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Form ADV Part 2A: Appendix 1
The Strategic Choice Program
Wrap Fee Brochure
This wrap fee brochure provides information about the qualifications and business practices of
The Strategic Financial Alliance, Inc. (“SFA”). If you have any questions about the contents of this
Brochure, please contact us at (678) 954-4000. 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.
SFA is a Registered Investment Adviser. Registration of an Investment Adviser does not imply
any level of skill or training. Additional information about SFA (CRD #126514) is available on the
SEC’s website at www.adviserinfo.sec.gov.
2200 Century Parkway, Suite 500
Atlanta, Georgia 30345
(678) 954-4000
www.thesfa.net
March 31, 2026
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ITEM 2 – MATERIAL CHANGES
The Strategic Financial Alliance, Inc. (“SFA”) published its annual update of Part 2A Disclosure
Brochure and Part 2A Appendix 1 Strategic Choice Program Wrap Brochure (collectively,
“Brochure”) on March 31, 2026.
There have been no material changes since the 2026 filing.
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 may 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. 4000. Our Brochure is
also available on our website at www.thesfa.net.
Additional information about SFA (CRD #126514) and its Advisory Representatives is available
on the SEC’s web site at www.adviserinfo.sec.gov.
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ITEM 3 – TABLE OF CONTENTS
ITEM 1 – COVER PAGE ............................................................................................................. i
ITEM 2 – MATERIAL CHANGES ................................................................................................. ii
ITEM 3 – TABLE OF CONTENTS ............................................................................................. iii
ITEM 4 – SERVICES, FEES AND COMPENSATION.................................................................. 1
PROGRAM DESCRIPTION ..................................................................................................... 1
FEES, BILLING AND COMPENSATION ................................................................................. 2
NEGOTIATION OF FEES AND COMPENSATION .................................................................. 7
OPTIONAL LIMITED TRADING AUTHORIZATION/DISCRETION .......................................... 8
TERMINATION ........................................................................................................................ 8
ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................... 9
ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION ....................................... 10
CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS .......................... 10
WRAP FEE PROGRAMS ...................................................................................................... 11
OTHER ADVISORY SERVICES ............................................................................................ 11
PERFORMANCE BASED FEES AND SIDE BY SIDE MANAGEMENT ................................. 11
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .................. 11
VOTING CLIENT SECURITIES ............................................................................................. 15
ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ......................... 15
ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS ................................................ 16
ITEM 9 – ADDITIONAL INFORMATION .................................................................................... 16
DISCIPLINARY ACTION ....................................................................................................... 16
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................... 16
CODE OF ETHICS ................................................................................................................ 18
REVIEW OF ACCOUNTS ...................................................................................................... 18
CLIENT REFERRALS AND OTHER COMPENSATION ........................................................ 19
FINANCIAL INFORMATION .................................................................................................. 21
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ITEM 4 – SERVICES, FEES AND COMPENSATION
The Strategic Financial Alliance, Inc. (“SFA”) is a registered broker-dealer with Financial Industry
Regulatory Authority (“FINRA”) and is also an Investment Adviser registered with the Securities
and Exchange Commission (“SEC”). SFA is an Atlanta-based, Georgia corporation, formed in
2003, and a wholly owned subsidiary of SFA Holdings, Inc. Clive Slovin is the President and CEO.
SFA has worked to build a strong reputation within the Financial Services Industry through its
independent model and commitment to service. Through its network of independent Advisory
Representatives, SFA offers a range of advisory services.
As of December 31, 2025, SFA managed assets valued at approximately $382 million, of which
approximately $27 million were managed on a discretionary basis and $355 million were managed
on a non-discretionary basis.
Additionally, as of December 31, 2025 SFA had approximately $71 million in assets under
advisement, which represents the assets referred by SFA to third-party asset managers as
described on Page 3 under “Third Party Asset Managers.”
SFA offers portfolio management through its Strategic Choice Program (“the program” or
“Strategic Choice”). Working with our Advisory Representatives, Strategic Choice offers clients a
personalized approach to implementing an individualized investment strategy designed to offer a
diversified, long-term approach to meeting personal investment goals.
PROGRAM DESCRIPTION
The program is designed to offer a diversified, long-term approach to help meet personal
investment goals and objectives through asset allocation, portfolio design, portfolio monitoring,
consolidated reporting, and individualized portfolio management. It allows you to invest in no- load
or load-waived mutual funds, variable products, stocks, bonds, commercial paper, money market
shares, CDs and exchange traded funds, according to your needs, goals, objectives and
preferences. For certain clients, illiquid alternative investments (“Alternatives”), such as interval
funds, non-traded REITs or private placements could be recommended. Permissible Alternatives
are approved products of SFA whose valuations are provided directly to the custodian by the
issuer or other bona fide third-party source. Alternatives also require delivery of separate offering
documents, executed subscription agreements and additional disclosures. This program is
available to individual clients, high net worth individuals, pension and profit- sharing plans,
corporations, trusts, estates, charitable organizations, and other business entities.
