Intrua Financial “Intrua” is a Registered Investment Adviser (“Adviser”) with the U.S. Securities and Exchange Commission ("SEC") and offers investment advisory services including financial planning and consulting, asset management, and referrals to third-party money managers. Intrua provides investment advice through the Investment Adviser Representatives (“IAR”) associated with Intrua. These individuals are appropriately licensed, qualified, and authorized to provide advisory services on our behalf. General Description of Primary Advisory Services The following are brief descriptions of our primary services. A detailed description of our services is provided in Item 4 – Services, Fees and Compensation so that clients and prospective clients can review the services and description of fees in a side-by-side manner. Financial Planning Intrua offers advisory services in the form of financial planning services. Financial planning services do not involve the active management of client accounts, but instead focuses on a client’s overall financial situation. Financial planning can be described as helping individuals determine and set their long- term financial goals, through investments, tax planning, asset allocation, risk management (i.e., insurance), retirement planning, and other areas. The role of a financial planner and/or the Intrua is to find ways to help the client understand their overall financial situation and help the client set and work toward their financial objectives. Asset Management Intrua offers advisory services in the form of asset management services. Asset management services involve providing clients with ongoing supervision over client accounts. This means we will continually monitor a client’s account and make trades in client accounts when necessary. Intrua generally manages client investments on a discretionary basis although the firm may provide non- discretionary investment management on a case-by-case basis. Use of Third-Party Money Managers Intrua offers advisory services by referring clients to outside, or unaffiliated, money managers that are registered or exempt from registration as investment advisors. Third-party money managers are responsible for continually monitoring client accounts and making trades in client accounts when necessary. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 6 of 26 Investment Management Services Investment Management Services include:
• Quantitative, momentum, and fundamental analysis
• The selection of mutual fund portfolios
• The selection of exchange-traded fund portfolios
• The selection of equities and fixed income investments
• The recommendation of asset allocations consisting of equities, fixed income, options, mutual funds, and other general securities
• Focus on long-term and short-term investment strategies Investment advice is limited to certain types of investments including:
• Exchange-listed securities
• Securities traded over-the-counter
• Exchange-traded funds
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States government securities
• Interests in partnerships investing in real estate, oil and gas Intrua provides investment advice on interests in partnerships, investing in real estate, and oil and gas interests. Advice is provided through consultation services and is limited to review of the prospectus or the offering document to form an opinion as to the appropriateness of the investment for the client. Intrua does not include this portion of a client’s portfolio as managed assets and therefore does not charge a management fee on these investments. Intrua in certain cases, may utilize Unit Investment Trusts as part of the Investment Management Services and may charge a management fee or advisory fee on such assets. Intrua has an Investment Committee which meets regularly to evaluate products, performance, asset classes, etc., to determine if products should be added or removed from investment portfolios. The committees also discuss investment strategies and models. Minutes are kept of all meetings. Portfolio Rebalancing Each Investment advisor manages their portfolios to respond to changing capital market conditions and periodically rebalances the portfolios. Clients may change the portfolio type if their financial or life circumstances change. Intrua requests that clients provide such notification to their Intrua Financial Advisor as soon as practicable following any such changes. Intrua retains the discretionary authority to buy, hold, and sell investments in the client’s portfolio, which may include modifying portfolio allocations, and rebalancing client accounts back to their original client-authorized allocation. Rebalancing may also Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 7 of 26 occur when an Intrua Financial Advisor and/or the client give instructions to Intrua Investment Management Department to change the client’s target allocations or when a client makes additions to or withdrawals from their account(s). Arrangement with LPL Financial and Recommendation of LPL Financial Programs Intrua Financial Advisors may also be Registered Representatives of LPL Financial, LLC (“LPL”), which besides being a broker-dealer, is also an investment advisor registered with the U.S. Securities and Exchange Commission. However, all accounts and advisory services described in this brochure are through Intrua. The use of a direct or three-party agreement allows Intrua to offer LPL Financial Investment Advisory Platform accounts to Intrua clients. Intrua clients investing in LPL Financial Investment Advisory Platforms will be required to complete a three-party agreement between the client, Intrua and LPL Financial. A description of the advisory programs offered through the LPL Financial Investment Advisory Platforms is described in the LPL SWM/SWM II Account packet. The account packet is provided to any client or prospective client who is interested in or has utilized any of the available LPL Financial Investment advisory Programs. Products and Services Available to Us from Charles Schwab & Co., Inc. Charles Schwab & Co., Inc. (“Schwab”) or Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Here is a more detailed description of Schwab’s support services: Services that Benefit the client. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit the client. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:
• provide access to client account data (such as duplicate trade confirmations and account
• statements); Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 8 of 26
• facilitate trade execution and allocate aggregated trade orders for multiple client accounts;
• provide pricing and other market data;
• facilitate payment of our fees from our clients’ accounts; and
• assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:
• Educational conferences and events
• Technology, compliance, legal, and business consulting;
• Publications and conferences on practice management and business succession; and
• Access to employee benefits providers, human capital consultants and insurance providers.
• Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. Our Interest in Schwab’s Services: The availability of these services from Schwab benefits us because we do not have to produce or purchase them. Products and Services Available to Us from Fidelity Investment Company As custodian of your brokerage account, Fidelity, at direction of Intrua, is responsible for:
• The executive, clearance, and securities transactions
• Preparing and sending transaction confirmations and periodic statements of your account
• The custody (or safekeeping), receipt, and delivery of funds and securities
• The extension of margin credit upon approval As a registered Broker/Dealer, Fidelity is subject to the rules and regulations of the SEC, FINRA, and other exchanges of which Fidelity is a member, and the MSRB, Fidelity is also a member of the New York Stock exchange (“NYSE”) and SIPC. We are not a subsidiary of, or affiliated with Fidelity in any manner. We have sole responsibility for investment advice rendered, and advisory services are provided separately and independently from Fidelity. We participate in Fidelity Institutional Asset Management and FMR, LLC (“Programs”) for investment advisors. Our recommendation for you to custody your assets with Fidelity has no direct correlation or link between our participation in the Programs and the investment advice we offer you, although we do receive economic benefits through our participation in the Program that are typically not available to Fidelity retail clients. Many of these services generally may be used to service a substantial number, of our accounts. Fidelity also makes available other services intended to help us manage our business. These services may include:
• Consulting, publications and conferences on practice management Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 9 of 26
• Information technology
• Business succession
• Regulatory compliance
• Marketing In addition, Fidelity may make available, arrange and/or pay for these types of services rendered to us by independent third party providing these services to us. As a fiduciary, we endeavor to act in your best interest. Our recommendation that you maintain your assets in accounts at Fidelity may be based in part on the benefit to us in the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by Fidelity. This may create a potential conflict of interest. Advisory Services Tailored to Individual Needs of Clients Intrua provides services based on the individual needs of the individual client. Therefore, you are given the ability to impose restrictions on your accounts, including specific investment selections and sectors. Wrap-Fee Program versus Portfolio Management Program Intrua may provide asset management services through a wrap-fee program in addition to the traditional management programs it offers. Under a wrap-fee program, advisory services and transaction services are provided for one fee. This is different from traditional management programs whereby services from Intrua are provided for a fee, but transaction services are billed separately on a per-transaction basis. From a management perspective, there is not a fundamental difference in the way Intrua would manage wrap-fee accounts versus traditional management accounts. The only significant difference is the way in which transaction services are paid. Wrap Fee Program We provide asset management services to individuals and businesses. Our focus is on helping you develop and execute plans that are designed to build and preserve your wealth. We currently provide our asset management services in investment programs that bundle or “wrap” services (investment advice, trade execution, custody, etc.) together and charge a single fee based on the value of assets under management. This is a program that allows us to create an investment model portfolio and manage it within your investment guidelines and financial parameters. This program enables you to pursue your investment objectives with us as manager all in one consolidated portfolio. We will serve as the investment adviser to manage only one asset class (e.g., large capitalization common stock portfolio or duration-limited fixed income portfolio) or one investment style from its investment product offering. In such an investment advisory relationship, the portfolio’s investment strategy is more limited by the specific product or investment style being sought by the client. The investments in the portfolio account may include mutual funds, stocks, bonds, ETFs, closed end funds, etc. Investment Strategies and Method of Analysis The Investment Advisors of Intrua will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 10 of 26 Based on the information you share with us; we will analyze your situation and recommend an appropriate Wrap Fee Program. You will be provided with a targeted strategic allocation of assets by class. We currently offer the following Wrap Fee Programs: Intrua and PEG – DSA Models The Investment Committee’s decision within the Intrua and PEG – DSA Models (collectively the “DSA Models”) will be based on the recommendations of DiMeo Schneider & Associates (“DiMeo”) and due diligence conducted by Intrua’s internal research analysts. The DSA Models are several different portfolio platforms that addresses the suitability over most of the client needs. These