients grant it limited power of attorney
to execute client transactions through Schwab. SRF is independently owned and operated, and
unaffiliated with Schwab. While commission rates are an important factor in custodian selection, SRF
may select custodians that charge commissions higher than those obtainable from other custodians. SRF
may consider a number of factors in addition to commission rates, including, for example net price,
reputation, financial strength and stability, efficiency of execution and error resolution, block trading
and block position capabilities, willing to execute related or unrelated difficult transactions in the future,
on-line access to computerized data regarding client accounts, custody, record keeping or other similar
services, as well as other matters involved in the receipt of general brokerage services.
Research and Other Soft Dollar Benefits
Regarding research and other soft dollar benefits, SRF does not receive research (both proprietary or
non-proprietary) or other products or services other than execution services from a custodian or a third
party in connection with client securities transactions, including but not limited to (otherwise known as
“soft dollar benefits”). However, SRF may receive from Schwab, without cost (or at a discount), support
services and/or other products that benefit SRF. These services and products are not directly connected
with the number or amount of client securities transactions, but are available to SRF on an unsolicited
basis, at no charge to SRF, for maintaining client assets in accounts at Schwab.
Schwab makes available products and services that assist SRF in managing and administering clients’
accounts including software and other technology that:
1. provide access to client account data (such as trade confirmations and account statements);
2. facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
3. provide research, pricing and other market data;
4. facilitate payment of SRF’s fees from its clients’ accounts; and
5. assist with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help SRF manage and further develop its business
enterprise. These services may include:
1. compliance, legal and business consulting;
2. publications and conferences on practice management and business succession; and
3. access to employee benefits providers, human capital consultants, and insurance providers.
12
SRF Brochure
May 27, 2025
Brokerage for Client Referrals
SRF does not receive client referrals from Schwab.
Directed Brokerage
SRF does not accept direction from clients to trade through specific broker-dealers.
Aggregation of Client Orders
Under certain circumstances, SRF may aggregate the purchase or sale of securities for various client
accounts, as well as for accounts of SRF’s supervised persons. SRF will not favor any account over any
other account. This includes accounts of SRF or any of its supervised persons. SRF supervised persons
will participate on the same terms as clients. Each account in the aggregated order will participate at the
average share price for all of the transactions within the aggregated trade. All accounts will pay their
individual transaction costs.
ITEM 13 - REVIEW OF ACCOUNTS
Clients of SRF are managed and reviewed on a continuous basis. Overall investment management,
market prospects and individual issue prospects are considered in the review process. Triggering factors
that may affect an account review could be any material change in a client's account such as a change in
company earnings, industry and/or company outlook as well as general economic factors or other
relevant situations that may alter a client's account. All account reviews are conducted by one of SRF’s
designated investment adviser professionals. We offer account reviews to clients on no less than an
annual basis. Clients may choose to receive reviews in person, by telephone, or in writing. It is the
client’s responsibility to notify SRF of any changes in the client’s circumstances and investment
objectives.
As may be retained by clients, reports are individualized, thereby, the nature and frequency are
determined by client need and the services offered. However, each client receives a statement from the
custodian not less than quarterly that includes an accounting of all holdings and transactions in the
account for the reporting period. In addition, SRF provides clients quarterly reports summarizing the
client’s overall account activity and investment performance.
ITEM 14 - CLIENT REFERRALS AND OTHER COMPENSATION
Economic Benefit from Non-Clients
Other than the benefits disclosed in Item 12 above, SRF does not receive an economic benefit for
providing investment advice or other advisory services from anyone who is not a client.
13
SRF Brochure
May 27, 2025
Compensation for Client Referrals
SRF does not compensate non-advisory personnel (solicitors/promoters) for client referrals.
