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Form ADV Part 2A
Disclosure Brochure
This Disclosure Brochure provides information about the qualifications and business practices of
Strategic Blueprint, LLC (“Strategic Blueprint”). If you have any questions about the contents of
this Brochure, please contact us at 678.954.4130. 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.
Strategic Blueprint is a registered Investment Adviser. Registration of an Investment Adviser does
not imply any level of skill or training.
Additional information about Strategic Blueprint (CRD #284840) is also available on the SEC’s
website at www.adviserinfo.sec.gov.
Strategic Blueprint, LLC
2200 Century Parkway, Suite 500
Atlanta, Georgia 30345
(678) 954-4130
www.StrategicBlueprint.net
May 15, 2025
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ITEM 2 – MATERIAL CHANGES
The Strategic Blueprint, LLC (“Strategic Blueprint”) published its annual update of the Brochures
on March 28, 2025.
Revisions since the previous annual update on March 26, 2024 include:
1. On July 1, 2024, Items 5 and 8 were revised to update annuities upon which the firm
provides advisory services and the risks associated with them.
2. On October 17, 2024, in Items 4 and 5, advisory services and fees regarding our Turnkey
Asset Management Programs (“TAMPs”) were further clarified.
3. On January 15, 2025, Item 5 was revised to update conflicts of interest regarding sub-
adviser selection by Advisory Representatives.
Annual Update
We will provide you a Summary of Material Changes to this and subsequent Brochures within 120
days of the close of our business fiscal year (December 31). We will provide other ongoing
disclosure information about material changes as necessary.
Brochure Availability
We will provide our most current Brochure upon request at any time, without charge. Our Brochure
may be requested by contacting our Chief Compliance Officer at 678.954.4130. Additional
information about Strategic Blueprint (CRD #126514) and its Advisory Representatives is
available on the SEC’s website at www.adviserinfo.sec.gov.
(Material Changes Rev.03.28.2025)
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ITEM 3 – TABLE OF CONTENTS
ITEM 3 – TABLE OF CONTENTS ................................................................................................................................ iii
ITEM 4 – ADVISORY BUSINESS .................................................................................................................................. 1
DESCRIPTION OF BUSINESS, PRINCIPALS, AND TYPES OF SERVICES .......................................................... 1
PORTFOLIO MANAGEMENT PROGRAMS ......................................................................................................... 1
SUB-ADVISER MANAGER SELECTION PROGRAMS ........................................................................................ 2
THIRD-PARTY MANAGED SEPARATELY MANAGED ACCOUNTS (“SMAs”) ................................................... 3
TURNKEY ASSET MANAGER PROGRAMS (“TAMPs”) ...................................................................................... 3
FINANCIAL PLANNING SERVICES and FINANCIAL CONSULTING .................................................................. 3
SUBSCRIPTION ADVISORY SERVICES ............................................................................................................. 5
FAMILY OFFICES SERVICES .............................................................................................................................. 6
LECTURES AND SEMINARS ............................................................................................................................... 6
CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS ........................................................ 6
ITEM 5 – FEES AND COMPENSATION........................................................................................................................ 6
PORTFOLIO MANAGEMENT FEES AND COMPENSATION .................................................................................. 6
SUB-ADVISER MANAGER SELECTION PROGRAMS ............................................................................................ 8
TURNKEY ASSET MANAGEMENT PROGRAMS FEES AND COMPENSATION ................................................... 8
FINANCIAL PLANNING AND CONSULTATION FEES AND COMPENSATION ...................................................... 9
RETIREMENT PLAN AND CONSULTING COMPENSATION .................................................................................. 9
LECTURE AND SEMINAR FEES AND COMPENSATION ..................................................................................... 10
SUBSCRIPTION ADVISORY SERVICES FEES AND COMPENSATION .............................................................. 10
ADDITIONAL FEES, COMPENSATION AND EXPENSES ..................................................................................... 10
NEGOTIATION OF FEES AND COMPENSATION ................................................................................................. 11
POTENTIAL CONFLICTS OF INTEREST ............................................................................................................... 11
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................................... 13
ITEM 7 – TYPES OF CLIENTS .................................................................................................................................... 14
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ....................................... 14
ITEM 9 – DISCIPLINARY INFORMATION................................................................................................................... 20
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ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................... 20
ITEM 11 – CODE OF ETHICS ..................................................................................................................................... 21
ITEM 12 – BROKERAGE PRACTICES ....................................................................................................................... 22
ITEM 13 – REVIEW OF ACCOUNTS .......................................................................................................................... 24
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ............................................................................ 25
OTHER COMPENSATION ...................................................................................................................................... 25
CLIENT REFERRALS THROUGH TESTIMONIALS AND ENDORSEMENTS ....................................................... 27
ITEM 15 – CUSTODY .................................................................................................................................................. 28
ITEM 16 – INVESTMENT DISCRETION ..................................................................................................................... 29
ITEM 17 – VOTING CLIENT SECURITIES.................................................................................................................. 29
ITEM 18 – FINANCIAL INFORMATION ....................................................................................................................... 29
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ITEM 4 – ADVISORY BUSINESS
DESCRIPTION OF BUSINESS, PRINCIPALS, AND TYPES OF SERVICES
Strategic Blueprint, LLC (“Strategic Blueprint”) is an Investment Adviser registered with the
Securities and Exchange Commission (“SEC”). Strategic Blueprint is an Atlanta-based, Georgia
corporation, formed in July 2016, and a wholly owned subsidiary of SFA Holdings, Inc. (“SFAH”).
Strategic Blueprint is under common control with The Strategic Financial Alliance, Inc., SFA
Insurance Services, Inc., Green Creek Resources, Inc., Curated Equities, LLC, and Timbrel
Capital LLC. Please refer to Item 10 of this Brochure for additional information about our affiliated
companies.
Through its network of independent Advisory Representatives, Strategic Blueprint offers a range
of advisory and wealth management services as described below, including:
• Portfolio Management Programs
• Selection of and Referral to Third-Party Asset Managers
• Financial Planning
• Retirement Planning
• College Education Planning
• Family Wealth Planning
• Financial Consulting
• Education Events
Advisory Representatives will market their services under doing-business-as names (“DBAs”), as
disclosed in their respective ADV Part 2B Supplements. They will use these DBAs and their
respective logos in their marketing, reporting and communications.
As of December 31, 2024, Strategic Blueprint managed assets valued at approximately $2.67
billion, with approximately $2.63 billion on a discretionary basis and approximately $37 million on
a non-discretionary basis.
PORTFOLIO MANAGEMENT PROGRAMS
Strategic Blueprint offers a customized approach to implementing individualized investment
strategies designed with the goal of meeting your investment objectives through asset allocation,
portfolio design, portfolio monitoring, and consolidated reporting.
In order to participate in the portfolio management programs, Advisory Representatives must be
properly registered, and have at least five years of experience in the financial services industry
(or equivalent experience as determined by Strategic Blueprint).
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Through its Strategic Blueprint Advisor Directed Program, you may select an all-inclusive program
(“wrap fee program”) in which the asset-based fee includes our advisory fee as well as transaction
costs. Alternatively, you may choose a program in which you pay transaction fees in addition to
our asset-based advisory fee. The amount of your advisory fee is negotiated with your Advisory
Representative, based on the program’s published fee schedule. This program is described in
the Strategic Blueprint Advisor Directed Program Brochure.
Management of Participant Directed Accounts. Strategic Blueprint engages an unaffiliated third-
party order management system to facilitate management of participant directed accounts, e.g.,
your 401(k) or 403(b) account. This service is available for most, but not all, participant directed
plans. Strategic Blueprint will not have custody of your funds or access to your personal log-in
credentials. Management fees will be deducted from a separate non-qualified managed account
specified by you. You will receive a link to connect your participant directed account to the
platform which will then authorize your Advisory Representative to have access to your account.
Your Advisory Representative will review the current allocations and will rebalance and/or
reallocate consistent with your stated investment goals and risk tolerance and in accordance with
the Investment Management Agreement. An account may be terminated with written notice at
least 30 calendar days in advance.