models will be focused on investing in Mutual Funds and Exchanged Traded Funds (“securities”) in order to achieve diversification in the overlying models. DiMeo conducts investment consulting for several investment advisers. They provide advice that is customized to Intrua’s (and its clients) needs, and goals. DiMeo provides Intrua due diligence and proprietary tools that are intended to improve the risk and returns of the Models. DiMeo’s investment insights will assist the Investment Committee on decisions on portfolio weighting and rebalancing in this dynamic market. However, DiMeo is a key tool for the DSA Models, the Investment committee is under NO OBLIGATION, to select or time the purchase/sales of securities that are recommended by DiMeo. Intrua’s research staff will continually monitor the underlying securities of the DSA Models. If a security does not maintain the risk and return requirements for the DSA Models, this will be reported to the members of the Investment Committee. The Investment Committee will determine the appropriate course of action, which may include reweighting the portfolio and/or removing the downgraded security(ies). The allocations of the DSA models will apply at the time a client establishes an account. Additions to and withdrawals from an account will generally be invested based on the suitable allocation. Fluctuations in the market value of the securities, as well as of the factors, however, will affect the actual asset allocation at any given time. Intrua will monitor the securities, in the portfolios and rebalance the allocations if those allocations exceed the predefined investment the range for the portfolio’s allocations. All models will reinvest dividends and capital gains distributions (if any) if the client does not provide instructions to hold such payments. Participation and Protection Models Intrua offers Participation and Protection Models (collectively the “P&P Models”) that will be based on the recommendations of the Q Consulting model and will be supervised by Intrua’s internal research analysts. The P&P Models are several different portfolio platforms that address the suitability over most of the client needs. These models will be focused on investing in various investment companies in order to achieve diversification in the overlying models. Models are defined by the levels of risk that are acceptable for the client with the max drawdown (tested by Monte Carlo simulations) being the differential factor. Q Consulting conducts investment consulting for several investment advisers. They provide advice that is customized to Intrua’s (and its clients) parameters. Q Consulting provides investment guidance with proprietary tools that are intended to improve the risk and returns of the Models. Q Consulting’s investment guidance will decide the portfolio weighting in this dynamic market. However, Q Consulting is Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 11 of 26 the deciding factor for the P&P Models, the Investment committee is under NO OBLIGATION, to select or time the securities that are recommended by Q Consulting. Intrua’s research staff will continually monitor the underlying securities of the P&P Models. If a security does not maintain the risk and return requirements for the P&P Models, this will be reported to the members of the Investment Committee. The Investment Committee will determine the appropriate course of action, which may include reweighting the portfolio or removing the downgraded security. The allocations of the P&P models will apply at the time a client establishes an account. Additions to and withdrawals from an account will generally be invested based on the suitable allocation. Fluctuations in the market value of the securities, as well as of the factors, however, will affect the actual asset allocation at any given time. Intrua will monitor the securities in the portfolios and rebalance the allocations if those allocations exceed the investment range (of 2% or more of the aggregated portfolio’s holdings) for the portfolio’s allocations. All models will reinvest dividends and capital gains distributions (if any) if the client does not provide instructions to hold such payments. Advisory Representative Account Programs Intrua, offers an Advisory Representative Account Program (“ARAP”) that is directed by the Investment Adviser Representatives. Rather than having guidance from a third party and Intrua’s Investment Committee, these programs will be directed by the client’s Investment Adviser Representatives. This will offer the client the opportunity to maintain investment authority within their account and delegate the level of investment discretion to their financial advisor. Intrua will provide the support services for client and financial advisers through the ARAP, such as establishing custodial service providers, initiating and/or adjusting pre-existing periodic investment and payment/disbursement plans, account inquiry services, billing and payment support, performance reporting, sales support, compliance oversight, educational/research opportunities, and other account maintenance services. The ARAP will provide the client with ongoing investment advise and monitoring of securities holdings by their Investment Adviser Representative. The Investment Adviser Representative will supervise their account on a discretionary basis, according to the client’s objectives. These accounts will be supervised by Intrua on a periodic basis to ensure that these portfolios comport with client suitability and the portfolio(s) guidelines. As part of our asset management services provided with our Wrap Fee Programs, we will:
