Description of Firm
Steward Partners Investment Advisory, LLC (“SPIA”), a limited liability company organized under the laws
of the State of Delaware, is a registered investment adviser (“RIA”) primarily based in New York, New York.
SPIA has been providing investment advisory services since March 2016. SPIA is wholly-owned by Steward
Partners Management Holdings, LLC (“SPMH”). Steward Partners Investment Solutions, LLC (“SPIS”)
operates as a broker-dealer and RIA registered with the SEC, wholly-owned by SPMH. Steward Partners
Investment Advisory, LLC (“SPIA”) and Elan Wealth Management, LLC (“EWM”) (hereinafter collectively
referred to as "Affiliated Advisers”) are separate SEC-registered investment advisers. SPIS, its Affiliated
Advisers and Steward Partners Global Advisory, LLC (“SPGA”), also a wholly owned subsidiary of SPMH, are
affiliates and separately operated. SPGA provides corporate and related services to SPIA, SPIS and its
Affiliated Advisers.
Raymond James & Associates, Inc. (“RJA”), acts as a custodian and a clearing agent to Client accounts
introduced by SPIA and facilitates various advisory programs through Asset Management Services (“AMS”),
an operating division of RJA (collectively “RJA”).
SPIA offers insurance and investment products and services directly and through our clearing
custodian, Raymond James & Associates, Inc. (“RJA”, “Raymond James” or the “Custodian”). SPIA has no
banking division and does not offer any proprietary products to Clients.
Available Account Types and Relationships
When you choose to purchase products and services through SPIA, you have the option of investing
through a transaction-based account, such as a brokerage account, a fee-based investment advisory
program, or both. It is important for you to understand the services you will receive, the fees, costs, and
expenses you will pay, and SPIA’s and your IAR’s conflicts of interest in connection with each of these
different types of accounts and relationships with SPIA. These services, fees, costs, expenses, and
conflicts of interest are described below and in greater detail in the Form CRS for SPIA and SPIS,
respectively. You can find the most recent Form CRS for SPIS broker-dealer at the following location
https://files.brokercheck.finra.org/crs_1254.pdf .
The following paragraphs describe our services and fees. Please refer to the description of each
investment advisory service listed below for information on how we tailor our advisory services to your
individual needs. As used in this brochure, the words "we," "our," "firm," and "us" refer to Steward
Partners Investment Advisory, LLC (“SPIA”) and the words "you," "your," and "Client" refer to you as either
a Client or prospective Client of our firm. You will also see the term "Associate" throughout this brochure.
This term refers to our officers, directors, employees, financial professionals, and other personnel of our
firm. The term “Investment Advisor Representative” or “IAR” refers to the financial professional who
provides investment advice on behalf of our firm.
The delivery of the below described services (and their related financial products and services) occurs
through our relationship with other parties described as follows:
Investment Advisory and Portfolio Management Services
SPIA has a fiduciary duty to provide services consistent with the Client's best interest. We offer
discretionary and non-discretionary portfolio management services generally exercised within the
auspices of the managed account program. Regardless of the program(s) selected, when you engage
for portfolio management services, we will consult with you to discuss your financial circumstances and
objectives and to assist you in determining (a) an appropriate set of financial goals, (b) a time horizon for
your investments, and (c) your level of risk tolerance. Based on our evaluation of your financial situation,
we will provide you with recommendations as to which investment program is the most appropriate for
management of your assets and as to which particular investments, asset allocation models, and/or
underlying third-party managed investment program(s) is suited for your investment profile. Our
investment advice is tailored to meet our clients’ needs and investment objectives.
As part of its investment advisory services, SPIA will review Client portfolios on an ongoing basis to
determine whether changes are necessary based upon a change in the Client's investment objective,
risk tolerance or other factors. Based upon this, there will be extended periods of time when we
determine that changes to a Client's portfolio or the investment program are not necessary, nor
prudent. Clients remain subject to the fees described in Item 5 during periods of account inactivity. As
indicated below, there can be no assurance that investment recommendations and decisions made by
SPIA will be profitable or equal any specific performance level(s).