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Before participating in the program, your Advisory Representative will consult with you to help
determine your financial profile including investment history, goals and objectives, risk tolerance,
and special interests or concerns. Based on this consultation, the Client Profile, Client Account
Form, and other account opening documents, your Advisory Representative will work with you to
design a portfolio intended to meet your goals as you have defined them. Your Advisory
Representative will assist you in establishing a brokerage account with Pershing LLC, which will
provide clearing and custody for your account(s).
Your Advisory Representative will review the strategy periodically, and will recommend, at his or
her discretion, changes in the asset allocation among securities based on such factors as, for
example, market conditions and/or changes in your circumstances. It is important that you contact
your Advisory Representative if your financial situation or objectives change.
FEES, BILLING AND COMPENSATION
The SFA program is offered in two fee structures, an All-Inclusive Account (“Wrap Fee”) in which
you pay an asset-based fee (“Advisory Fee”) and, non-transaction related fees such as stock
reorganization fees, maintenance fees, etc. ; and, a Non-Inclusive Account (“Non-Wrap Fee”) in
which you pay transaction costs as well as the Advisory Fee. Fees are negotiable and are fully
described in the Strategic Choice Agreement (“Agreement”).
You will be charged advisory fees based on an annualized percentage of the value of the assets
in the Strategic Choice Account. The fee will be assessed and billed quarterly in advance. The
fee for any given calendar quarter is debited by the custodian from your account at the beginning
of the calendar quarter, based on the total portfolio value as of the last business day of the
preceding calendar quarter as determined by the custodian. Your account statement will show the
fee for that quarter and the value of the assets on which it was calculated.
The first fee will be billed after execution of the Agreement and your Strategic Choice account
is funded. The fee will be based upon the opening value of the account. If the account is funded
at any time other than the first day of a calendar quarter, the payment will be prorated.
Alternatively, you may elect to pay all advisory fees described above from a source other than
your Strategic Choice account. Direct payments will be calculated in the same manner and
billed on the same time frame. Such payments must be received by the 25th day after the
beginning of the quarter. Payments will be deposited into your Strategic Choice account and
then deducted so that the amount of the fee deduction will be reported on your quarterly
statement, and your performance will be shown net of fees. If such funds are not deposited
timely, SFA is expressly authorized, in its discretion, to liquidate securities in the Account in an
amount sufficient to cover such fees. Any delinquent payments may result in the loss of all
direct pay privileges and SFA may debit your Strategic Choice account for all future advisory
fees.
During a quarter, if you contribute additional funds of $10,000 or more to the account, or withdraw
$10,000 or more, the Advisory Fee for that quarterly period will be recalculated. Any
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resulting difference in the fee for that period will be added to or deducted from the Advisory Fee
for the next billing period.
We generally require that you authorize us in writing to direct your custodian to pay the Advisory
Fee directly to us by charging your account. This authorization is set forth in the Agreement.
The following are the maximum advisory fees applied to this program.
STRATEGIC CHOICE - ALL INCLUSIVE PROGRAM
Account Value
Maximum Annual Advisory Fee*
2.25%
2.25%
2.00%
1.75%
1.50%
1.25%
1.00%
First $250,000
Next $250,000 to $500,000
Next $500,000 to $1,000,000
Next $1,000,000 to $2,500,000
Next $ 2,500,000 to $5,000,000
Next $5,000,000 to $10,000,000
Above $10,000,000
*All fees are negotiable
Transaction Charges
No transaction charges are assessed for trades in these accounts, but certain nominal fees and
charges beyond SFA’s control such as reorganization charges, termination fees, and postage and
handling are assessed against the account. If you elect to include alternative investments in your
account, the custodian will assess an annual fee of $50.00 for the purchase, redemption of
registration of the security, in addition to a $35.00 per position for registered securities, or
$125.00 for unregistered securities.