• Review your present financial situation
• Monitor and track assets under management
• Provide portfolio statements, asset allocation statement, rebalanced statements as needed
• Advise on asset selection
• Determine market divisions through asset allocation models
• Provide research and information on performance and fund management changes Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 12 of 26
• Build a risk management profile for you
• Monitor our portfolios for style drift and benchmark performance, and provide portfolio rebalancing as necessary
• Assist you in setting and monitoring

goals and objectives
• Provide personal consultations as necessary upon your request or as needed. You must notify us promptly when your financial situation, goals, objectives, personal circumstances, or needs change. You shall have the ability to impose reasonable restrictions on the management of your account, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. Under certain conditions, securities from outside accounts may be transferred into your advisory account; however, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. Certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is not indicative of future results. Intrua manage assets on a discretionary basis, which means you have given us the authority to determine the following without your consent:
• Securities to be bought or sold for your account
• Number of securities to be bought or sold for your account
• Broker-dealer to be used for a purchase or sale of securities for your account
• Commission rates to be paid to a broker or dealer for your securities transaction. If you have not given us the authority to manage your account on a discretionary basis, then we cannot trade in your account without your express permission. Trading may be required to meet initial allocation targets, after substantial cash deposits that require investment allocation, and/or after a request for a withdrawal that requires liquidation of a position. Additionally, your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule we have determined together. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. We are not tax professionals and do not give tax advice. However, we will work with your tax professional to assist you with tax planning. You will have the opportunity to meet with us periodically to review the assets in your account. We will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian, and not with us. We recommend LPL Financial or Schwab as the independent custodian for all accounts that we manage, and at the request of the client will utilize the services of a different custodian of the client’s choice if approved by the Intrua Financial Compliance team. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 13 of 26 You will also receive our Investment Advisory Agreement which describes what services you will receive and what fees you will be charged. We are available during normal business hours either by telephone, fax, email, or in person by appointment to answer your questions. Fees and Compensation A wrap fee program allows you to pay a specified fee for portfolio management services and the execution of transactions. The fee is not based directly upon transactions in your account. The fee is bundled with our costs for executing transactions in your account(s). Our minimum account opening balance is $15,000 which may be negotiable based upon certain circumstances. The fee charged is based upon the amount of money you invest, but maybe negotiated on a case-by-case basis. Multiple accounts of immediately-related family members, at the same mailing address, may be considered one consolidated account for billing purposes. Fees are charged monthly or quarterly, in arrears. Fees will be calculated on the ending balance of the previous period, will be billed within the first two weeks of the period and will be calculated per the fee schedule negotiated fees may not exceed 2.50%. Fee Schedules For purposes of calculating quarterly Account Fees, for those participating in Strategic Wealth Management II Program (“SWM II”) the account period will be based on the appropriate fee cycle. Fee cycles are as follows and will be based upon the date in which the client funds their account(s): Cycle 1 Cycle 2 Cycle 3 January February March April May June July August September October November December For purposes of calculating Account Fees, for those participating in the Manager Access Select / Manager Access network (“MAS/MAN”), Model Wealth Portfolio (“MWP”) & Personal Wealth Portfolio (“PWP”) programs the account quarter will be based on Cycle 3 above. Our Advisory Account Application defines what fees are charged and their frequency whether monthly or quarterly. The fees shown above are annual fees and may be negotiable based upon certain circumstances. Fees for partial periods will be charged on a pro rata basis based on the number of days remaining in the billing period. No increase in the wrap fee shall be effective without