SUB-ADVISER MANAGER SELECTION PROGRAMS
Strategic Blueprint evaluates asset managers for selection to participate as portfolio managers in
the programs (“Managers”). Strategic Blueprint, through your Advisory Representative, will assist
you in reviewing the participating portfolio managers. Your Advisory Representative may
recommend managers, strategists, or model portfolios to manage all or a portion of your portfolio
in a manner consistent with your stated financial objectives, risk tolerance and investment horizon.
The selected portfolio manager or managers will, typically, exercise discretionary authority in the
account relative to the assets allocated to that strategy. Your Advisory Representative will monitor
your account and its performance, meet with you periodically and may recommend changing
managers based on your needs and objectives. You may grant discretionary authority to your
Advisory Representative to reallocate among and/or replace Managers, consistent with your
stated objectives, risk tolerance, and time horizon. You will generally be required to grant trading
authority in writing to the sub-adviser through the sub-adviser’s or custodian’s related documents.
This service is offered as part of the Strategic Blueprint Advisor Directed Program.
The individual manager programs, including managers, fees and expenses, are more fully
described in the respective ADV Part 2A and Appendix 1 Disclosure Brochures, which will be
provided to you prior to entering into an advisory agreement. These Brochures are also available
upon request.
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THIRD-PARTY MANAGED SEPARATELY MANAGED ACCOUNTS (“SMAs”)
Separately managed accounts, or SMAs, are portfolios of individual securities managed by an
investment adviser. When you invest in an SMA, you directly own all securities in the account.
There are SMAs managed by third party asset managers available through the custodians which
do not require a separate agreement between the asset manager and Strategic Blueprint in order
for Advisory Representatives to recommend them.
When your Advisory Representative recommends one of these SMAs, you will receive the asset
manager’s Form ADV, complete the respective asset manager’s application, and grant trading
authorization to that manager.
TURNKEY ASSET MANAGER PROGRAMS (“TAMPs”)
Turnkey Asset Manager Programs (TAMPs) offer access to unaffiliated strategists and managers.
The TAMP assesses a fee that generally includes management, the strategists’ fees, and
transaction costs. You will enter into a discretionary Investment Management Agreement with the
TAMP. Your Advisory Representative will recommend strategists and/or model portfolios whose
management style and strategies align with your stated objectives and financial profile. The
strategists and managers will have discretion to select, buy and sell securities in your account(s).
Neither Strategic Blueprint nor your Advisory Representative will exercise discretion in the
selection of individual securities or make investment choices in your account, but your Advisory
Representative may recommend changes in the strategists and models used. These programs
will include asset allocation models, model portfolios, market timing strategies, or other strategies
using an array of investment options, including mutual funds, stocks, bonds, ETFs, and variable
annuity sub-accounts.
Strategic Blueprint through your Advisory Representative typically gathers information about your
financial situation, investment objectives, and reasonable restrictions you wish imposed upon the
management of your account; periodically reviews reports provided to you; monitors your
accounts, and contacts you at least annually to update your financial information and review the
account, its performance and the services of the TAMP; and, communicates changes in your
information to the TAMP as warranted. It is important to notify your Advisory Representative of
any changes in your financial situation, investment objectives, or account restrictions.
Program details are described in the TAMP’s Form ADV Disclosure Brochures.
FINANCIAL PLANNING SERVICES and FINANCIAL CONSULTING
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Financial Planning
Your Advisory Representative will work with you to prepare (1) a comprehensive, written
financial plan designed to help you achieve your financial goals and investment objectives or (2)
a plan limited in scope to a particular area. Preparation of a plan requires that you provide your
Advisory Representative with personal data such as family records, employment records,
budgeting, assets, liabilities, estate information, and tax information. Financial planning is a
process that will address any or all of the following topics as you may request:
insurance planning
• asset protection
•
tax planning
• business succession
• cash flow
• education planning
• estate planning
multi-generational planning
•
• asset allocation
•
risk management
•
retirement planning
• wealth transfer
• charitable gifting
•
long-term care and disability planning
Should you choose to implement the recommendations in your financial plan, we encourage you
to work closely with your attorney, accountant, insurance agent, and other professional advisors.
Certain Advisory Representatives are also registered representatives of The Strategic Financial
Alliance, Inc. (“SFA”), an affiliated broker/dealer, and/or licensed as insurance agents. Although
you may choose to implement the recommendations made in your financial plan through SFA or
your Advisory Representative in his or her capacity as a registered representative or as an
insurance agent, you are free to employ the services of any advisor, registered representative, or
insurance agent of your choice, regardless of whether or not that person is associated with SFA.
Financial Consulting
We offer investment consulting services that are limited to the specific areas you identify. These
services are not considered financial planning services because we will not perform a
comprehensive analysis of your financial position and will not prepare a written report
documenting our review.
The consulting services our Advisory Representatives provide may include (but are not limited
to):
• Assisting you in the preparation of an investment policy statement;
• Reviewing and recommending changes to an existing investment policy statement (or
similar guidelines, policies, and/or investment allocation that you are employing);
• Reviewing existing contracts you have with service providers such as managers and
consultants, and making recommendations for changes;
• Assisting you in renegotiating the fees you pay to service providers and/or assisting
you in conducting a search for new service providers;
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• Analyzing the performance of your current investment manager;
• Advising you regarding the manner in which your investment account is being
managed and, at your request, assisting you in searching for a new investment
manager;
• Advising you on the purchase and sale of particular individual investments;
• Monitoring your transaction costs; and
• Monitoring compliance by your investment managers with your investment policy
statement.
Retirement Plan Consulting
We offer consulting services to retirement plans to employer sponsored qualified retirement plans.
These services may be fiduciary services under ERISA Section 3(21)(A)(ii). Strategic Blueprint
and your advisory representative will act with the diligence, care, and skill that a prudent person
rendering similar services would exercise under similar circumstances. Other services may be
offered on a non-fiduciary basis. Services will be described in the Retirement Plan Consulting
Agreement.
• All services are offered in conformity with the Adviser’s ADV Part 2A Disclosure Brochure
and Part 2A Appendix 1, which Client acknowledges having received, and the Agreement
entered into between Client and Adviser.
• Adviser does not provide legal, tax or accounting advice.
• Adviser does not provide recordkeeping services.
• Adviser will not advise any investment contract, fund or entity in which the Plan has an
equity interest.
• Adviser does not recommend or render advice to utilize any affiliated investment options.
Services include but are not limited to:
Investment monitoring
• Participant education
• Enrollment meetings
• Reviewing investment options
•
• Generating and evaluating service provider requests for proposals
• Service provider transitions
• Review of service providers, including investment managers
• Rebalancing model portfolios
Services may be provided to individual participants only through separate agreements with the
individual for services and/or advice related, for example, to assets held outside the plan or a
rollover to an individual retirement account.
SUBSCRIPTION ADVISORY SERVICES
The Subscription Advisory Services Program (Subscription Program) offers an array of financial
planning and wealth management services selected by you for an annual flat fee, provided on an
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on-going basis to help you adhere to your plan and achieve stated goals and objectives. The
Subscription Program services can include retirement, education, estate, and legacy planning;
wealth management, advice related to accounts held away from the Firm, tax strategies, and
asset allocation. With your authorization, your Advisory Representative will collaborate with your
other advisors, including tax and legal advisors. The nature and frequency of reporting, meetings,
written plans, and other specific services are described and agreed upon in the Subscription
Program Agreement. Investment Management is not offered through the Subscription Program.
FAMILY OFFICES SERVICES
Please refer to the GenCrest Capital Partners Family Offices Services Brochure for more
information. These services are offered through Strategic Blueprint on a limited basis by certain
Advisory Representatives, as described in the respective brochure.
LECTURES AND SEMINARS
Strategic Blueprint sponsors lectures, seminars, or speeches of an educational and generic
nature. A broad range of topics may be included in each seminar including, but not limited to,
asset allocation, retirement planning, risk, tax planning, long-term care and estate planning.
CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
Your Advisory Representative develops and recommends a strategy based on the information
you provide about your financial profile using his or her knowledge and experience. It is very
important that you communicate changes in your information so your Advisory Representative
can make recommendations and manage your account in a manner that is consistent with your
objectives, risk tolerance, and time horizon. You may impose reasonable restrictions on the
manner in which your account is managed, such as limiting investments in certain types of
securities or asset classes, in accordance with your values or beliefs.
Regardless of the services you choose, we strongly encourage you to notify your Advisory
Representative promptly if there are any changes in your personal circumstances, financial
situation, investment objectives, or risk tolerance.
ITEM 5 – FEES AND COMPENSATION
PORTFOLIO MANAGEMENT FEES AND COMPENSATION
The Strategic Blueprint Advisor Directed Account Program offers two fee structures:
• All-Inclusive (“wrap”) account in which the fee includes our advisory fee and
transactions fees; or
• Non-Inclusive account in which the transaction fees are assessed separately from the
advisory fee.
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Fees are negotiated based on the amount of your managed assets and are assessed monthly or
quarterly in arrears based on the average daily balance of your managed account(s). We do not
manage wrap accounts in a manner that differs from non-wrap accounts.
Account Value
All-Inclusive (Wrap)
Maximum Annual Asset-
Based Advisory Fee
Non-Inclusive
Maximum Annual Asset-
Based Advisory Fee
2.25%
2.15%
2.00%
1.75%
1.50%
1.25%
2.15%
2.05%
1.90%
1.65%
1.40%
1.15%
First $250,000
Next $250,000 to $500,000
Next $500,000 to $1,000,000
Next $1,000,000 to $2,000,000
Next $2,000,000 to $5,000,000
Above $5,000,000
All fees are negotiable
These fees do not include the internal fees and expenses associated with the underlying
securities in your portfolio; sub-adviser fees, margin interest, maintenance and termination fees
(if applicable) or other fees and taxes on brokerage accounts and securities transactions.
Please review the fee schedule with your Advisory Representative.
The transaction charges assessed by the custodian of your account in the non-inclusive program
are described in your account opening, and in your Investment Management Agreement.
You may also select an advisory fee negotiated as a flat fee, based on the amount of assets, the
complexity and range of services provided.
For complete fee details, please refer to the respective program brochures, the Appendix 1
Strategic Blueprint Advisor Directed Program.
Advisory Fees Charged to Annuities included in your portfolio:
• Some issuers will allow the deduction of advisory fees from a variable or equity
indexed annuity.
• The maximum advisory fees charged to annuity assets is 1.5% of the contract’s cash
value.
• Advisory fees cannot be deducted from commission-based annuities.
• The advisory fees charged against an annuity contract must be for the services
performed by the investment adviser for that contract only.
• Advisory fees are withdrawn first from the earnings of the annuity contract and will not
reduce the cost basis.
Participant Directed Accounts (e.g., 401k and 403b):
• Strategic Blueprint is charged a fee by an order management system provider for access
to the platform.
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• This fee plus the Strategic Blueprint Access Fee is passed on to the respective Advisory
Representative.
• Your negotiated Advisory Fee will be assessed on the total assets in your accounts and
charged to the separate non-qualified account designated by you when unavailable to be
withdrawn from the participant account.
SUB-ADVISER MANAGER SELECTION PROGRAMS
Sub-advisory fees for each manager have been previously negotiated. Sub-advisory fees range
from .00% to 0.35%.
These fees do not include the fees and expenses associated with the underlying investments or
strategists and funds available through Sub-Advisers and SMAs. Sub-advisers and SMA fees
are in addition to the advisory fee negotiated with your Advisory Representative but the total can
not exceed the maximum annual asset-based advisory fee in the table in Item 4.
Sub-Adviser Fees will appear on your quarterly statement as a separate Advisory Fee from the
fee charged by Strategic Blueprint. If all or a portion of your portfolio is sub-advised by SMArtX,
then the total SMArtX fee plus the strategists’ fees will be combined and appear on your statement
as a single charge.
Certain SMA asset managers may charge their fees in advance, rather than in arrears. This will
be described in the respective Form ADV, and on the Fee Schedule.
Please refer to the Strategic Blueprint Advisor Directed Brochure for more complete information
about fees assessed for Sub-Advisers.
TURNKEY ASSET MANAGEMENT PROGRAMS – FEES AND COMPENSATION
Fees, services provided, payment structure, termination provisions, and other aspects of each
program are detailed and disclosed in the TAMP’s Form ADV Part 2 and Appendix 1 wrap fee
program disclosure brochures. The TAMP will also deduct Strategic Blueprint’s fee from your
account. These fees will be disclosed in the agreement signed with the TAMP and will not exceed
the maximum advisory fees disclosed in Strategic Blueprint’s Form ADV. Fees will vary
depending upon the program selected, the size of the account, and the services covered. Under
some programs, an inclusive fee covers account management, brokerage, clearance, custody,
and administrative services. In other programs, the account may be charged separately for such
services.
The fees mentioned above are in addition to the internal management fees and expenses paid
by the mutual funds, ETFs, or variable annuity companies to their separate investment advisors.
In addition, variable annuity companies generally impose mortality charges on such accounts.
Fees are payable in advance or in arrears as described in the TAMP’s Form ADV and wrap fee
program brochures.
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FINANCIAL PLANNING AND CONSULTATION FEES AND COMPENSATION
Advisory Representatives may charge a fixed or hourly fee for financial planning and
consultations. Fees are negotiated with each client depending on the complexity of the situation,
the services provided and experience of the representative. The fee charged generally does not
exceed a flat fee of $10,000 or an hourly rate of $500 per hour. Due to the complexity of some
financial plans and consulting arrangements, a higher fee may be negotiated.
The agreed upon fee may be billed in advance, during or throughout the engagement as agreed
upon with your Advisory Representative. However, $1,200 or more of the fee cannot be billed
more than six months in advance of delivery of services related to the plan or consultation, in
accordance with your Financial Planning or Consulting Agreement.
Financial Planning services may be included in portfolio management services as described in
your Investment Management Agreement, and as negotiated with your Advisory Representative.
You may terminate the planning/consulting agreement without penalty within five business days
after signing the agreement. Thereafter, you may terminate the planning or consulting agreement
upon written notice. If you terminate the agreement, Strategic Blueprint will refund unearned fees
based upon the time and effort expended by Strategic Blueprint prior to the termination, as
determined by the Advisory Representative. Strategic Blueprint reserves the right, at its sole
discretion, to refund all of the fee paid based on individual circumstances. Strategic Blueprint will
bill you for any unpaid fees for services provided prior to termination.
If you choose to implement your financial plan or any recommendations through your Advisory
Representative in his or her capacity as a registered representative of The Strategic Financial
Alliance, Inc., or a licensed insurance agent, he or she will receive additional compensation in the
form of sales commissions and, in some cases as described in the product offering materials, trail
commissions such as 12b-1 fees.
RETIREMENT PLAN AND CONSULTING COMPENSATION
Fees for Retirement Plan Consulting may be charged as an asset-based fee determined by plan
assets, as a fixed fee, or an hourly fee. The fee will be negotiated between you and your Advisory
Representative and will be based on the scope and complexity of the services to be provided.
Fee Schedule rates will be based on the following:
• Fixed Fee
• Hourly Fee
• Percentage of Plan Assets: Based on specific asset levels in a Plan at dates provided in
the engagement, fees can range up to 125 basis points (1.25%).
Fees are charged in arrears. As the Plan Sponsor, you may specify whether the fees are paid
directly or from the plan assets. The amount of the fee, the frequency, and the method of payment
will be described in the Retirement Plan Consulting Agreement.
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The fees charged may be more or less than if the same services were purchased through another
firm. You should consider the fees charged by the underlying investments, the plan’s other
services providers, plus the fees charged by Strategic Blueprint when evaluating the total amount
of fees paid for services to the Plan.
LECTURE AND SEMINAR FEES AND COMPENSATION
Strategic Blueprint may charge attendees a fee for attending such lectures and seminars. Fees
for seminars are paid to Strategic Blueprint or to a billing agent designated on the application
form. Fees are negotiable at the sole discretion of Strategic Blueprint. Fees are due at or prior
to attendance unless otherwise specified and are not refundable.
