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ITEM 1
Cover Page
DISCLOSURE BROCHURE
THE INVESTMENT ADVISERS ACT OF 1940RULE 203-1
Part 2A of Form ADV: Firm Brochure
COMPANY HEADQUARTERS
Principal Office & Mailing Address
1465 South Fort Harrison Ave
Suite 201
Clearwater, Florida 33756
Contact Information
Firm IARD/CRD #: 324120
P: 727.306.0299
Unify Financial Advisors
REGIS TERED
IN VEST MENT ADVISOR
B R O C H U R E
D A T E D
This Disclosure Brochure provides information on Unify Financial, LLC's qualifications and business practices,
which should be considered before becoming a client. You are welcome to contact us if you have any
questions about the contents of this brochure – our contact information is listed to the right. Additional
information about Unify Financial Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov.
4.16.26
The information contained in this Disclosure Brochure has not been approved or verified by the United States
Securities and Exchange Commission or by any State Securities Administrator. Furthermore, the term
“registered investment advisor” is not intended to imply that Unify Financial Advisors has attained a certain
level of skill or training.
DISCLOSURE BROCHURE
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MATERIAL CHANGES
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Unify Financial Advisors has no material changes to its ADV Part 2A since its last annual update
on March 27, 2025.
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DISCLOSURE BROCHURE
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TABLE OF CONTENTS
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ITEM 1
Cover Page
1
ITEM 2 Material Changes
2
ITEM 3
Table of Contents
3
ITEM 5
ITEM 4 Advisory Business
Who We Are
Assets Under Management
What We Do
Fees & Compensation
Discovery Meeting
Portfolio Management Fee
Financial Planning Fee
Performance-Based Fees & Side-By-Side Management
ITEM 6
4
4
4
4
5
5
6
8
8
ITEM 7
Types of Clients
8
ITEM 8 Methods of Analysis, Investment Strategies & Risk of Loss
General Portfolio Management Representation
Methods of Analysis, Investment Strategies and Risk of Loss
ITEM 9 Disciplinary Information
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9
9
12
ITEM 10 Other Financial Industry Activities & Affiliations
13
ITEM 11
ITEM 12
ITEM 13
ITEM 14
Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
Code of Ethics
Client Transactions
Personal Trading
Brokerage Practices
Custodial Services
Aggregating Trade Orders
Review of Accounts
Portfolio Management Reviews
Financial Planning Reviews
Client Referrals & Other Compensation
Referral Compensation
Other Compensation (Indirect Benefit)
Financial Planning Compensation
Retirement Rollover Compensation
ITEM 15 Custody
ITEM 16
Management Fee Deduction
Standing Letters of Authorization
Investment Discretion
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ITEM 17
Voting Client Securities
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ITEM 18
Financial Information
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DISCLOSURE BROCHURE
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ADVISORY BUSINESS
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Who We Are
Unify Financial Advisors1 (hereinafter referred to as “Unify”, “the Company”, “we”, “us” and
“our”) is a fee-only2 registered investment advisor3, organized as a Florida Limited Liability
Company in January 2022, to offer financial services4 designed to help you, our client5, pursue
financial stability, security, and peace.
Owners
The following person controls the Company:
Name
Title
CRD#
David L. Bennett, CFA®, CFP® Managing Member & Chief Compliance Officer
4761782
Our Mission & Core Values
Our mission is to help individuals, businesses, and our community pursue financial peace. Our
core values are to strive for exceptional service with diligence, unity, and humility.
Assets Under Management
As of December 31, 2025, our assets under management totaled:
Discretionary Accounts.......................................................
Non-Discretionary Accounts...................................................
$155,592,494
$197,510
What We Do
We strive to create value for every client by catering financial services to meet their specific
needs, by understanding their unique lifestyle, objectives, risk tolerance, investment
preferences and experience.
1 Unify Financial Advisors is the doing-business-as name for Unify Financial, LLC.
2 As a “fee-only” registered investment advisor, Unify does not receive compensation from any source other than what is directly paid
by you, our client, for the services we provide.
3 The term “registered investment advisor” is not intended to imply that Unify has attained a certain level of skill or training. It is used
strictly to reference the fact that we are “Registered” as an “Investment Advisor” with the Florida Office of Financial Regulation – and
with such other regulatory agencies that may have limited regulatory jurisdiction over our business practices.