prior written notification to you. We believe our wrap fee schedule is reasonable considering the fees charged by other investment advisers offering similar services/programs. Our fees will not be based upon a share of capital gains or capital appreciation of the funds or any portion of your funds. If the Wrap Fee Brochure is not delivered to the Client at least 48 hours prior to entering into the management agreement, the Client may terminate the agreement for services within five business days of execution without penalty. After the five-day period, either party, upon 30 days written notice to the Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 14 of 26 other, may terminate the management agreement. The management fee will be pro-rated for the month in which the cancellation notice was given, and any unearned fees will be returned to the client via check. You will authorize the custodian to directly debit fees from your account held at the custodian and to pay us. Management fees are prorated for each contribution and withdrawal made during the applicable calendar quarter (with the exception of small inconsequential contributions and withdrawals). You will be provided with a quarterly statement reflecting deduction of the advisory fees. By participating in a wrap fee program, Clients may end up paying more or less than they would through a non-wrap fee program. The relative cost of the program includes trade execution costs that would typically be passed directly through to the Client by the executing broker. Clients could invest in debt and equities directly, without the Adviser’s services. In that case, Clients would not receive the services provided by the Adviser which are designed, among other things, to assist in determining which funds are appropriate for the portfolio and the Client’s Account. In our wrap fee program, we include all trade charges for your account; however, our fees do not include other related costs and expenses. You may incur certain charges imposed by custodians, and other third parties. These include custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds and exchange-traded funds (ETFs) also charge internal management fees, which are disclosed in the fund’s prospectus. These fees may include, but are not limited to, a management fee, upfront sales charges, and other fund expenses. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as “12(b)(1) fees”. These 12(b)(1) fees come from fund assets, and thus indirectly from clients’ assets. We do not receive any compensation from these fees. All of these fees are in addition to the management fee you pay us. You should review all fees charged to fully understand the total amount of fees you will pay. Services similar to those offered by us may be available elsewhere for more or less than the amounts we charge. Since the Adviser does not charge Clients fees based on trading activity, the Adviser may have an incentive to limit trading activities in Client account(s) because the Adviser is charged for executing trades. In addition, the amount of compensation received by the Adviser may be more than what the Adviser would receive if the Client paid separately (“unbundled”) for investment advice, brokerage, and other services. Therefore, the Adviser may have a financial incentive to recommend the wrap fee program over other programs or services. The Adviser monitors all Client accounts to ensure that the Adviser’s fiduciary duty is met for all Clients. Any breaches of the Adviser’s fiduciary duty are noted, and appropriate repercussions are initiated to deter such behavior. Third-Party Managed Account Programs Intrua offers a variety of third-party manger programs. Under these programs, a third-party asset manager manages the client’s account. A description of the third-party manager programs and associated fees and compensation details are located below. Manager Access Select Program Manager Access Select provides clients access to the investment advisory services of professional portfolio management firms for the individual management of client accounts. Advisor will assist client in Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 15 of 26 identifying a third-party portfolio manager (Portfolio Manager) from a list of Portfolio Managers made available by LPL. The Portfolio Manager manages client’s assets on a discretionary basis. Advisor will provide initial and ongoing assistance regarding the Portfolio Manager selection process. A minimum account value of $100,000 is required for Manager Access Select, however, in certain instances, the minimum account size may be lower or higher. Optimum Market Portfolios Program (OMP) OMP offers clients the ability to participate in a professionally managed asset allocation program using Optimum Funds shares. Under OMP, client will authorize LPL on a discretionary basis to purchase and sell Optimum Funds pursuant to investment objectives chosen by the client. Advisor will assist the client in determining the suitability of OMP for the client and assist the client in setting an appropriate investment objective. Advisor will have discretion to select a mutual fund asset allocation portfolio designed by LPL consistent with the client’s investment objective. LPL will have discretion to purchase and sell Optimum Funds pursuant to the portfolio selected for the