SUBSCRIPTION ADVISORY SERVICES FEES AND COMPENSATION
The Annual Flat Fee is negotiable and based on the complexity and scope of your financial
situation, including but not limited to your net worth, income, total investable assets, tax situation,
number of accounts and account types, employment (i.e., self-employed or W-2 employee),
number of family members, trusts, current transitions, and any additional factors we determine
that may add to the complexity of your financial life.
The Annual Flat Fee does not include asset management. Asset management is covered by a
separately executed Investment Management Agreement.
The Annual Flat Fee is billed quarterly (or monthly, as agreed) in arrears and assessed pro rata
depending on when services commence.
An initial negotiated fee (separate from and in addition to the flat fee) may be assessed for the
establishment of the services, including account opening and an initial plan. This initial fee may
be waived at the discretion of your Advisory Representative on behalf of the Firm.
Your Advisory Representative will review fees periodically and may increase fees based on
certain factors such as the complexity of your financial situation, and/or the addition of investable
assets and accounts under our management. No fee increase will be effective until you sign a
new or amended Subscription Agreement fee schedule.
ADDITIONAL FEES, COMPENSATION AND EXPENSES
Strategic Blueprint’s fees for non-inclusive accounts are exclusive of brokerage commissions,
transaction fees, and other related costs and expenses which may be incurred. Whether you are
in a wrap account or a non-inclusive account, you can incur certain charges imposed by
custodians, brokers, third-party asset managers and other third parties such as custodial fees,
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees,
termination fees for qualified plans, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds, index funds, annuities, and exchange traded funds also
incur internal expenses and management fees, which are disclosed in a fund’s prospectus or an
annuity contract. Such charges, fees and commissions are exclusive of and in addition to
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Strategic Blueprint’s advisory fee. Fees assessed by the custodian are disclosed in its account
documentation.
If you purchase alternative investments in your managed accounts, additional custodial fees will
be charged by your account custodian.
If you purchase alternative investments through SFA as the executing broker/dealer, SFA will
generally receive compensation from the issuer (or managing broker-dealer) for commissions,
marketing and/or due diligence. SFA is affiliated with Strategic Blueprint. This compensation is
not shared with your Advisory Representative. If your Advisory Representative, in his or her role
as a Registered Representative, earns a commission on your purchase of an alternative product
through SFA, no advisory fee will be assessed on that asset when it is held in your managed
account.
Some alternative investments and other products (such as annuities) offered through SFA as a
broker-dealer are also available with reduced or waived sales commission (often referred to as
Advisor Class shares). If these products are made available for managed accounts, an advisory
fee would be assessed on the value of that investment if included as part of your managed
portfolio. It is important to discuss the costs and fees associated with these investments with your
Financial Advisor to determine the most appropriate and beneficial way to purchase these
investments. Please see Item 14 Client Referrals and Other Compensation for more information
about alternative investment products available through the Strategic Blueprint platform.
The advisory fees paid for Financial Planning and Consulting services do not include the costs
associated with implementing any recommendations.
NEGOTIATION OF FEES AND COMPENSATION
Fees are negotiated on a case-by-case basis, depending on a variety of factors, including the
nature and complexity of the particular service, your relationship with Strategic Blueprint and your
Advisory Representative, the size of the Account, the potential for other business or clients, the
amount of work anticipated, and the attention needed to manage your Account. Please note that
the same or similar services to those described above may be available elsewhere to you at a
lower cost. Your Advisory Representative may negotiate a fee that is more or less than fees
negotiated by other Strategic Blueprint Advisory Representatives for similar services.
POTENTIAL CONFLICTS OF INTEREST
In addition to providing advisory services, Advisory Representatives can offer securities products
and other investment and insurance products in their capacities as registered representatives of
the Strategic Financial Alliance, Inc. (SFA) and as licensed insurance agents. SFA, and its
registered representatives, will receive compensation in connection with this activity and the
amount of compensation will depend on the type of product purchased. This compensation is
disclosed in the product prospectus or offering documents. Advisory Representatives who are
also registered representatives may have a greater financial incentive to recommend certain
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products as opposed to others. Your Advisory Representative will make recommendations based
on your stated investment objectives, risk tolerance, and time horizon. Security transactions
executed through SFA are reviewed for suitability by a designated supervisor.
No commissions or 12b-1 fees are paid to Strategic Blueprint or your Advisory Representative on
those securities recommended and purchased in your Strategic Blueprint accounts. Certain third-
party asset managers with which Strategic Blueprint has entered into sub-advisory, co-advisory
and/or promoter’s agreements provide marketing support to Strategic Blueprint and its Advisory
Representatives for meetings and other functions. They may also provide software and other
tools to assist our Advisory Representatives in providing services to you.
Strategic Blueprint imposes an access fee on Advisory Representatives who choose to utilize
sub-advisers. Your Advisory Representative may have incentive to recommend or avoid certain
investments or platforms because of the additional associated fees.
to Strategic Blueprint
located on
the Disclosures
Sponsors, sub-advisers, TAMPs, and issuers of alternative investments sponsor training and due
diligence programs for Advisory Representatives. They may also provide marketing support to
Strategic Blueprint, its affiliated companies, and Advisory Representatives for conferences,
education, training and client appreciation events. The sponsors of the alternative investments
available through Strategic Blueprint pay an annual fee in order to make their products available.
Your Advisory Representative does not receive any portion of those fees. You may obtain a list
of those sponsors and those companies that provide marketing support in the Additional Sources
of Financial Benefits
tab at
www.strategicblueprint.net, by contacting the Chief Compliance Officer at 678.954.4130, or by
emailing Clientservices@strategicblueprint.net.
Your Advisory Representative can participate in conferences and educational programs
sponsored by SFAH affiliated companies. These conferences generally receive the financial
support of product sponsors, asset management, and vendors. When attending such
conferences, your Advisory Representative will receive non-cash compensation in the form of
travel expenses, meals, and other services based on the amount of assets managed plus
commissions and compensation earned through the SFAH affiliated companies.
The participation in this support gives the companies an advantage over other sponsors, asset
managers, and vendors in that representatives of these two asset managers have more
opportunity to discuss their products and services with those advisory representatives who
participate in the conferences.
If your Advisory Representative recommends certain alternative products, the product sponsor
can pay for reasonable costs related to due diligence conducted by the Advisory Representative,
including travel to visit the sponsor and/or the investment site.
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Certain Advisory Representatives and members of Strategic Blueprint management and home
office employees are shareholders of SFA Holdings, Inc. (“SFAH”), parent company of Strategic
Blueprint, SFA and other entities. Shareholders will benefit from the profits accrued to SFAH in
the form of dividends, as well as the potentially enhanced value of the stock. All advisory
representatives of Strategic Blueprint and registered representatives of SFA are awarded stock
options based on the assets they manage and non-asset based revenues, and to registered
representatives of SFA based on the revenues they generate. As profits accrue from the sale of
securities products and investment advisory services of the respective registered entities, the
value of SFAH stock can be enhanced. SFAH stock ownership creates a conflict of interest for
representatives.
Please be aware that you are under no obligation to purchase products or services recommended
by us or your Advisory Representative. Your Advisory Representative will answer any questions
you have about fees and expenses of the products recommended. Additionally, Strategic
Blueprint has adopted a Code of Ethics, as described in Item 11 of this Brochure, which describes
the standard of conduct required of our Advisory Representatives.
If your Advisory Representative is also registered with SFA or is a licensed insurance agent, you
are under no obligation to purchase securities and/or insurance products and services through
him or her in that capacity. Neither are you obligated to purchase any products or services
through SFAH affiliated companies.
If a conflict of interest exists between an Advisory Representative, employee, or related entity and
any client or client’s holdings, Advisory Representatives are responsible to disclose such conflicts
to the Strategic Blueprint Compliance Department. The Compliance Department will determine
the materiality of such conflicts. Material conflicts will be disclosed to you. You will be offered an
opportunity to waive such conflicts, to work with another Advisory Representative, or to move your
assets to another investment advisory firm.