STRATEGIC CHOICE – NON-INCLUSIVE PROGRAM
Account Value
Maximum Annual Advisory Fee*
2.00%
1.90%
1.75%
1.50%
1.25%
1.00%
0.75%
First $250,000
Next $250,000 to $500,000
Next $500,000 to $1,000,000
Next $1,000,000 to $2,500,000
Next $2,500,000 to $5,000,000
Next $5,000,000 to $10,000,000
Over $10,000,000
*All fees are negotiable
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Transaction Charges for Non-Inclusive Program
In addition to the asset management fee listed above, $4.00 will be applied to each transaction in
the non-inclusive program. If you elect to include alternative investments in your account, the
custodian will assess a $50.00 fee for the purchase or redemption of a non-registered security, in
addition to an annual fee of $35.00 per position, or $125.00, depending on the type of security.
Additional information about Transaction Charges
Transaction charges may be subject to change upon 30 days’ notice. Transaction charges for the
Non-Inclusive Accounts may be assessed by the clearing firm or directly by the product sponsors
as described in the prospectuses. Certain other miscellaneous charges may apply.
The transaction costs listed above are maximum costs. SFA, as the broker/dealer, shares in the
transaction fee, but no part of the transaction fee is shared with your Advisory Representative.
Your Advisory Representative may choose to pay the transaction fees described above on your
behalf from the advisory fees assessed on your account.
Selected mutual funds are available through the custodian for no transaction fee (“NTF funds”) to
you in the Non-Inclusive Program. When the Advisory Representative recommends or selects
funds which are not on the NTF Fund list, you will pay transaction fees, the cost of which may
reduce the performance of the portfolio. However, the internal expenses of NTF funds may be
higher than those funds that are not on the NTF Fund list. All expenses associated with a fund
are disclosed in the fund’s prospectus.
The scheduled maximum fees for the All-Inclusive Program are higher than the Non-Inclusive
Program because most or all transaction charges are included in the fee.
In some cases, the wrap fee will cost you more than the aggregate cost of services if they were
provided separately. In those cases, your Advisory Representatives could have a financial
incentive to recommend the wrap fee program over other programs or services. Generally, wrap
programs are relatively less expensive for actively traded accounts. However, they will result in
higher overall costs to you in accounts that experience little trading activity.
Your Advisory Representative will consider these costs when negotiating the Advisory Fee with
you. Your Advisory Representative is obligated by your Agreement and SFA’s Code of Ethics to
make recommendations based on your investment goals and objectives, without regard to the
amount of his or her compensation.
When deciding on whether to select an All-Inclusive or Non-Inclusive account, you should
base your decision upon anticipated trading activity, the types of securities utilized in the
account, and the value of the services that are provided to you. Please discuss the costs
associated with your account with your Advisory Representative.
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ILLIQUID ALTERNATIVE INVESTMENTS (“ALTERNATIVES”)
Some Alternative products may not be available for purchase without a commission or sales
charge. If you select to hold these Alternatives in your managed account, you will pay a sales
commission, which will be paid to SFA as the broker/dealer. Or, SFA may be compensated by a
portion of the advisory fee collected by the manager of the alternative investment in the form of a
solicitor’s fee. A portion of this compensation will be shared with your Advisory Representative. If
SFA receives a commission or solicitor’s fee, SFA will not charge an advisory fee on the value of
the purchased asset. If the Alternative asset is purchased in an Advisor Share Class or at net
asset value, and no commission is paid, the value of the asset will be included in the account
value for billing purposes as long as the asset is supervised, or managed, as part of the account.
SFA conducts due diligence on the alternative products it selects to make available for offer to its
retail clients. Many alternative investment sponsors compensate SFA for its due diligence and
marketing through a portion of the dealer manager fee. Payment of this fee to SFA does not
increase the cost of the investment to the purchaser. No part of the due diligence and marketing
fees are shared with your Advisory Representative.
Alternative investments are not appropriate for all investors. Please review offering documents
carefully for more complete information about the risks associated with a particular product.
ADDITIONAL EXPENSES
In addition to the Advisory Fee, your investment account may also be charged:
internal fees and expenses charged by mutual funds, ETFs and variable annuities;
fees charged by third party money managers;
maintenance and termination fees for IRAs, certain retirement and qualified
accounts; and,
taxes and other fees on brokerage accounts and securities transactions, as
may be imposed or passed through by the custodian.
Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses
for their products. These fees and expenses are in addition to any advisory fees charged by us.
Class B, C, and similar mutual fund shares, and variable products held in accounts may incur
sales charges when sold or redeemed. Complete details of these internal fees and expenses are
explained in the prospectuses for each investment. We encourage you to read these documents
before making or authorizing any investments. Your Advisory Representative will be available to
answer any questions you have about fees and expenses. SFA does not assess advisory fees
on Class B or Class C share mutual funds held in Strategic Choice Accounts. As a registered
representative, your Advisory Representative will share in the fees charged by the fund company
for Class B as described in the fund prospectus.