client. LPL will also have authority to rebalance the account. A minimum account value of $10,000 is required for OMP. In certain instances, LPL will permit a lower minimum account size. Personal Wealth Portfolios Program (PWP) PWP offers clients an asset management account using asset allocation model portfolios designed by LPL. Advisor will have discretion for selecting the asset allocation model portfolio based on client’s investment objective. Advisor will also have discretion for selecting third party money managers (PWP Advisors), mutual funds and ETFs within each asset class of the model portfolio. LPL will act as the overlay portfolio manager on all PWP accounts and will be authorized to purchase and sell on a discretionary basis mutual funds, ETFs and equity and fixed income securities. A minimum account value of $250,000 is required for PWP. In certain instances, LPL will permit a lower minimum account size. Model Wealth Portfolios Program (MWP) MWP offers clients a professionally managed mutual fund asset allocation program. [Advisor] will obtain the necessary financial data from the client, assist the client in determining the suitability of the MWP program and assist the client in setting an appropriate investment objective. The Advisor will initiate the steps necessary to open an MWP account and have discretion to select a model portfolio designed by LPL’s Research Department consistent with the client’s stated investment objective. LPL’s Research Department or third-party portfolio strategists are responsible for selecting the mutual funds or ETFs within a model portfolio and for making changes to the mutual funds or ETFs selected. The client will authorize LPL to act on a discretionary basis to purchase and sell mutual funds and ETFs and to liquidate previously purchased securities. The client will also authorize LPL to effect rebalancing for MWP accounts. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 16 of 26 MWP requires a minimum asset value for a program account to be managed. The minimums vary depending on the portfolio(s) selected and the account’s allocation amongst portfolios. The lowest minimum for a portfolio is $25,000. In certain instances, a lower minimum for a portfolio is permitted. Guided Wealth Portfolios (GWP) GWP offers clients the ability to participate in a centrally managed, algorithm-based investment program, which is made available to users and clients through a web-based, interactive account management portal (“Investor Portal”). Investment recommendations to buy and sell exchange-traded funds and open-end mutual funds are generated through proprietary, automated, computer algorithms (collectively, the “Algorithm”) of FutureAdvisor, Inc. (“FutureAdvisor”), based upon model portfolios constructed by LPL and selected for the account as described below (such model portfolio selected for the account, the “Model Portfolio”). Communications concerning GWP are intended to occur primarily through electronic means (including but not limited to, through email communications or through the Investor Portal), although [Advisor] will be available to discuss investment strategies, objectives or the account in general in person or via telephone. A preview of the Program (the “Educational Tool”) is provided for a period of up to forty-five (45) days to help users determine whether they would like to become advisory clients and receive ongoing financial advice from LPL, FutureAdvisor and [Advisor] by enrolling in the advisory service (the “Managed Service”). The Educational Tool and Managed Service are described in more detail in the GWP Program Brochure. Users of the Educational Tool are not considered to be advisory clients of LPL, FutureAdvisor or [Advisor], do not enter into an advisory agreement with LPL, FutureAdvisor or Intrua Financial, do not receive ongoing investment advice or supervisions of their assets, and do not receive any trading services. A minimum account value of $5,000 is required to enroll in the Managed Service. SEI Investments Intrua participates in the Separately Managed Accounts Program (the Program) sponsored by SEI Investments Management Corporation (SIMC). To participate in the Program, Intrua, SIMC and each client execute a three-party agreement (hereinafter, a Managed Account Agreement) providing for the management of certain investor assets in accordance with the terms thereof. By means of the Managed Account Agreement, the client appoints Intrua as its investment advisor to assist the client in selecting an asset diversification strategy, which includes allocating a percentage of client assets to designated portfolios of separate securities (each, a Separately Managed Account Portfolio) and which may include a percentage of assets allocated to a portfolio of mutual funds sponsored by SIMC or an affiliate of SIMC. The client appoints SIMC to manage the assets in each Separately Managed Account Portfolio in accordance with a strategy selected by the client together with Intrua. SIMC may delegate its responsibility for selecting particular securities to one or more portfolio managers. The Fee Schedule for the Separately Managed Accounts Program depends upon the nature of the securities in the portfolio and investment strategy as follows:
• The fees payable for the Tier 1 Strategy, which includes the Tax Managed Core, Equity Core, Large Cap, Managed Volatility, Mid Cap, Multi-Strategy SMA, Global, Risk Regime, and International Developed Strategies, range from 0.90% to 0.65%. Intrua Financial ADV Part 2A Appendix 1 August 18, 2023 Page 17 of 26
• The fees payable for the Tier 2 Strategy, which includes the Small Cap and Real Estate Strategies, range from 1.10% to 0.85%
• The fees payable for the Tier 3 Strategy, which includes the International Emerging Strategy, range from 1.25% to 1.00%
• The fees payable for the Tier 4 Strategy, which includes the Active Municipal Bond, Active U.S. Fixed Income, Active Preferred Stocks, Alternative Income, and Active Core Fixed Income, range from 0.65% to 0.45%
• The fees payable for the Tier 5 Strategy, which includes the SEI ETF Strategies and the SEI Factor- Based Strategies, range from 0.55% to 0.20%
• The fees payable for the Tier 6 Strategy, which includes the Laddered Strategies, range from 0.30% to negotiable Additionally, the SEI Program offers a feature called Automated Tax Management (ATM), formerly known as Integrated Managed Accounts Program (IMAP), which is an enhancement to the standard program. In ATM, SIMC appoints a tax overlay manager for the equity portion of the client’s Managed Account Portfolio. The various equity sub-advisors for the client’s portfolio provide buy/sell lists to the overlay manager, who then is responsible for executing the transactions (within the parameters of performance and security weighting variances from the underlying model portfolios), with the goal of increased coordination across the equity account, increased tax efficiency and minimization of wash sales. Neither the tax manager nor SIMC offers tax advice; clients should consult with their tax advisors as to the suitability of IMAP for their accounts. SIMC charges clients an integration fee when the client selects the IMAP feature. These additional fees apply only to the equity portion of a client’s account that is allocated to the integrated equities portfolio; the fees do not apply to the fixed income or mutual funds portion of the client’s account (if applicable). A selection of clients may receive a fee discount. These fees may be higher or lower than those charged by other investment advisors for similar services. SIMC pays a portion of this fee to the portfolio manager acting as the accounts’ integration manager. The fees payable for Integrated Managed Account Feature:
• 0.10% in addition to the Tier fees described above SIMC may impose minimum account balances, which will typically vary between $50,000 to $250,000 depending upon the manager selected in the Managed Account Portfolio chosen and whether the client selects the ATM feature. To the extent a client’s assets in a Managed Account Program account are invested in SEI Funds, SIMC and its affiliates will earn fund-level fees on those assets, as set forth in the applicable Fund’s prospectus, but SIMC will waive the fees set forth above on Managed Account Program assets invested in any SEI Fund. Each SEI fund pays an advisory fee to SIMC that is based on a percentage of the portfolio’s average daily net assets, as described in the mutual fund’s prospectus. From such amount, SIMC pays the sub-advisor(s) to the fund. SIMC’s fee is negotiable, but it typically ranges from 0.10% to 1.50% of the portfolio’s average daily net assets for its advisory services. Affiliates of SIMC provide administrative, distribution and transfer agency services to all of the portfolios within the SEI Funds, as described in the SEI Funds’ registration statements. These fees and expenses are paid by the SEI Funds but ultimately are borne by each Intrua Financial ADV Part 2A Appendix 1 July 18, 2023 Page 18 of 26 shareholder of the SEI Funds. Clients may also pay custody fees to SEI Private Trust Company (SPTC) when SPTC has custody of their assets. These fees will vary depending on the account balance and trade activity in the account. Clients can refer to their account application for specific information on SPTC custody fees. SIMC investment advisory fees are calculated as a percentage of the market value of the client’s account assets. The fees are calculated and payable quarterly in arrears and net of any income, withholding or other taxes. The asset-based Intrua Fee & Compensation Schedule detailed in the Wrap Fee Program section includes the fees Intrua charges for its services in connection with SEI’s program. SEI Trust Company debits the client’s account on a quarterly basis for all of the above-mentioned fees and charges. The charges to the account are calculated and debited in arrears and are remitted quarterly net of any applicable account and performance reporting charges not charged to the customer. Upon written notification, the SEI Managed Account Agreement may be terminated by either Intrua or the client. Prorated fees will be charged based on market value on the date the termination notice is received. All fee arrangements are subject to negotiation and possible modification. Clients receive monthly statements from SEI Trust Company indicating holdings. A quarterly report, indicating market value, cash flows, gains and losses, asset allocation, and performance as it relates to market indices, is also available if the investor elects to receive it. Annually, the client will receive a tax statement for the account.