4 Unify is a fiduciary, as defined within the meaning of Title I of the Employer Retirement Income Security Act of 1974 (“ERISA”) and/or
as defined under the Internal Revenue Code of 1986 (the “Code”) for any financial services provided to a client who is: (i) a plan
participant or beneficiary of a retirement plan subject to ERISA or as described under the Code; or (ii) the beneficial owner of an
Individual Retirement Account (“IRA”).
5 A client could be an individual and their family members, a family office, a foundation or endowment, a charitable organization, a
corporation and/or small business, a trust, a guardianship, an estate, a retirement plan, or any other type of entity to which we choose
to give investment advice.
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Portfolio Management
We will create and manage a diversified portfolio, allocating your assets across various
investments in line with your stated investment objectives. Our management strategies are
not limited to specific products or services; however, the majority of our portfolio allocations
will utilize a mix of equity (“stock”) positions, fixed-income/debt (“bond”) instruments,
Exchange-Traded Funds (“ETFs”), Investment Company (“mutual fund”) products, and
cash/cash equivalent securities to meet your investment objectives6. Unify recommends
investments that have daily liquidity and low fees.
Information regarding our management fee structure is disclosed under “Portfolio Management
Fee” in Item 5, “Fees & Compensation” and further description of our investment strategies
under Item 8, “Methods of Analysis, Investment Strategies & Risk of Loss.”
Financial Planning
A financial plan is a collaborative process that helps maximize a client’s potential for meeting
life goals through Financial Advice that integrates relevant elements of the client’s
personal and financial circumstances⁷. The Financial Planning process includes:
Identifying and Selecting Goals
Implementing the Planning Recommendation(s)
1. Understanding the Client’s Personal and Financial Circumstances
2.
3. Analyzing the Client’s Current Course of Action and Potential Alternative Courses of Action
4. Developing Financial Recommendation(s)
5. Presenting Financial Recommendation(s)
6.
7. Monitoring Progress and Updating
The fee for preparing a financial plan is disclosed under “Financial Planning Fee” under Item
5, “Fees & Compensation”.
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FEES & COMPENSATION
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Discovery Meeting
The discovery meeting is an initial consultation with Unify. During this meeting, Unify seeks to
understand your financial circumstances, goals, and concerns, while providing an overview of its
services, investment philosophy, and planning approach. Unify conducts this meeting in a
manner consistent with its fiduciary standard; however, no advisory relationship is established
until a formal agreement is executed.
The objectives of the discovery meeting include:
Understanding your current financial situation, priorities, and objectives
Identifying potential areas where Unify’s services may provide value
Addressing general questions about your financial circumstances and Unify’s advisory process
Reviewing, at a high level, your current investment strategy, fees, and overall approach
Explaining Unify’s investment methodology and service offerings
Answering questions you have regarding our business and services
6 You may, at any time, impose restrictions in writing on the securities we may recommend (i.e., limit the types/amounts of particular securities
purchased for your account, etc.).
7 All information provided by you, and given to you, will be kept entirely confidential. Such information will be disclosed to third
parties only with mutual written consent or as may be permitted by law.
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The discovery meeting is educational and exploratory in nature and does not constitute
personalized investment advice or a recommendation to take any specific action.
If you choose to engage Unify, a formal advisory agreement will be provided. If you choose not
to engage Unify, you will be responsible for implementing any ideas discussed, and Unify will not
provide ongoing advice, monitoring, or supervision.
Portfolio Management Fee
Portfolio management is provided on an asset-based fee8 arrangement. Regardless of portfolio
size, our management fee is negotiable and will not exceed 1.25% annually.
Portfolio Asset-based fees are assessed on all billable assets under management, including
securities, cash, and money market funds. The initial fee will be based on a client's account
value as of the date the Investment Advisory Agreement (IAA) is signed and will be prorated
based on the number of days from the first day of management to the end of the month in which
the IAA was signed. Subsequently, fees are determined in arrears on the last trading day of each
month and collected during the following month.
Unify retains discretion to negotiate management fees on a client-by-client basis depending on
the size, complexity, and nature of the portfolio. All management fees will be fully disclosed in
the advisory agreement prior to the provision of services.
A minimum initial investment of $100,000 is generally required to open a managed account;
however, Unify reserves the right to waive or reduce this minimum at its discretion.