Strategic Blueprint monitors for potential conflicts of interest through reviews of client accounts;
reviews of Advisory Representatives’ personal securities accounts, their correspondence, email
and other communications; and their outside business activities. Any Advisory Representative
knowingly placing personal interest above that of a client will be subject to disciplinary action, up
to and including termination.
You will receive an ADV Part 2B Supplement with information about your Advisory
Representative, including credentials, education, and conflicts of interest.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
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Strategic Blueprint does not charge any performance-based fees (fees based on a share of capital
gains on or capital appreciation of the assets of a client).
Certain third-party asset managers may assess a performance-based fee, which will be described
in the respective manager’s disclosure brochure. In some cases, a portion of the performance fee
may be shared with Strategic Blueprint and Advisory Representative(s) as a promoter’s fee. Any
such arrangement will be described to you in a written Promoter’s Disclosure Statement.
ITEM 7 – TYPES OF CLIENTS
Strategic Blueprint provides investment advisory services to individuals, high net worth
individuals, pension and profit-sharing plans,
trusts, estates, charitable organizations,
corporations, and other business entities.
Strategic Blueprint anticipates a minimum account size of $25,000 for managed accounts. This
minimum account size serves as a guideline only. Please consider that the management fee and
the underlying costs of investments in an account impact the performance of the account. This
impact can be more profound in a smaller account.
The minimum account sizes required for participation in the programs sponsored by third-party
asset managers are described in the manager’s respective disclosure brochures.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK
OF LOSS
Strategic Blueprint’s Representatives will rely on various types of tools and methods to assist in
recommending or selecting investment strategies to you, including asset allocation and various
types of software. Strategic Blueprint’s methods of analysis include charting analysis,
fundamental analysis, technical analysis, and cyclical analysis. The main sources of information
used to formulate investment advice and/or manage assets includes financial newspapers and
magazines, research materials prepared by others, corporate rating services, timing services,
annual reports, prospectuses, fillings with the SEC, and company press releases. The investment
strategies used to implement any investment advice given to clients include long-term purchases
(securities held at least a year), short-term purchases (securities purchased and sold within a
year), margin transactions, and option writing. Investment returns are highly dependent on the
value of underlying securities which are impacted by trends in the various investment markets.
We generally recommend stocks, bonds, ETFs, and mutual funds. We may also recommend
certain alternative or illiquid investments and certain fee-based annuities. Investing involves the
assumption of risks, which may include the following:
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Investing in stocks involves the assumption of risk, including:
• Financial Risk: the risk that the companies we recommend to you may perform poorly,
which will affect the price of your investment.
• Market Risk: the risk that the Stock Market will decline, decreasing the value of the
securities we recommend to you.
•
Inflation Risk: the risk that the rate of price increases in the economy deteriorates the
returns associated with the stock.
• Political and Governmental Risk: the risk that the value of your investment may change
with the introduction of new laws or regulations.
Investing in bonds involves the assumption of risk, including:
•
Interest Rate Risk: the risk that the value of the bond investments we recommend to you
will fall if interest rates rise.
• Call Risk: the risk that your bond investment will be called or purchased back from you
when conditions are favorable to the bond issuer and unfavorable to you.
• Default Risk: the risk that the bond issuer may be unable to pay you the contractual interest
or principal on the bond in a timely manner or at all.
•
Inflation Risk: the risk that the rate of price increases in the economy deteriorates the
returns associated with the bond.
Investing in Exchange Traded Funds (“ETFs”) and Exchange Traded Notes (“ETNs”)
(including Buffer ETFs) involve the assumption of risk, including:
• The public trading price of a redeemable lot of the ETFs may be different from its net asset
value. Declining stock prices can cause losses to your investment.
• Some leveraged and inverse ETFs and ETNs "reset" daily, meaning that they are
designed to achieve their stated objectives on a daily basis. If held for a period longer than
one day, their performance over the longer periods of time can differ significantly from the
stated multiple of the performance (or the inverse of the performance) of their underlying
index or benchmark during the same period of time. This effect can be magnified in volatile
markets.
• ETFs and ETNs linked to commodity futures do not offer direct exposure to the
commodity’s spot price and may perform differently than the spot price for the commodity
itself.
• You should not assume that an ETF or ETN that is linked to commodity futures will provide
an effective hedge because of a negative correlation with equities or other asset classes.
Investing in mutual funds involves the assumption of risk, including:
• Manager Risk: the risk that an actively managed mutual fund’s investment adviser will fail
to execute the fund’s stated investment strategy.
• Market Risk: the risk that the Stock Market will decline, decreasing the value of the
securities contained within the mutual funds we recommend to you.
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•
Industry Risk: the risk that a group of stocks in a single industry will decline in price due to
adverse developments in that industry, decreasing the value of mutual funds that are
significantly invested in that industry.
•
Inflation Risk: the risk that the rate of price increases in the economy deteriorates the
returns associated with the mutual fund.
Investing in interval funds involves the assumption of risk, including:
• Liquidity Risk: Interval funds, a type of closed-end mutual fund, are not traded on a
secondary market; shares may be redeemed at intervals, generally quarterly; and the fund
may limit the periodic redemptions to 5% or less of outstanding shares. If liquidation is
requested, it could take more than one interval (e.g., quarter) to liquidate all the shares in
your account.
•
Interval funds generally invest in unlisted, more complex products such as real estate
investment trusts and limited partnerships. These underlying non-traded investments are
valued by the respective asset manager as of a specific date, so the valuation of an interval
fund may vary from the fair market value of the investment that would be obtained if the
underlying investments were sold to a third party.
Investing in Alternative Investments (“Alternatives”) involves the assumption of risk, including:
• Alternatives are generally more complex products which are not correlated to the general
market, and include non-traded REITs, direct participation programs, private placements,
private equity, hedge funds, and preferred stock of non-traded REITs.
• There may be no public market so these investments may not be sold quickly or
rebalanced.
• Because there is no public market, the shares are not valued daily. An appraised value
may be available only on a periodic basis and may not reflect the value you would obtain
if a market did exist. The appraised value may be more or less than the amount you
invested.
• Privately offered investments (e.g., Reg D programs) may not be valued until there is a
liquidation event, which can be years after the initial investment. These investments are
often valued by the issuer at the initial investment amount, which does not reflect the value
you would obtain if a market existed. If these investments are included in your managed
account, the advisory fee will be assessed on the value provided by the issuer as
described in the offering memorandum, which could be the invested amount and not the
true value of the asset.
• Alternatives are long-term investments. The holding period will vary by product before a
liquidation event is executed.
• Many Alternatives are not registered with the SEC so do not afford the benefits of public
disclosure and reporting.
• Many Alternatives are speculative. The risks associated with an investment are described
in the offering documents. Read the offering documents carefully before investing.
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• Privately offered, non-public investments classified as Alternatives may not be purchased
on a discretionary basis in your account.
• The percentage of Alternatives held in a managed account will be limited based on your
liquidity needs, net worth, investment objectives, risk tolerance, custodial limitations and
any state or regulatory limitations.
• Additional fees may be assessed by account custodians related to holding certain
alternative investments in managed accounts.
Investing in Real Estate Investment Trusts (“REITs”) involve the assumption of risk, including:
• Changes in economic conditions and real estate markets can affect a REIT’s ability to
deploy proceeds and can impact the REIT’s performance.
• A perpetual REIT has no specific liquidity event or liquidity date contemplated.
• There is not a public market for non-traded REITs so you will be unable to sell or reallocate
your shares quickly. Limited redemption programs are described in the offering
documents.
Investing in Non-Traded Redeemable Preferred Stock of publicly traded REITs involves the
assumption of risk, including:
• There is no public market. After a required holding period (if any), shares may be
redeemed.
• Some securities impose a sliding redemption fee, so if your investment is liquidated during
the redemption period, you will pay a penalty which will lower the potential return on your
investment.
• After the holding period, shares may be redeemed at par. In some cases, shares may be
redeemed for shares of the issuer’s common stock.
• There is market risk when you sell common shares of thinly traded stock.