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SFA AND ADVISORY REPRESENTATIVE COMPENSATION
The Advisory Representative managing your Strategic Choice account will receive a portion of
the advisory fee paid to SFA as a result of your participation in the Program. Such portions range
up to 92% of the advisory fees assessed by SFA on a Strategic Choice account. The amount of
this compensation may be more or less than the amount the Advisory Representative would
receive if you participated in other company programs or paid separately for investment advice,
brokerage, and other services.
Pershing, LLC, imposes an asset-based charge for administrative services such as reporting and
billing. SFA shares in this fee for its administrative services. This charge is paid out of your
Advisory Fee by the Advisory Representative.
Transactions in Strategic Choice Program accounts incur a transaction fee, which is paid to SFA
to offset the costs Pershing, LLC assesses to SFA. In the inclusive program, the transaction fee
is paid by the respective Advisory Representative. In the non-inclusive program, the transaction
fee is paid by the account owner and deducted from the account.
SFA and its representatives consider costs, fees and your interests when recommending
investments; however, you should consult mutual fund and variable product prospectuses for a
complete description of underlying fees and compensation when considering the purchase of such
products. Your Advisory Representative is available to answer any questions you may have about
the fees and expenses associated with the products he or she recommends.
You can purchase certain alternatives in the account. Alternatives will generally be purchased at
Net Asset Value (“NAV”) or in a share class specifically designed for advisory accounts. However,
if purchased at public offering price, SFA will receive a sales commission, a part of which will be
paid to your Advisory Representative in his or her capacity as a registered representative. No
advisory fees will be assessed on the value of alternative investment assets for which a
commission has been paid to or a solicitor’s fee is earned by SFA.
You can purchase shares of certain mutual funds directly from the issuer without a transaction
fee. Mutual funds held in accounts at brokerage firms may charge internal fees that are different
from mutual funds held directly at the mutual fund company. Those directly purchased mutual
funds, however, will not be part of our advisory relationship with you. This means that they will not
be included in our investment strategies, investment performance monitoring, or investment
reallocations under this Agreement. Generally, only securities purchased without a sales
commission through SFA or which were purchased through other firms may be billed in Strategic
Choice accounts as part of the managed portfolio.
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Other securities may be deposited into a Strategic Choice Account with the following limitations:
C-share mutual funds must be held one year or more before converting to a lower class
share or, if converted prior to one-year, contingent deferred sales charges will be
refunded by SFA to the account (C-shares are excluded from billing);
No advisory fees are assessed on other share class mutual funds purchased within the
previous 24 months on which sales compensation was paid to SFA;
No advisory fees are assessed on variable insurance products purchased within the
previous 24 months on which sales compensation was paid to SFA;
No advisory fees may be assessed on assets on which brokerage commissions were paid
to SFA during the preceding 90 days; and.
No advisory fees may be assessed on alternative investments which are purchased in your
managed account, or transferred into your account, for which a sales commission or solicitor’s
fee is paid to SFA. Billable illiquid assets are limited to no more than 15% of the total portfolio.
For determining the 15% threshold, a portfolio can include multiple accounts with the same
ownership.
Exceptions will only be made if there is a strong economic or practical reason for doing so, with
the written authorization of the Chief Compliance Officer or the Chief Supervisory Officer.
For these purposes, “sales compensation” does not include 12b-1 fees which are paid on certain
mutual funds and variable annuity products, pursuant to the product prospectus. SFA refunds
12b-1 fees paid on A-share and C-share class assets held in a Program Account to the Program
Account.
Some third-party advisers, mutual fund companies, alternative product sponsors, insurance
companies, and other product vendors pay directly or indirectly additional compensation to SFA.
This additional compensation includes but is not limited to solicitor fees, marketing allowances,
support for SFA conferences, meetings and/or functions. Certain companies also provide support
for client appreciation events, software, training or other tools and services to facilitate SFA’s and
its Advisory Representatives’ business.
Advisory Representatives who recommend alternative or complex products conduct due diligence
on such products. They will participate in due diligence meetings for certain products. The sponsor
of such meetings will generally pay travel, lodging and food for advisory representatives to attend
and be educated about their products. Attendance must be approved by SFA. The agenda,
location and expenses must be reasonable. Expenses may not be paid for an advisory
representative’s guest.
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 SFA and your Advisory
Representative, the size of the Account, the potential for other business or clients, the amount
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of work anticipated and the attention needed to manage your Account. Your Advisory
Representative may negotiate fees that are higher or lower than those negotiated by other SFA
Advisory Representatives for similar services. Please note that the same or similar services to
those described above may be available through other providers at a lower cost.