Protocols for Portfolio Management Services
Discretion
Unless otherwise requested by the client, Unify will maintain discretionary trading authority
to execute securities transactions without prior client approval.
Billing
Accounts are billed in arrears based on the value of the portfolio, including cash and cash
equivalents, as of the last trading day of each month. Fees are collected during the following
month.
Advisory fees will be deducted first from available cash or money market balances. If
sufficient cash is not available, a portion of account assets may be liquidated to cover the
advisory fee.
8 An asset-based fee is a percentage charged based on your assets under management for our financial advice and investment
management. We receive no other compensation for this advisory service unless first disclosed to you.
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Management Fee Exclusions
Custodial Fees
The management fee does not include fees charged by the custodian(s) holding your
account. These fees may include, but are not limited to, transaction fees, transfer taxes,
wire transfer fees, margin interest, account service fees, and other costs associated with
maintaining and trading in your account. These charges are separate from and in addition
to Unify’s management fee.
Unify does not receive any portion of these fees. Custodians may change their fee schedules
at any time, and such changes are outside of Unify’s control.
For more information on the custodial firms, see Item 12, “Brokerage Practices”.
Investment Company Fees
Fees paid to Unify for portfolio management services are separate from fees and expenses
charged by investment companies, such as mutual funds and exchange-traded funds (ETFs).
These expenses typically include management fees, operating expenses, and other fund-
related costs, which are described in each investment’s prospectus.
Unify does not receive any portion of these fees. Clients are encouraged to review the
prospectus of any investment for a complete description of associated costs.
Termination of Portfolio Management Service
Either party may terminate the advisory agreement at any time by providing written notice to
the other party at least five (5) days prior to the termination date.
Clients may provide instructions regarding the disposition of account assets upon termination,
including liquidating the account, transferring assets, or maintaining current positions.
If termination occurs during a billing period, the management fee will be prorated based on
the number of days services were provided during the month.
Upon termination, Unify will cease providing investment advice and portfolio management
services, and the client will be responsible for all future investment decisions.
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Financial Planning Fee
The Financial planning services are provided under a separate agreement and are limited in scope
to the services described therein.
The cost to prepare a financial plan depends on the scope of the engagement, the complexity of
the services requested, and the client’s financial circumstances. Financial planning services are
offered at a negotiable hourly rate not to exceed $200 per hour for the initial engagement. Fees
may be reduced or waived if Unify provides portfolio management services.
The financial planning fee will be fully disclosed in advance and is due upon completion and
delivery of the financial plan, as outlined in the planning agreement9.
Clients may terminate the planning agreement at any time prior to the delivery of the financial
plan. In such cases, Unify will be compensated for services performed through the date of
termination, and any unearned fees will be refunded on a pro-rata basis.
Once the financial plan has been completed and delivered, the planning engagement is
considered fulfilled.
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PERFORMANCE-BASED FEES & SIDE-BY-SIDE MANAGEMENT
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We do not charge fees based on a share of capital gains or the capital appreciation of the assets
held in your accounts.
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TYPES OF CLIENTS
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The Unify offers investment advisory services to individuals and their families, retirement plan
participants, trusts, estates, charitable organizations, and businesses.
Additional information regarding the nature of Unify’s advisory services is described under “Who
We Are” in Item 4, “Advisory Business.”
Unify’s minimum account size for portfolio management services is disclosed under “Portfolio
Management Fee” in Item 5, “Fees & Compensation.” Unify reserves the right to waive or reduce
account minimums at its discretion.
9 Financial plans are generally completed within 30 to 45 days from signing the Agreement. However, implementing the plan with outside
professionals (e.g., attorneys, CPAs) may require additional time beyond our control. Therefore, when we refer to the completion of
the financial plan, we are referring to our delivery of the financial plan.
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METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS
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General Portfolio Management Representation
Unify’s portfolio management services are designed to support your financial goals and
objectives. Your financial needs, investment objectives, time horizon, liquidity needs, tax
considerations, and risk tolerance are used to determine an appropriate investment strategy.
Your portfolio may include a mix of equity (“stock”) positions, fixed-income (“bond”)
instruments, exchange-traded funds (“ETFs”), mutual funds, and cash or cash equivalent
securities.