• The underlying shares of the Non-Traded Redeemable Preferred are publicly traded, have
ready liquidity.
The use of Barrier and Buffered Notes involve the assumption of risk, including:
• These Notes provide only limited downside protection against loss and only if the note is
held to maturity.
• You can lose up to 100% of your principal invested in a Note if the reference asset(s)
declines by more than the stated barrier or buffer level at maturity.
• Gains on the Notes are subject to a cap so you may not benefit from the full upside of the
reference asset(s).
• These Notes lack liquidity. They are not listed on any securities exchange, but if a
secondary market were to develop, the prices may be less or more than the original
investment.
• Buffered Notes do not pay dividends. Payment at maturity of the Note will reflect
cumulative performance.
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• Some Barrier Notes may not pay dividends, while others may pay periodic dividends
contingent on the performance of the reference asset(s).
• An automatic call feature associated with some Barrier Notes can force a potential early
exit which would terminate future coupon payments.
• These notes are not obligations of a bank and are not guaranteed by any governmental
agency or program of the United States or other jurisdiction.
• All payments on these Notes are subject to the creditworthiness of the issuer.
The use of annuities involve the assumption of risk, including:
•
If a contract has a Market Value Adjustment feature, there may be a penalty for withdrawal
if the interest rate moves between issue and surrender date.
• Fixed annuities are not inflation proof.
• The upside growth of an equity indexed annuity is limited by the index selected.
• These products may be subject to a penalty schedule if redeemed prior to a specified date.
• The guarantees on any annuity are dependent on the financial ability of the issuer to fund
those guarantees.
• Certain payout options may end before death or may not provide residual value to
•
beneficiaries.
Investment accounts within a variable annuity will fluctuate with the stock and bond
markets.
The use of margin, options and short sales are higher risk strategies:
• Option transactions are limited to writing covered calls, writing cash secured puts,
purchasing options, and certain spread strategies. It is possible to lose all of the principal
you invest.
• Option spreads are strategies that typically involve two or more options on the same
underlying asset, but with different expiration dates or strike prices.
• Writing a covered call will limit upside potential of the underlying asset, in exchange for
the premium earned. This strategy does not protect against downside risk of owning the
asset.
•
• When writing cash secured puts, losses can be significant when the price of the stock falls
and you are obligated to buy the stock at the strike price. This loss is reduced by the
premium received for selling the put option.
In a cash account, your risk is limited to the amount of money that you have invested. In
a margin account, your risk includes the amount of money invested plus the amount that
has been loaned to you.
• When you sell short, your losses can be infinite.
When funds in your managed account are allocated to cash, the funds will earn interest in a cash
account or money market fund through the account custodian:
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• Cash accounts are generally intended as a place to hold cash pending investment or for
immediate cash needs, not solely for the purpose of receiving interest.
• The interest rates will generally be less than the investment management fee when the
cash allocation is included in your billable assets.
• The custodian can earn income from holding client cash.
• The custodian can earn fees from money markets for marketing, distribution and other
services (see the money market prospectus).
• As a result, the custodian and adviser will likely earn more than you on your cash assets.
When your custodian offers an FDIC-insured cash account, coverage will be defined by the
FDIC limits of coverage:
• Limits are up to $250,000 per account owner, per legal capacity per bank. This means
that all accounts held by you in the same legal name at the same bank will be aggregated
to determine the coverage limits.
• When your FDIC insured accounts are maintained through multiple banks, the limit across
banks per account owner per legal capacity is $500,000.
• Additional information about FDIC insurance is available at www.fdic.gov.
The use of securities associated with Digital Assets, Virtual Currencies, or Cryptocurrencies,
involve the assumption of risk, including:
• Digital Assets are deemed commodities, not securities.
• Digital Assets are speculative investments. They lack intrinsic economic value.
• The market for Digital Assets is decentralized and unregulated.
• Digital Assets are not legal tender.
• These assets have a history of high volatility. The value may change drastically in a short
period of time.
• Because these assets are virtual, they are susceptible to fraud, hackers, technical
problems, and malicious software.
• The value of a digital asset is directly related to its supply and demand.
• You may obtain exposure to Digital Assets through funds, grantor trusts, and private
placements without purchasing the actual asset.
You should also be aware that transactions in the account (including account reallocations and
rebalancing) may trigger a taxable event for you unless your account is a qualified retirement
account.
When using third party investment managers, each manager will have its own methods of
analysis, investment strategies and unique investment risks that should also be reviewed and
considered. In instances where we recommend that a third-party manage your assets, please
refer to the third party’s ADV Part 2A and Appendix 1 disclosure brochures for details on their
investment strategies, methods of analysis and associated risks.
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Investing in securities involves risk of loss that you should be prepared to bear.
ITEM 9 – DISCIPLINARY INFORMATION
Strategic Blueprint has no reportable disciplinary information.
On October 29, 2015, the Strategic Financial Alliance, Inc. (SFA), an affiliated company, entered
into an Acceptance, Waiver and Consent with the Financial Industry Regulatory Authority
(“FINRA”) concerning its supervision of and procedures related to consolidated reports. Without
admitting or denying the allegations, SFA consented to a censure and a $30,000 fine. SFA was
also required to submit an attestation that it had implemented procedures which more fully
addressed the supervision of consolidated reports.
Information about your Advisory Representative is available in his or her Supplement to this
brochure, and at www.adviserinfo.sec.gov.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Strategic Blueprint’s sole business purpose is to be a registered investment adviser.
Strategic Blueprint is wholly owned by SFA Holdings, Inc. (SFAH). SFAH also owns the Strategic
Financial Alliance, Inc. (SFA), a registered broker-dealer, member of FINRA and SIPC, and an
SEC-registered investment adviser. Strategic Blueprint shares office space, technology,
including servers and email archiving, and employees with SFAH and SFA. Compliance,
supervisory, and finance personnel provide similar functions for both companies.
SFA Partners is wholly owned by SFA Holdings, Inc. It provides services shared by SFA,
Strategic Blueprint, and SFA Insurance Services, including human resources, marketing,
recruiting, advisor relations, accounting, and due diligence.
Individuals affiliated with Strategic Blueprint may also be registered representatives of SFA. They
may also associate as advisory representatives of SFA. SFA and its registered representatives
offer securities and financial products in addition to rendering investment advice. Please refer to
your Advisory Representative’s ADV Part 2B.
Representatives associated with Strategic Blueprint can also be licensed to sell insurance
products with the states in which they do business, and are appointed by various insurance
companies, including through Strategic Blueprint’s affiliated insurance agency, SFA Insurance
Services, Inc.
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SFAH owns 50% of Green Creek Resources, LLC and 50% of Curated Equities, LLC, both
managers and sponsors of pooled investment programs. Green Creek Resources, Curated
Equities, and Strategic Blueprint share office space and certain employees.
Timbrel Capital LLC (Timbrel), member FINRA and SIPC, is a registered broker-dealer formed in
2019 and is wholly owned by SFAH. It provides wholesaling and consulting services to sponsors
of alternative investments, including Reg D private offerings and unregistered public programs.
Timbrel does not conduct business directly with retail investors. Timbrel and Strategic Blueprint
share office space, certain personnel, and systems. If your Advisory Representative recommends
a program or fund that is sponsored by a client of Timbrel, disclosure will be made to you.
Clive Slovin, President of SFAH, certain employees and certain Advisory Representatives are
shareholders of SFAH, parent company of Strategic Blueprint. Shareholders will benefit from the
profits accrued to SFAH from any of its subsidiaries in the form of dividends and enhanced stock
value. SFAH offers stock options to employees; to persons registered with SFA based on the
revenues they produce; and, to persons registered with Strategic Blueprint based on the assets
they manage and non-asset-based revenues.
Clients are under no obligation to purchase insurance products, securities products, or other
products or services through SFA and its associated persons. While Strategic Blueprint and its
Advisory Representatives endeavor at all times to put the interests of clients first, you should be
aware that the receipt of additional compensation itself creates a conflict of interest and may
potentially affect the judgment of these individuals when making recommendations.