Fees may be negotiated but not waived for the All-Inclusive program, in which the transaction fees
are included in the advisory fee. Accounts where fees are waived will be transferred to the Non-
Inclusive program, in which the transaction fees are paid by the client and charged to the account
separately from the advisory fee.
OPTIONAL LIMITED TRADING AUTHORIZATION/DISCRETION
You may choose to sign a limited trading authorization in order to facilitate management of
portfolios consistent with your stated investment objectives. This limited authority gives
investment discretion as to the selection of securities, number of shares to be bought or sold
and the time of execution. Discretion may not be authorized in ERISA accounts (e.g., 401k,
profit/pension accounts).
Discretion applies only to the selection and amount of general securities, including stocks, bonds,
commercial paper, money market shares and exchange traded funds; variable insurance sub-
accounts; and, open-end and closed-end mutual funds bought and sold in your Account.
Alternative Investments and variable annuity contracts may not be purchased on a discretionary
basis. Discretion does not extend to deposits into or withdrawals from accounts. All Strategic
Choice accounts are held at, and trades executed through, Pershing LLC.
You must authorize discretion in writing, and you may withdraw the authorization, in writing, at
any time. Advisory Representatives must receive the approval of SFA’s Chief Supervisory Officer
or Chief Compliance Officer prior to offering discretionary portfolio management in Strategic
Choice accounts.
TERMINATION
Both you and SFA have the right to terminate the Agreement and relationship at any time with or
without cause. Termination is effective within 30 days of receipt of your notice to SFA, unless a
later date is requested in your notice and agreed to by SFA. For your convenience, SFA will accept
your request for termination by telephone. You may terminate your Agreement without penalty
within five business days of executing the Advisory Agreement.
If the Agreement is terminated before the end of a billing period (during a quarter), any unearned
fees that were deducted from your account will be refunded to the account.
The amount refunded to you is calculated by dividing the most recent advisory fee you paid by
the total number of days in the quarter. This daily fee is then multiplied by the number of calendar
days in the quarter that the Agreement was in effect. This amount, which equals the
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amount we earned for the partial quarter, is subtracted from the total fee you paid in advance to
determine your refund.
If your Advisory Representative should terminate his or her association with SFA, and affiliate with
another registered investment adviser, SFA will facilitate the transfer of your account to the new
firm, if you agree. Otherwise, your account will not be managed as SFA will await your instructions
regarding the transfer of your account, or your designation of a new SFA Advisory Representative.
If you choose to terminate an Account within the first calendar year after the Account is opened,
you will be assessed a fee (“Administrative Fee”) of $200 to defray initial account setup and
administration costs, and such fee may be paid in the same manner as the Asset-Based Fee.
SFA may waive the Administrative Fee in its sole discretion. You will be responsible for any
transactions initiated prior to termination. Such redemption or liquidation may affect the asset
allocation and/or market value of the Account and may also have tax consequences. In addition,
early redemption fees or similar fees for mutual funds and other products may be applicable as
described in the product’s prospectus or other offering documents. Certain assets that may be
transferred or held in the Account may not be accepted by another custodian. SFA will use
reasonable efforts to follow your instructions regarding the disposition of Account assets;
however, assets that are not accepted by the receiving custodian may be required to be liquidated.
ITEM 5 – ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
SFA requires a minimum account size of $25,000 in supervised assets for Strategic Choice
accounts. This minimum may be met by a single account or, at SFA’s discretion, by aggregating
the assets within multiple accounts with the same ownership. This minimum account size serves
as a guideline. SFA, at its sole discretion, may waive this minimum account requirement.
Should the value of your Strategic Choice account (in aggregate with any related accounts
considered in the $25,000 minimum) fall below the minimum requirement of $25,000 and remain
20% below the minimum (or below $20,000) for two consecutive quarters, then the advisory
contract may be terminated and the assets transferred to a brokerage account held at the then
current custodian so that you do not continue to incur the advisory fees. Please discuss this option
with your Advisory Representative.
SFA provides investment advisory services to individuals, high net-worth individuals, pension and
profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business
entities.
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ITEM 6 – PORTFOLIO MANAGER SELECTION AND EVALUATION
Your Advisory Representative is the sole portfolio manager available with respect to the Program.
Please refer to your Advisory Representative’s Supplement to this Brochure for information about
his or her education and business experience. Your Advisory Representative must be properly
registered, have at least five years’ experience in the financial services industry (or equivalent
experience as determined by SFA), and be approved by SFA’s Chief Supervisory Officer and/or
Chief Compliance Officer, in addition to approval from the Advisory Representative’s Supervising
Principal, as a portfolio manager in the Strategic Choice Program. When your Advisory
Representative works with another Advisory Representative in partnership to manage your
account, you will receive the Supplement for each Advisory Representative.