Unify may recommend alternative investments, such as closed-end funds or derivatives (including
options and commodities), when appropriate based on your investment objectives and risk
tolerance. If such investments are recommended, Unify will discuss the associated risks and
limitations.
Methods of Analysis
Unify uses various analytical methods to evaluate securities and develop appropriate asset
allocation strategies.
Fundamental Analysis
Fundamental analysis is a method of evaluating a financial asset, such as a stock or bond, by
examining its underlying economic and financial characteristics. This includes analyzing
financial statements, key ratios, and broader economic factors to assess the asset’s intrinsic
value and long-term potential. The objective of this analysis is to determine whether a
security is appropriately valued relative to its fundamentals and whether it may contribute
to a client’s long-term investment strategy.
RISKS – Fundamental analysis places greater emphasis on a company’s long-term financial
condition, which may not always correlate with short-term market performance. As a
result, securities may decline in value despite strong underlying fundamentals.
Quantitative Analysis
Quantitative analysis uses mathematical and statistical models to evaluate financial markets
and assets. It involves analyzing data such as historical prices, trading volume, and other
financial metrics to identify patterns and trends. This information is used to support
investment decisions based on statistical probabilities and risk management principles, and
to enhance portfolio construction and optimization.
RISKS – Quantitative analysis relies on historical data and mathematical models, which may
not always accurately predict future market conditions or performance
Cyclical Analysis
Cyclical analysis evaluates economic and market cycles to better understand trends in
economic activity and market behavior. It is based on the concept that economic activity
generally moves through periods of expansion and contraction over time. By assessing where
the economy may be within the business cycle, this analysis provides context for investment
decisions and portfolio positioning.
RISKS – Cyclical analysis may involve assumptions about future economic conditions. If
these assumptions are incorrect, investment decisions based on such analysis may
negatively impact portfolio performance.
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Investment Strategies
Unify is not limited to a single investment strategy or philosophy. Investment decisions are
made using a disciplined approach that considers your financial goals, risk tolerance, and time
horizon, with a focus on long-term objectives.
Asset Allocation Strategy
Asset allocation is the process of selecting a mix of asset classes and allocating capital among
them to align expected returns with a client’s risk tolerance and investment objectives.
Modern Portfolio Theory
Modern Portfolio Theory (“MPT”) 10 is an approach to portfolio construction that focuses on
diversification and the relationship between risk and return. The objective is to construct
a portfolio that seeks to optimize expected returns for a given level of risk.
Strategic Allocation Modeling
Strategic asset allocation involves setting target allocations for various asset classes and
periodically rebalancing the portfolio when allocations deviate due to market
performance.
Tactical Allocation Modeling
Tactical asset allocation is an active approach that adjusts portfolio allocations in response
to changing market conditions and perceived risks or opportunities.
Sharpe Ratio Model
The Sharpe Ratio11 The Sharpe Ratio is a risk-adjusted measure of return used to evaluate
portfolio performance by assessing the level of return achieved relative to the amount of
risk taken.
Core-Satellite Approach
Core-Satellite is an investment strategy that combines a tactically managed core allocation
with a more actively managed satellite allocation. The core portion of the portfolio is
designed to provide broad market exposure and may be adjusted over time based on
changing market conditions and risk considerations. The satellite portion consists of
individual securities intended to complement the core allocation and provide risk-adjusted
return opportunities.
10 The “Portfolio Theory” was developed and introduced by Harry M. Markowitz in his paper “Portfolio Selection” published in 1952 by the
Journal of Finance while he was working on his PhD doctoral thesis at the University of Chicago. Mr. Markowitz further refined his
theory during the latter part of the 1950’s and on into the 70’s. Along the way, his theory became known as the “Modern Portfolio
Theory”. Mr. Markowitz won the Nobel Memorial Prize in Economic Sciences in 1990 as a co-laureate along with William Sharpe
11 Nobel laureate and economist William F. Sharpe developed the Sharpe Ratio.
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Value Investing Strategy
Value investing involves selecting securities that appear to be trading below their intrinsic
value based on an analysis of the underlying business and its financial characteristics. This
approach emphasizes evaluating a company’s fundamentals rather than short-term market
movements.
Unify may identify securities that, based on its analysis, appear to be undervalued relative
to their financial strength and long-term prospects. If a company’s fundamentals support its
valuation, the security may be included in a client’s portfolio consistent with their
investment objectives and risk tolerance.