ITEM 11 – CODE OF ETHICS
We have adopted a Code of Ethics (“Code”) to address the standard of business conduct required
of our Advisory Representatives and employees. The Code includes our policies and procedures
developed to protect your interests in relation to the following:
• Duty at all times to place your interests ahead of ours;
• All personal securities transactions of our Advisory Representatives and employees must
be conducted in a manner consistent with the Code and avoid any actual or potential
conflict of interest, or any abuse of an Advisory Representative’s or employee’s position
of trust and responsibility;
• Advisory Representatives may not take inappropriate advantage of their positions; and
•
Information concerning the identity of your security holdings and financial circumstances
is confidential and must be safeguarded.
We will provide a copy of the Code to you or any prospective client upon request.
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We do not buy or sell securities for our own account that we also recommend to you. Our Advisory
Representatives and employees are permitted to buy or sell the same securities for their personal
and family accounts that are bought or sold for your account.
The personal securities transactions by our Advisory Representatives and employees may raise
potential conflicts of interest when they trade in a security that is owned by you or is being
considered for purchase or sale for your account.
We have adopted policies and procedures that are intended to address these conflicts of interest.
These policies and procedures:
• Require our Advisory Representatives and employees to act in your best interest,
• Prohibit favoring one client over another, and
• Provide for the review of transactions to monitor that an Advisory Representative or
employee does not place a trade in a personal or beneficial account in front of a client’s
transaction in the same security.
Our Advisory Representatives and employees must follow our procedures when purchasing or
selling the same securities purchased or sold for your account.
ITEM 12 – BROKERAGE PRACTICES
Strategic Blueprint does not maintain custody of client assets. All managed accounts will be
custodied by a qualified custodian, including Fidelity Brokerage Services, LLC (“Fidelity”),
member FINRA/SIPC; or, Schwab Advisor Services division of Charles Schwab & Co., Inc.
("Schwab”), member FINRA/SIPC. Your Advisory Representative will generally recommend one
of these custodians exclusively for the custody of client funds and securities and for trade
execution. We are independently owned and operated and are not affiliated with any of the
custodians.
When recommending custodians to our clients, we consider many factors, including execution
and custody services, availability of investment products, investment research and tools, quality
of services, competitiveness of price for those services, reputation, financial strength, security
and stability of the custodian.
In addition to brokerage and custody services, Fidelity provides access to research, software, and
education opportunities.
Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving
independent investment advisory firms like ours. Schwab provides us and our clients with access
to its institutional brokerage – trading, custody, reporting and related services – many of which
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are not typically available to Schwab retail customers. Schwab also makes available various
support services. Some of those services help us manage or administer our clients’ accounts
while others help us manage and grow our business. Schwab’s support services are generally
available on an unsolicited basis and at no charge to us as long as we maintain a total of at least
$10 million of our clients’ assets in accounts at Schwab. (Please see the disclosure under Item
14 below.)
Schwab’s institutional brokerage services include access to a broad range of investment products,
execution of securities transactions, and custody of client assets. The investment products
available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit clients or their account(s).
Certain services offered by Fidelity and Schwab generally benefit only Strategic Blueprint and our
advisers. These services are offered to help us manage and grow our business. These services
include educational conferences and events; consulting on technology, business needs, and legal
and compliance needs; publications and conferences on practice management and business
succession; access to employee benefits and insurance providers, and human resources
consultants; marketing consulting and support; and recruiting.
Commissions and other fees for transactions executed through our account custodians (i.e.,
Fidelity or Schwab) may be higher than commissions and other fees available if you use another
custodian firm to execute transactions and maintain custody of your account. Fees assessed by
the custodian of your account will be disclosed to you in the respective custodian’s account
opening documents.
Strategic Blueprint does not have soft dollar arrangements wherein commissions are used to pay
for research. The benefits received from a custodian are not based on the number of transactions
executed through the custodian.
Bunched Trading
We may engage in “bunched trading,” which is the purchase or sale of a security for the accounts
of multiple clients in a single transaction. If a bunched trade is executed, each participating client
receives a price that represents the average of the prices at which all of the transactions in a given
bunch were executed. If the order is not completely filled, the securities purchased or sold are
distributed among participating clients on a pro rata basis or in some other equitable manner.
Transactions for the accounts of our Advisory Representatives and employees may be included
in bunched trades. They will receive the same average price as clients.
Transactions for the accounts of our Advisory Representatives or employees will not be favored
over transactions for client accounts.
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We are not obligated to include any client transaction in a bunched trade. Bunched trades will
not be effected for any client’s account if doing so is prohibited or otherwise inconsistent with that
client’s investment advisory agreement. No client will be favored over any other client.
ITEM 13 – REVIEW OF ACCOUNTS
Security purchases and sales effected in your account are monitored for suitability by a
designated supervisor. Advisory Representatives review advisory accounts with you at least
annually. Transactions in the accounts are reviewed on an ongoing basis. Interim reviews may
be triggered by changes in political, economic or market conditions or if there are changes in your
stated financial profile.
Reviews for financial plans occur upon the engagement as part of the financial planning process.
The extent of reviews depends on the arrangement with you. Thereafter, reviews are conducted
according to the financial planning agreement. Financial planning clients receive a financial plan
in the agreed upon form upon completion of the plan. Updates to the financial plan and
subsequent reviews are conducted as determined by advisor and client as outlined in the
Financial Planning Agreement.
Strategic Blueprint’s Advisory Representatives render investment advisory services to clients
using different methods. Advisory Representatives may offer any or all of the advisory services
described in this Brochure. Strategic Blueprint instructs each Advisory Representative that
manages accounts to review accounts with their clients, at least annually, as to suitability of the
portfolio relative to stated financial needs and objectives, and to determine what action, if any, is
indicated. Broader reviews are performed periodically by the Advisory Representative’s
designated supervising principal and/or the Strategic Blueprint Compliance Department, or their
qualified designees.
The custodian of your managed account(s) provides quarterly brokerage account statements.
You will also receive monthly statements for those months in which there is activity in your
account. Please review your statements carefully to make sure that your account is being
managed according to your stated objectives. Your statement will also show the amount of any
advisory fee deducted from your account.
Performance reports for your managed account(s) will generally be made available no less than
quarterly, as agreed upon between you and your Advisory Representative.
Third-party asset managers to which Strategic Blueprint has referred clients provide statements
and performance reports to clients, monthly or quarterly, based on the TPAM’s disclosure
brochure and their agreement with the client.
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ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
OTHER COMPENSATION
In certain instances, product sponsors, investment companies, and asset managers (“product
sponsors”) will participate in activities that are designed to help facilitate the distribution of their
products, such as marketing activities and educational programs, and by offsetting expenses that
result from the cost of conducting initial and on-going due diligence on their products. In return
for assistance in facilitating the activities described above, Strategic Blueprint generally receives
additional compensation from product sponsors in the form of financial support for conferences
and educational programs. SFA, an affiliated company, may receive marketing support, due
diligence fees, and other financial benefits from product sponsors and third-party managers.
Advisory Representatives will indirectly share in non-cash benefits when that additional
compensation is used by Strategic Blueprint and/or SFA for conferences, meetings or other
educational opportunities.
to Strategic Blueprint
located on
the Disclosures
These companies will have greater access to our representatives to provide training, education
presentations and product information. And this additional exposure and compensation can give
rise to a financial incentive for Strategic Blueprint to recommend these products over other
products where such financial incentives are not present. Please see the Additional Sources of
tab at
Financial Benefits
www.strategicblueprint.net for additional information.
While Strategic Blueprint and its Advisory Representatives endeavor at all times to put the
interests of our clients first, you should be aware that the receipt of additional compensation itself
creates a conflict of interest and can potentially affect the judgment of these individuals when
making recommendations.