Affiliated and unaffiliated service providers may develop asset allocation models. Your Advisory
Representative may also develop asset allocation models or use others from outside
independent sources. Each representative develops his or her own methods of analysis, sources
of information, and investment strategies. As such, recommendations by representatives,
individual investment portfolios, and performance will differ.
Your Advisory Representative will manage accounts on an ongoing basis and will review accounts
at least annually with you or more frequently upon your request. The purpose of the review is to
review the portfolio and its performance; to discuss any changes in your financial profile and
investment goals; and, to recommend changes if determined changes are warranted.
You will receive monthly brokerage statements, except for months in which no account activity
has occurred, and quarterly statements and performance reports. You may contact your Advisory
Representative or the SFA home office at (678)954-4000 when you have questions or concerns
about your account, financial situation, or investment needs. Please note that your Advisory
Representative may not be readily available for unscheduled or unannounced visits or calls.
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
financial profile, including your objectives, risk tolerance and time horizon. You can 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, beliefs
or preferences.
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WRAP FEE PROGRAMS
You may select the All-Inclusive Program (“wrap fee program”) in which the asset-based fee
includes our advisory fee as well as transaction costs. Alternatively, you may select a program in
which you pay transaction fees in addition to our asset-based advisory fee. You and your Advisory
Representative, together, agree on the asset-based fee applied to the management of the
account, based on the program’s published maximum fee schedule. We do not manage the All-
Inclusive program accounts in a manner different from the Non-Inclusive Program accounts
except, as mentioned above, the All-Inclusive Program is more suitable when the portfolio strategy
includes more active trading. A portion of the Advisory Fee is allocated to the Administrative Fee,
which covers administrative and supervisory services provided by SFA as well as custodial and
program services provided by the custodian. The Administrative Fee is set on a sliding scale
determined by the size of the assets in the account.
SFA offers wrap fee programs sponsored by Lockwood Advisors, Inc., Orion Portfolio Solutions,
LLC, and AssetMark, Inc..
OTHER ADVISORY SERVICES
In addition to the investment management services through the Strategic Choice Program, SFA
offers financial planning and investment consulting, as well as recommendations of and referral
to third party asset managers. These services are described in SFA’s ADV Part 2A Disclosure
Brochure. The Brochure is available upon request at no charge.
PERFORMANCE BASED FEES AND SIDE BY SIDE MANAGEMENT
SFA does not charge any performance-based fees (fees based on a share of capital gains 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 SFA and Advisory Representative(s) as a solicitor’s fee. Any such
arrangement will be described to you in a written Solicitor’s Disclosure Statement.
METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS SFA’s
Representatives 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.
SFA’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 can include long term purchases
(securities
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held at least a year), short term purchases (securities purchased and sold within a year), margin
transactions, and covered 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, mutual funds and alternative investments.
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: 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: 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: 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 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.
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 Exchange Traded Funds (“ETFs”) involves 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.
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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 Structured Products involves the assumption of risk, including:
If a principal protected structured note is guaranteed by the underwriting firm’s
assets, then the guarantee is limited to the claims-paying ability of the underwriter.
Investment in a Principal Protected Certificate of Deposit carrying FDIC insurance
is subject to the limits of that insurance.
Investment in a Principal Protected Structured Product may still result in
substantial opportunity loss.
Buffered notes do not provide 100% principal protection. Buffered notes only provide
limited downside protection against loss and only if the buffered note is held to
maturity.
The gain on buffered notes may be subject to a cap so you may not participate in the
full upside of the reference asset(s).
Buffered notes will trade, if at all, at a discount on the first day after purchase as a
result of upfront fees paid in connection with your purchase.
Buffered notes lack liquidity. They are not listed on any securities exchange and
you may not be able to sell your buffered note(s) prior to maturity.
Buffered notes do not pay dividends. The payment of a buffered note at maturity will
reflect cumulative performance. If you require current income, you should not invest in
a buffered note.
Buffered notes are not obligations of a bank and are not insured or guaranteed by the
Federal Deposit Insurance Corporation or any other governmental agency or program
of the United States or any other jurisdiction.
Structured products are subject to loss of principal.
Investing in Alternative Investments (“Alternatives”) involves the assumption of risk,
including:
There may be no public market so these Alternatives could not be sold quickly or
rebalanced.
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.