Bond Portfolio Strategy
The primary objective of Unify’s bond management strategy is to generate income while
preserving capital over the long term. This objective is pursued by investing in fixed-income,
investment-grade securities, including U.S. government obligations, corporate bonds,
mortgage and asset-backed securities, tax-exempt bonds when appropriate, and certificates
of deposit.
A secondary objective is to seek opportunities for capital appreciation through selective
investment in below investment-grade fixed-income securities and convertible securities
when appropriate.
Unify evaluates bond portfolios using the Bloomberg U.S. Aggregate Bond Index as a reference
point, along with analysis of duration, sector allocation, convexity, yield to maturity,
liquidity, and credit quality.
Option-Trading12 Strategy
Unify may use options as part of an investment strategy when consistent with a client’s
objectives and risk tolerance. Options are derivative instruments that involve additional risks
and are not appropriate for all investors.
When utilized, options may be incorporated to help manage risk, enhance income potential,
or support overall portfolio objectives. Unify primarily uses covered call and cash-secured
put strategies and does not engage in the sale of uncovered options.
Options strategies may involve generating income from option premiums, dividend income,
and equity appreciation. These strategies involve trade-offs, including the potential
limitation of upside gains and the risk of being required to buy or sell securities at
predetermined prices.
12 Prior to any options, your custodian must approve your account for the appropriate level of option trading.
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Managing Risk
An important risk to consider is that the value of your investment portfolio may decrease due
to changes in market conditions. This is commonly referred to as market risk or volatility risk.
Other important risks include:
Interest Rate Risk – Rising interest rates may reduce the value of fixed-income
securities. When market interest rates rise, the value (bond price) can decline; and
vice versa, when interest rates fall, bond values can rise.
Equity Risk – Stock values may decline due to market, economic, or company-specific
factors.
Currency Risk – Currency risk is the risk that arises from the change in price of one
currency against that of another. Investment values in international securities can
be affected by changes in exchange rates.
Liquidity Risk – Certain investments may be difficult to sell without affecting their
price because of low volume or demand.
Inflation Risk – Inflation may reduce the purchasing power of investment returns.
Commodity Risk – Commodity price fluctuations may impact related investments.
These risks are not exhaustive. Other risks, including political risk and concentration risk, may
also affect your portfolio. Investing involves risk, including the potential loss of principal. Past
performance is not indicative of future results.
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DISCIPLINARY INFORMATION
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We are required to disclose disciplinary events that may be material for your evaluation of our
advisory practices; therefore, pursuant to Item 9.B. of the Form ADV Part 2A: Firm Brochure, we
are making the following disclosure.
In seeking registration with his prior firm back in 2016, Mr. David L. Bennett didn’t disclose on
his Form U-4 application, submitted to the Florida Office of Financial Regulation (“OFR”), that
he had a motor vehicle infraction in 2005. OFR found that Mr. Bennett made a material
misstatement and ordered his application be denied and he could reapply in 12-months. Mr.
Bennett agreed to the terms with OFR and resubmitted his Form U-4 for registration in Florida
and it was approved by OFR on September 26, 2017. No further action was taken by OFR and
Mr. Bennett is operating in good standing.
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OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS
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We are a fee-only registered investment advisor; none of our supervised persons are licensed
with, or are related to, another financial industry participant, and therefore, no disclosure is
necessary for this item.
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CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
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Code of Ethics
As a fiduciary, Unify has an affirmative duty to provide continuous, unbiased investment advice
and always act in clients' best interest. Unify has adopted a Code of Ethics designed to ensure
that all personnel act in the best interest of clients and maintain high standards of professional
conduct. The Code of Ethics addresses topics such as ethical behavior, confidentiality,
compliance with applicable laws, and the reporting of violations.
Client Transactions
The following disclosures are internal guidelines we have adopted to ensure that your welfare is
not subordinated to any of our or our personnel's interests.
Participation or Interest
It is against our policies for any owners, officers, directors and employees to invest with you
or with a group of clients, or to advise you or a group of clients to invest in a private business
interest or other non-marketable investment unless prior approval has been granted by our
Chief Compliance Officer, and such investment is not in violation of any SEC and/or State rules
and regulations.