Alternative and Complex Investments
Strategic Blueprint makes available a select group of alternative investments for managed
portfolios. The products are vetted through a due diligence process and must be approved by
Strategic Blueprint. They are then monitored during the life of the investment. These products
are generally purchased by subscription and will have limited or no liquidity. Because there is no
public market for these securities, they are valued only periodically. The value on your statement
may not reflect the price you would receive if you were able to liquidate the holding. The value
provided to the custodian by the issuer or other third party will be included in the asset value of
your account for the purpose of calculating advisory fees. Risks associated with these programs
are outlined in the product’s prospectus or offering document. Many of the general risks are
outlined in Item 8 herein. Advisory Representatives who recommend these products complete
product specific training as determined by Strategic Blueprint.
Advisory Representatives will be limited to recommending alternative investments for your
managed account(s) that are included on the Strategic Blueprint platform (“platform”). Each
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investment sponsor on the platform is charged an annual fee, to help offset the firm’s cost in
making these investments available, including due diligence, additional workflows, disclosures,
and supervision. This additional compensation does create a conflict for the firm. These sponsors
will also contribute financially to the national and educational conferences held by Strategic
Blueprint and its affiliates.
While the financial arrangements described above do not impact advisor compensation, they do
limit your Advisory Representative to recommending only alternative investment products that are
available on the platform or through registered representatives of SFA. The additional
compensation paid to Strategic Blueprint to participate on the platform, and the commissions,
marketing and due diligence fees that are paid to SFA for commission products, as well as the
limitations on available products, create a conflict of interest for the firm and your Advisory
Representative. Your Advisory Representative recommends these investment products based
on your financial objectives, risk tolerance, and other financial information. Risks and benefits
are more fully disclosed in the product offering documents.
If also registered with SFA, your advisory representative can recommend an investment that is
not on the platform but is available through SFA. Alternative investments that are privately offered
(e.g., private placements, Reg D programs) may not be purchased in your account on a
discretionary basis. An offer can be made only through a Private Placement Memorandum and
you will be required to complete a subscription agreement if you determine to acquire the
investment in your account.
When you purchase a product with a commission through your Advisory Representative in his or
her role as a registered representative, an advisory fee will not be charged on those assets even
if the assets are held in your advisory account. Please talk with your Advisory Representative
about the pricing options, the impact on yield, and other relevant factors related to the purchase
of a commission product through SFA.
Strategic Blueprint does not offer legal or tax advice. An Advisory Representative will present the
tax aspects of certain investments or strategies in general terms but does not provide specific tax
advice. We recommend that all tax questions or strategies be discussed with your tax
professional.
Benefits Provided by Custodians
As disclosed in Item 12 above, Schwab makes available to us other products and services that
benefit us but may not directly benefit the client or their account(s). These products and services
assist us in managing and administering our clients’ accounts. They include investment research,
both Schwab’s own and that of third parties. We may use this research to service all or some
substantial number of our clients’ accounts, including accounts not maintained at Schwab. In
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addition to investment research, Schwab also makes available software and other technology
that:
• provides access to client account data (such as duplicate trade confirmations and account
statements);
facilitates trade execution and allocate aggregated trade orders for multiple client accounts;
facilitates payment of our fees from our clients’ accounts; and
•
• provides pricing and other market data;
•
• assists with back-office functions, recordkeeping and client reporting.
technology, compliance, legal, and business consulting;
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services include:
• educational conferences and events
•
• publications and conferences on practice management and business succession; and
• access to employee benefits providers, human capital consultants and insurance providers.
Schwab may provide some of these services itself. In other cases, it will arrange for third-party
vendors to provide the services to us. Schwab may also discount or waive its fees for some of
these services or pay all or a part of a third party’s fees.
In addition, Schwab has also agreed to pay for certain products and services for which we would
otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a
certain size. In some cases, a recipient of such payments is an affiliate of ours or another party
which has some pecuniary, financial or other interests in us (or in which we have such an interest).
You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the arrangement because the cost of these services would otherwise
be borne directly by us. You should consider these conflicts of interest when selecting a custodian.
The products and services provided by Schwab, how they benefit us, and the related conflicts of
interest are described above (see Item 12 – Brokerage Practices).
Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the
client’s experience, help reach their goals and put their interests before that of our firm or its
associated persons.
Fidelity also provides products and services to help us manage and administer accounts. It
provides access to educational events and conferences; and, technology, compliance and
business consulting. Fidelity will also provide support for certain transitions costs, such as
account termination fees.
CLIENT REFERRALS THROUGH TESTIMONIALS AND ENDORSEMENTS
Strategic Blueprint will compensate certain unaffiliated investment advisers, existing and former
clients, and other professionals (such as CPAs, attorneys, etc.) for referring clients to us. We will
pay these individuals or entities (which we refer to as “promoters”) a fixed fee or a percentage of
the advisory fee that you pay us if it is determined that you have become a client of ours as a
result of their direct or indirect efforts.
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We will enter into written agreements with these promoters. The payment of these referral fees
will not result in an increase in the amount of the advisory fee that you pay. You will receive a
disclosure describing the relationship with the promoter, the nature of the compensation, and any
conflicts of interest created by the arrangement.
Additionally, Strategic Blueprint can endorse other investment advisers, for compensation.
Strategic Blueprint (and, in turn, your Advisory Representative) will receive a portion of the
advisory fee as a promoter’s or referral fee when you enter into an advisory agreement with a
third-party asset manager as a result of your Advisory Representative’s recommendation.
These referral arrangements will comply with applicable laws that govern:
the nature of the services provided;
the fees to be paid;
•
•
• disclosure to the referred client;
• state regulations; and
• client consents, as required.
Any referral fee that exceeds a nominal payment will be fully described in a written Disclosure
Statement which you will receive and acknowledge when you enter into an advisory agreement.
ITEM 15 – CUSTODY
Strategic Blueprint does not maintain physical custody of client assets. We will be deemed to
have custody when you authorize us to deduct advisory fees directly from your account. Strategic
Blueprint may only deduct fees with your written authorization, and the amount of any advisory
fee deducted is shown on your account statement. You will receive at least quarterly statements
from the account custodian. Strategic Blueprint urges you to carefully review such statements
and compare this official custodial record to the account statements that we may provide to you.
Our statements may vary from custodial statements based on accounting procedures, reporting
dates, or valuation methodologies of certain securities. Where there are differences, you should
rely on the values disclosed in the custodial account statements.
Strategic Blueprint is also deemed to have custody when you execute a Standing Letter of
Authorization (“SLOA”) which allows your Financial Advisor to request disbursements to be sent
from your account to payees as specified by you in the SLOA at designated addresses or to
designated account numbers. You will receive notifications from the account custodian when
such a disbursement is made. Annually, the custodian will send a notification to you to confirm
the SLOAs which you have authorized. By limiting the manner in which we are deemed to have
custody, Strategic Blueprint is not subject to a surprise audit requirement.
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ITEM 16 – INVESTMENT DISCRETION
We may manage your accounts on a discretionary or non-discretionary basis. We will only
manage your account on a discretionary basis upon obtaining your written consent. Your consent
is typically granted and evidenced in the executed Investment Management Agreement. We
define discretion as the authority to trade your account without obtaining your prior consent, to
select the securities and amount of securities to be bought or sold, and the timing of the purchase
or sale. It does not extend to the withdrawal or transfer of your account funds or securities. We
may give advice and act in the performance of our duties to you, which differs from advice given,
or the timing and nature of action taken, with respect to other clients’ accounts.
ITEM 17 – VOTING CLIENT SECURITIES
As a matter of firm policy and practice, Strategic Blueprint does not have any authority to and
does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving
and voting proxies for any and all securities maintained in client portfolios. Strategic Blueprint
may provide advice to clients regarding the clients’ voting of proxies. You will receive
information about proxies directly from your account custodian.
ITEM 18 – FINANCIAL INFORMATION
In May 2020, SFA Holdings, Inc. (SFAH), parent company of Strategic Blueprint, and owner of a
group of financial services companies, applied for and received a Paycheck Protection Program
(PPP) Loan. The COVID-19 Pandemic presented many risks, including unprecedented market
volatility, and the uncertainties surrounding duration of the pandemic and its level of impact on
the various affiliated companies. The loan proceeds were used in conformity with the program
requirements. Accordingly, the loan was forgiven in June 2021.
Strategic Blueprint has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding.
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