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Strategic Choice Wrap Fee Brochure
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SFA will limit the percentage of Alternatives held in a managed account based on your
liquidity needs, net worth, investment objectives, risk tolerance, and any state or regulatory
limitations. Alternatives may not be purchased on a discretionary basis.
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:
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 on your cash assets than you
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.
Margin, options and short sales are higher risk strategies. It is possible to lose all of the principal
you invest, and sometimes more. 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 short sell, your losses can be infinite.
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 asset 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.
Investing in securities involves risk of loss that you should be prepared to bear.
VOTING CLIENT SECURITIES
As a matter of firm policy and practice, SFA does not have any authority to and does not vote
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proxies on behalf of advisory clients. You retain the responsibility for receiving and voting proxies
for any and all securities maintained in your account(s). Your Advisory Representative may
provide advice to you regarding the voting of your proxies. SFA will not take any action with
respect to any securities held in any accounts that are named in or subject to class action lawsuits.
You will receive information related to proxies directly from your account custodian. We will
forward any information received by us regarding proxies and class action legal matters involving
securities held in your accounts.
ITEM 7 – CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
SFA appreciates the trust you place in us, and we respect your right to privacy.
We are committed to safeguarding the personal information you entrust to us. At SFA, we believe
that it is important that you understand the uses and safeguarding of your personal information.
SFA receives information:
From paperwork you provide such as Client Account Forms, questionnaires and product
applications;
From conversations, discussions and interviews; and
From product or service vendors, as a result of your transactions with or through SFA.
At SFA we:
Maintain all client records in a secured environment;
Protect computer programs through physical and electronic safeguards; and
Limit access to employees who require access to the information in order to service your
account.
SFA may disclose certain types of information to qualified entities, including affiliates, which
perform administrative services on our behalf, with our affiliates with which you otherwise have a
relationship, and as required or permitted by law for legal or regulatory purposes. The information
that falls within this category is:
Information provided by you on Client Account Forms and product applications; and
Information provided by product or service vendors, as a result of your transactions with
SFA.
SFA maintains physical, electronic and procedural safeguards to help ensure that your personal
information is safe and accessed only according to these policies, and we will continue to make
safeguarding your privacy our highest priority.
Our Privacy Statement is available on our website at www.thesfa.net.
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ITEM 8 – CLIENT CONTACT WITH PORTFOLIO MANAGERS
You are encouraged to contact your Advisory Representative with respect to any changes
regarding your investment objectives, risk tolerance and requested restrictions with respect to
management of your Strategic Choice account. Your Advisory Representative will conduct a
review of your account with you no less than annually.
ITEM 9 – ADDITIONAL INFORMATION
DISCIPLINARY ACTION
On October 29, 2015, SFA 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 will be available in his or her Supplement to this
brochure, and at www.adviserinfo.sec.gov.
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
SFA is also registered as a broker-dealer, member of FINRA and SIPC. Individuals affiliated with
SFA may be both Advisory Representatives and registered representatives. SFA and its
registered representatives offer securities and financial products in additional to rendering
investment advice. SFA estimates it devotes 60% of its time to activities as a broker-dealer.
Many representatives associated with SFA are also licensed to sell insurance products with the
states in which they do business, and are appointed by various insurance companies, including
through SFA’s affiliated insurance agency, SFA Insurance Services, Inc.
Certain Advisory Representatives may also be Advisory Representatives of investment adviser
firms which are unaffiliated with SFA. These relationships are disclosed in the respective Advisory
Representative’s Part 2B Supplement. The services provided to you through SFA are disclosed
in your Advisory Agreement.
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Strategic Choice Wrap Fee Brochure
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Clients are under no obligation to purchase insurance products, securities products or other
products or services through SFA and its associated persons. While SFA 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.
SFA Holdings, Inc. (“SFAH”) parent company of SFA. Clive Slovin, President of SFAH. He and
certain Advisory Representatives are shareholders of SFAH. Shareholders will benefit from the
profits accrued to SFAH in the form of dividends.
Strategic Blueprint, LLC is an SEC registered investment adviser established in July 2016, wholly
owned by SFA Holdings, Inc. It shares office space and certain supervised persons with SFA.
Julie Sullivan serves as an officer and director of Strategic Blueprint.
SFA Partners is also wholly owned by SFA Holdings, Inc. It was formed for branding purposes,
and provides shared services to its affiliates, SFA, Strategic Blueprint and SFA Insurance
Services, including marketing, advisor relations, human resources, finance, recruiting, and due
diligence.
Green Creek Resources, LLC is a manager and sponsor of pooled investment programs. Green
Creek Resources is 50% owned by SFA Holdings, Inc. and shares office space with SFA.