Insider Trading Policy
We comply with the Insider Trading and Securities Fraud Enforcement Act of 1988. We do not
share any non-public information with anyone who does not need to know and have established
internal controls to guard your personal information.
Class Actions, Bankruptcies, and Other Legal Proceedings Policy
Unify does not elect to participate in class action lawsuits on your behalf. Such decisions shall
remain with you or with an entity you designate. We will not advise or act on your behalf in
legal proceedings involving companies whose securities are held in your account(s), including,
but not limited to, the filing of "Proofs of Claim" in class action settlements. If desired, you
may direct us to transmit copies of class action notices to you or a third party or to relate
requested claim form information to you or a third party. Upon such direction, we will make
commercially reasonable efforts to forward such notices in a timely manner.
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Personal Trading
Employees of ours are permitted to personally invest their own monies in securities, which may
also be, from time to time, recommended to you. Sometimes, such investment purchases are
independent of, and not connected in any way to, the investment decisions made on your behalf.
However, there may be instances where investment purchases for you may also be made, at or
about the same time, in an employee’s account. This practice can create a conflict of interest
as our employees may benefit from the sale and purchase of those securities. In these situations,
we have implemented the following guidelines to ensure our fiduciary integrity:
1. No employee acting as an Investment Advisor Representative (“IAR”), or who has discretion
over your account, shall buy or sell securities for their personal portfolio(s) where their
decision is substantially derived, in whole or in part, by reason of his or her employment,
unless the information is also available to the investing public on reasonable inquiry. No
employee of ours shall prefer his or her own interest to that of yours or any other advisory
client.
2. Our Chief Compliance Officer reviews securities holdings for all our access employees on a
regular basis.
3. We require that all employees act in accordance with all applicable Federal and State
regulations governing registered investment advisory practices.
4. Aggregate orders (See “Aggregating Trade Orders” below under Item 12, “Brokerage
Practices”) may include employee accounts. In such cases, priority and advantage will be
given to satisfy clients' orders.
5. Any individual not in observance of the above may be subject to termination.
Our Chief Compliance Officer monitors personal trading activities to ensure they do not create
conflicts of interest.
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BROKERAGE PRACTICES
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Custodial Services
The Company has established custodial relationships with the following financial institutions:
Charles Schwab & Company, Inc. (“CS&Co”) – CS&Co is a registered broker-dealer
(member FINRA/SIPC), offering custodial services through their division Schwab Advisor
Services for financial advisors.
Interactive Brokers, LLC (“IB”) – IB is a licensed registered broker-dealer (member
NYSE/FINRA/SIPC), through their Institutional division for investment advisors.
Both CS&Co and IB offer services which include custody of securities, trade execution, clearance
and settlement of transactions. Unify is not a subsidiary or affiliated entity of either CS&Co or
IB. Unify has sole responsibility for investment advice rendered, and advisory services are
provided separately and independently from these custodians.
Our recommendation to custody account(s) with CS&Co and/or IB presents a conflict of interest
because Unify receives certain economic benefits from these relationships that are not typically
available to retail investors. These benefits may create an incentive for Unify to recommend
these custodians. However, Unify selects custodians based on a number of factors, including the
quality of services provided, transaction costs, trading capabilities, and overall value to clients.
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DISCLOSURE BROCHURE
These economic benefits include the following products and services provided without cost or at
a discount:
Receipt of duplicate client statements and confirmations.
Research related products and tools.
Consulting services.
Access to a dedicated trading desk.
Access to batch trading (which provides the ability to aggregate securities
transactions for execution and then allocate the appropriate shares to accounts).
The ability to have advisory fees deducted directly from accounts.
Access to an electronic communications network for order entry and account
information.
Access to mutual funds with no transaction fees and to certain institutional money
managers.
Direction of Transactions and Commission Rates (Best Execution)
Unify has a fiduciary duty to place client interests ahead of its own and to seek best execution
for client transactions. The custodial support services received from CS&Co and IB create an
economic benefit to Unify and a potential conflict of interest.
We select custodians based on factors such as competitive transaction costs, trading platform
capabilities, operational support, financial strength, and overall service quality.
Unify does not recommend, suggest, or make available a selection of custodians beyond CS&Co
or IB. As a result, clients may not have access to other custodians that could offer lower
transaction costs or different services. Clients are not required to use these custodians;
however, if a client directs us to use another custodian, we may not be able to provide the
same level of services or efficiencies, and such arrangements may result in additional costs to
the client.