ITEM 15 - CUSTODY
SRF does not maintain physical custody of client funds and/or securities. However, we do have
constructive custody where we have the client’s authorization to withdraw our fees from the client’s
account with the custodian. SRF is also deemed to have custody of clients’ funds or securities when
clients have standing authorizations with their custodian to move money from a client’s account to a
third-party (“SLOA”) and under that SLOA authorize us to designate the amount or timing of transfers
with the custodian. State and Federal regulators have set forth a set of standards intended to protect
client assets in such situations, which we follow. Clients will receive their monthly and/or quarterly
account statements directly from the designated qualified custodian of record and therefore should
carefully review those statements for accuracy. In the event that clients also receive reports from SRF, it
strongly encourages each client to compare the account statements they receive from the qualified
custodian with the invoices and reports they received from SRF and notify SRF promptly of any
discrepancies.
ITEM 16 - INVESTMENT DISCRETION
Upon receiving written authorization from a client, SRF manages client assets on a discretionary basis. In
this case, the client delegates to SRF discretionary trading authorization with respect to the purchase,
exchange and sale of securities in the client’s account, including actively traded equity and equity-
related securities, mutual funds, and fixed-income securities.
ITEM 17 - VOTING CLIENT SECURITIES
SRF is typically given the authority to vote client proxies and therefore may be required to take action or
render advice with respect to voting of proxies solicited by or with respect to the issuers of securities in
which assets of the clients account(s) may be invested from time to time. When SRF accepts such
responsibility, we will cast proxy votes in a manner consistent with the best interest of clients. Clients
generally cannot direct SRF’s vote in particular solicitations. If SRF identifies a conflict of interest in
connection with a particular voting decision, it will disclose the conflict to the client or contact a third
party to advise SRF to determine the vote and/or provide voting recommendations. Clients may contact
SRF directly at (925) 855-4300 to request information about how it voted proxies for their securities.
ITEM 18 - FINANCIAL INFORMATION
Pre-Payment of Fees
SRF does not require or solicit prepayment of more than $1200 in fees per client, six months or more in
advance.
14
SRF Brochure
May 27, 2025
Material Impact of Discretionary Authority
SRF may exercise discretionary authority over certain client funds or securities. However, SRF does not
anticipate any financial condition that may be reasonably likely to impair its ability to meet contractual
commitments to clients at this time.
Custody Disclosure
SRF does not have physical custody of client funds or securities. Please see Custody section above for
further details.
Bankruptcy Disclosure
SRF has not been the subject of a bankruptcy petition at any time during the past ten years.
15
SRF Brochure
May 27, 2025
Privacy Policy
Privacy Policy Notice
Your privacy is important to us. Your personal information is kept secure. Under federal and state law,
you have a right to know what information is being collected about you and how that information will
be used. SRF collects nonpublic personal information about you from the following sources:
Information SRF receives from you on applications or other forms.
Information about your transactions with SRF; and
Information that you specifically have had your other professional advisors forward to SRF.
SRF does not disclose any nonpublic personal information about our customers or former customers to
anyone, except as permitted or required by law, or as directed by you:
Under law, the information SRF collects is provided to companies that perform support services on
our behalf as necessary to effect, administer, or process a transaction, or for maintaining and
servicing your account;
Certain individuals of SRF are licensed as registered representatives for Vanderbilt Financial
Group (CRD#5953), a FINRA member broker/dealer. As a broker/dealer, Vanderbilt Financial
Group has supervision responsibilities for its licensed representatives including business
activities outside of Vanderbilt Financial Group. As such, Vanderbilt Financial Group reviews, has
access to, and maintains all business emails of these supervised persons, including,
communication with and about clients of SRF;
As directed by you, SRF will be working with your other professional advisors and SRF will
provide information in our possession that is reasonably requested by the other advisors.
SRF does not give or sell information about you or your accounts to any other company, individual or
group, except as permitted or required by law. SRF restricts access to nonpublic personal information
about you to those employees who need to know that information to provide services to you. SRF
maintains physical, administrative, and technical procedural safeguards to protect your nonpublic
personal information. You do not need to call or do anything as a result of this notice. It is meant to
inform you of how SRF safeguards your nonpublic personal information.
16
SRF Brochure
May 27, 2025