Curated Equities, LLC is a manger and sponsor of pooled investment programs. Curated Equities
is 50% owned by SFA Holdings, Inc. and shares office space with SFA.
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. If your Advisory Representative
recommends a program that is sponsored by a client of Timbrel, disclosure will be made to you.
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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.
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 for a personal or beneficial account ahead 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.
REVIEW OF ACCOUNTS
Our Advisory Representatives review your account on an on-going basis to monitor that your
investments and investment strategies are performing in a manner consistent with your stated
objectives. Your Advisory Representative will contact you at least annually (or more often as
agreed upon with you) to review your account with you and to update your financial status, goals,
objectives, and risk tolerances. These reviews also consider any investment restrictions you have
requested and how your investments meet your investment time horizons, liquidity needs, tax
considerations and other circumstances unique to you. Changes in your investments
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and your investment strategies will be made or recommended by your Advisory Representative
as they are deemed appropriate. Interim reviews may be triggered by social, economic, and/or
political events.
We strongly encourage you to advise your Advisory Representative of any changes in your
personal circumstances, your investment goals or objectives, and your risk tolerances to ensure
that your investments and investment strategies are most appropriate for you.
In addition to the reviews done by your Advisory Representative, an Advisory Representative’s
designated supervisor reviews purchase and sell transactions in your Strategic Choice account
for suitability. The designated supervisor and SFA also monitor client accounts on a periodic and
on-going basis to help ensure that the investments and transactions in those accounts are
consistent with the information you have provided.
CLIENT REFERRALS THROUGH TESTIMONIALS AND ENDORSEMENTS, AND
OTHER COMPENSATION
OTHER COMPENSATION
In its capacity as a broker-dealer, SFA and its registered representatives will earn brokerage
commissions and/or fees from the sale or services of investment products such as stocks, bonds,
mutual funds, variable annuities and variable universal life products. Commissions vary depending
upon the type of security and service offered.
SFA Holdings Inc. (SFAH) is the parent company of SFA. Clive Slovin, President of SFAH. He
and certain Advisory Representatives, officers and employees of SFA are shareholders of SFAH.
Shareholders will benefit from the profits accrued to SFAH in the form of dividends.
SFA will receive certain economic benefits from Pershing LLC as the clearing firm and custodian
for Strategic Choice Accounts, including a portion of fees earned by Pershing on money market
balances and margin balances. Such fees are not passed, in whole or in part, to Advisory
Representatives. Although these fees are nominal, they could pose an incentive to retain assets
in money market accounts. Other benefits received from Pershing LLC are described in the ADV
Part 2A Disclosure Brochure.
In certain instances, product sponsors, investment companies, and third-party asset managers
(“product sponsors”) 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 doing business. Additionally, SFA enters into arrangements with certain
product sponsors whereby SFA receives a marketing allowance or other financial benefit based
on sales of the product sponsor’s products or by providing access to registered representatives
affiliated with SFA’s broker-dealer. In return for assistance in facilitating the activities described
above, SFA will receive additional compensation from product
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sponsors. While SFA does not recommend these products over others, these companies often
have greater access to our representatives to provide training, education presentations, and
product information. This additional compensation may give rise to a financial incentive for SFA
to recommend these products over other products where such financial incentives are not present.
While SFA and its registered representative’s endeavor at all times to put the interest of their
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. Additionally, because of the revenue sharing arrangements referenced above,
though they do not impact registered representative or advisory representative compensation,
representatives may prefer recommending products offered by a sponsor who is participating in
the revenue sharing program over other mutual funds, variable products, DPPs, REITs or third-
party asset managers available through SFA. Please ask your Advisory Representative how he
or she will be compensated for any transaction.
CLIENT REFERRALS
We enter into written agreements with certain unaffiliated investment advisers and other
professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. We
will pay these individuals (referred to as “solicitors”) 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.
The payments we make to a solicitor will not result in an increase in the amount of the advisory
fee that you pay.
Additionally, we enter into written agreements through which SFA will serve as a solicitor to other
investment advisers. SFA (and, in turn, your Advisory Representative) will receive a portion of the
advisory fee as a solicitor’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.
Our solicitation or referral arrangements will comply with applicable laws that govern:
the nature of the services provided;
the fees to be paid;
disclosure of solicitor arrangements to clients; and
client consents, as required.
Any solicitor’s fee will be fully described in a written Solicitor’s Disclosure Statement which you
will receive when you enter into an advisory agreement as a result of your Advisory
Representative’s recommendation.
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FINANCIAL INFORMATION
SFA 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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