As part of its duty to seek best execution, Unify may, at its discretion, use another broker-
dealer to execute transactions for client accounts. If we do so, we will be responsible for
negotiating the terms and arrangements with that broker-dealer. When negotiating
commissions, they may be higher than those typically charged by CS&Co or IB.
Unify periodically reviews its custodial relationships and execution quality to evaluate whether
clients are receiving best execution under the circumstances.
Aggregating Trade Orders
Unify seeks to act fairly and impartially when executing client transactions and to take
reasonable steps to obtain best execution. We may aggregate orders for multiple client accounts
into a single block trade when doing so is believed to be in our clients' best interests and
consistent with achieving best execution. When orders are aggregated, each participating
account will receive an average price per share, subject to rounding, and no client will be
intentionally advantaged or disadvantaged.
In determining whether to aggregate orders, Unify considers factors such as:
❖ Security trading volume
❖ Number of client accounts involved
❖ Type of financial instrument and complexity of the order
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REVIEW OF ACCOUNTS
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Portfolio Management Reviews
strategies and
investments are monitored by
the
Investment Advisor
Investment
Representative(s) (“IAR”) managing the portfolio. The general economy, market conditions,
and/or changes in tax law can trigger more frequent reviews. Cash needs will be adjusted as
necessary. Material changes in your personal/financial situation and/or investment objectives
will require reviewing and evaluating objectives and portfolio composite assignment(s). However,
it is your responsibility to communicate these changes to Unify so we can recommend and
implement changes to your investment objectives and portfolio.
Statements are provided at least quarterly, from the custodian, CS&Co and/or IB. You are
encouraged to review the trading activities disclosed on your account statements, portfolio
account value, current holdings, and all account transactions made during the period. It is
important for you to review these documents for accurate reporting and to determine whether
we are meeting your investment expectations.
Financial Planning Reviews
A financial planner will work with you on tasks identified in the financial plan that have been, or
need to be, completed. Once completed, the financial plan should be reviewed at least annually.
Material changes in your finances, lifestyle, personal circumstances, the economy, or tax law
changes can trigger more frequent reviews. However, it is your responsibility to communicate
these changes to Unify so that your financial planning is updated appropriately.
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CLIENT REFERRALS & OTHER COMPENSATION
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Referral Compensation
We do not receive any economic benefit from an independent party for managing your
account(s). In addition, we do not compensate persons/firms for client referrals.
Other Compensation (Indirect Benefit)
As described in Item 12, “Brokerage Practices,” Unify may receive certain products and services
from custodians such as Charles Schwab & Co., Inc. (“CS&Co”) and Interactive Brokers, LLC (“IB”)
without cost or at a discount. These benefits are provided in connection with maintaining client
assets at these custodians and create a potential conflict of interest because they provide an
economic benefit to Unify. Clients do not pay higher transaction costs or advisory fees as a result
of these arrangements. Unify does not receive compensation based on the sale of specific
investment products and is not obligated to invest client assets in any particular securities or
investment products as a result of these arrangements.
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DISCLOSURE BROCHURE
Financial Planning Compensation
Conflicts of interest may arise when Unify recommends outside professionals, such as attorneys,
accountants, insurance agents, or other financial service providers, to assist in implementing
aspects of a financial plan. Although Unify does not receive compensation from these
professionals, such recommendations may create an incentive to refer clients to professionals
who may also refer clients back to Unify. Clients are under no obligation to engage any
professional recommended by Unify and are free to select any qualified professional of their
choosing.
If implementing a financial plan requires the services of a registered representative, insurance
agent, or other licensed professional, those individuals may earn commissions or fees for their
services. Unify does not receive any portion of those fees unless otherwise disclosed.
Any material conflicts of interest associated with such recommendations will be disclosed to
clients as required under applicable laws and regulations.
Notwithstanding such potential conflicts of interest, we strive to serve your best interests and
ensure such disclosures are being properly made to you in compliance with the Investment
Advisors Act of 1940, Rule 275.206.
Retirement Rollover Compensation
Earning a management fee from recommending the rollover of retirement plan assets to an IRA
we manage is considered “self-dealing” and prohibited unless we comply with the Prohibited
Transaction Exemption (“PTE”) 2020-02, “Improving Investment Advice for Workers & Retirees”
exemption issued by the Department of Labor (“DOL”). The DOL considers earning a management
fee “self-dealing” because it increases our compensation and profits while potentially
disregarding the underlying costs paid by, and the services provided under, the retirement plan
that might be more beneficial to you should your retirement assets remain with the plan.
Therefore, when it comes to your retirement assets, there are typically four options you should
consider when leaving an employer:
Leave the account assets in the former employer’s plan, if permitted.
Rollover the assets to the new employer’s plan if one is available and rollovers are
permitted.
Rollover the assets to an Individual Retirement Account (an “IRA”), or
Cash out the retirement account assets (there may be tax consequences and/or IRS
penalties depending on your age.).
Should you choose to rollover your retirement account assets to an individual IRA account, you
understand you are under no obligation to engage us to manage these assets … that you are
free to take your IRA account anywhere to be managed.
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DISCLOSURE BROCHURE
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CUSTODY
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Management Fee Deduction
Unify does not take physical possession of client funds or securities. Client assets are maintained
with their custodian Charles Schwab & Company, Inc. and/or Interactive Brokers, LLC. However,
Unify is defined as having custody of client assets because clients authorize us to deduct advisory
fees directly from their accounts.
To protect clients, Unify has implemented the following safeguards:
Unify is registered with the United States Securities and Exchange Commission (“SEC”)
and discloses its custody status as required.
Client funds and securities are maintained with a qualified custodian in a separate
account in the client’s name.
Clients provide written authorization permitting Unify to deduct advisory fees.
Unify provides clients with an itemized notice of advisory fees, including the formula
used, the assets under management on which the fee is based, and the time period
covered.
Clients will receive account statements, at least quarterly, directly from the qualified custodian.
These statements will include current holdings, valuations, and all account activity. Clients are
encouraged to review these statements carefully and compare them with any reports provided
by Unify.
Standing Letters of Authorization
Unify may allow clients to establish a Standing Letter of Authorization (“SLOA”) to direct the
transfer of funds from their account to a third party (e.g., any person, entity, or account other
than the account owner(s)).
Under SEC rules, the authority to transfer funds pursuant to an SLOA may cause Unify to be
deemed to have custody of client assets.
To address this, Unify follows procedures designed to comply with the conditions outlined in the
SEC’s SLOA No-Action Letter and to safeguard client assets. These procedures include:
The client must provide written authorization identifying the recipient and account
details.
Unify does not have the authority to modify the designated recipient or destination
of funds
Unify will not accept SLOA instructions for transfers to related parties or accounts
associated with Unify.
The timing and amount of transfers may be specified by the client, including open-
ended instructions.
SLOA instructions must be submitted to and approved by the qualified custodian
(CS&Co or IB) in accordance with their procedures.
Verbal SLOA instructions are not accepted.
The qualified custodian provides confirmations of transfers and periodic account
statements directly to clients
The qualified custodian implements additional safeguards in accordance with SEC requirements.
Clients may request additional information regarding these safeguards.
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DISCLOSURE BROCHURE
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INVESTMENT DISCRETION
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Unify generally provides investment management services on a discretionary basis. Discretionary
authority is granted by the client through the execution of an advisory agreement, which
authorizes Unify to buy and sell securities and take other investment actions on behalf of the
client without prior approval for each transaction.
Clients may impose reasonable restrictions on Unify’s discretionary authority by providing written
instructions (e.g., limiting the types of securities that may be purchased or sold, restricting the
use of margin, or prohibiting certain transactions).
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VOTING CLIENT SECURITIES
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Unify does not vote proxies on behalf of clients. Clients retain the right to vote all proxies for
securities held in their accounts.
The qualified custodian will forward proxy materials directly to clients. Upon request, Unify may
provide general information or clarification regarding a proxy matter; however, Unify does not
provide recommendations or advice on how clients should vote.
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FINANCIAL INFORMATION
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Unify is not required to include financial information in this Disclosure Brochure because it does
not take physical custody of client funds or securities and does not require or solicit prepayment
of advisory fees more than six (6) months in advance and in excess of $500.
Unify has no financial condition that is reasonably likely to impair its ability to meet its
contractual commitments to clients.
Unify has not been the subject of a bankruptcy petition at any time during the past ten (10)
years.
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