Types of Investments
We offer advice on a broad range of securities including, but not limited to, equity securities, warrants,
corporate debt securities, certificates of deposit, municipal securities, variable life insurance, variable
annuities, mutual fund shares, exchange traded funds (ETFs), and options. We do not primarily
recommend one particular type of security over another since each Client has different needs and a
different tolerance for risk. Additionally, we can also provide advice on other types of investments held
in your portfolio at the inception of our advisory relationship.
ESG/Socially Responsible Investing
Certain Clients may desire to invest all, or a portion, of their investment portfolio in socially responsible
securities including but not limited to mutual funds and exchange traded funds (the “ESG Funds”) (i.e.,
Funds that have a mandate to avoid, when possible, investments in alcohol, tobacco, firearms, oil
drilling, etc.). There are potential limitations associated with allocating a portion of an investment
portfolio to ESG Funds. The number of ESG Funds are substantially few when compared to those that
do not maintain such a mandate. ESG Funds could underperform broad market indices. Investors
must accept these limitations, including the potential for underperformance. The Client is under no
obligation to invest any portion of their portfolio in ESG Funds. As with any type of investment
(including the investments and/or investment strategies recommended and/or undertaken by SPIA),
there can be no assurance that an investment in ESG Funds will be profitable or prove successful.
Wrap Fee Programs Sponsored by Third-Party Money Managers (“TPMM”)
An account that is considered to be a wrap fee program is not charged commissions and/or transaction
fees. The advisory fee paid by the Client includes custody, trades, management expertise and reporting
in a bundled format. In such instances your IAR receives a portion of the wrap fee.
A Client's total cost for each of the services provided through these programs could be different if
purchased separately. Cost considerations include the Client's ability to:
1. Obtain the services provided within the programs separately from any of the mutual fund
sponsors,
2. Invest and rebalance the selected mutual funds without the payment of a transaction
charge, and
3. Obtain performance reporting comparable to those provided within each program.
When comparing costs, the combination of multiple mutual fund investments, advisory services,
custodial and brokerage services available through each program may not be available separately. As
such, Clients are subject to have multiple accounts, sign numerous documents, and incur various fees.
If an account is not actively traded or the Client qualifies for reduced sales charges, the fees in these
programs can be more expensive than if utilized separately.
Our IARs have a financial incentive to recommend a fee-based advisory program rather than having you
pay separately for investment advisory services, brokerage, performance reporting and other services. A
portion of the annual fee charged in fee-based programs is paid to our IARs. This can be more than what
would be received under an alternative program or if these services were paid for separately. Our IARs have
a financial incentive to recommend a particular account program over another. Compensation structures
vary by product type, our IARs may receive higher compensation for certain product types.
We believe the charges and fees offered within each fee-based program are competitive and reasonable.
However, we make no guarantee that the aggregate cost of a particular program is lower than that
which is available elsewhere. If you participate in a wrap fee program, we will provide you with a separate
Wrap Fee Program Brochure explaining the program and costs associated with the program.
Within our investment advisory programs, we offer separately managed accounts (“SMA’s), multiple
discipline accounts, unified managed accounts (“UMA’s”), mutual fund and/or exchange-traded
funds(“ETF’s”) asset allocation programs through Asset Management Services (“AMS ), an operating
division of RJA (each, an “AMS Managed Program”) and a dual contract managed account platform, also
through AMS, in which you enter into a separate contract with an outside manager. RJA also sponsors a
program where your Investment Advisor Representative (“IAR”), advises you on your account assets (“FA
Advisory Program” or “Ambassador”). While RJA is the wrap fee program sponsor of the FA Advisory
Program, the IAR and its associated registered investment adviser is providing you advisory services.
Each of the AMS Managed Programs is a discretionary program, whereas the FA Advisory Program can
be discretionary or non-discretionary. In a discretionary account, you delegate to your IAR the authority
to decide what securities to buy or sell for your account. In a non-discretionary account, your IAR will
provide you with advice in the form of recommendations but the decision to buy or sell securities is
made by you. Your delegation of investment discretion to RJA will generally result in securities and other
investment prospectuses (and other associated regulatory mailings) being available to RJA as the
program’s Manager for investment purposes. We will make these documents available to you upon
request.
Once selected, the TPMM(s) will invest the Client's assets, typically on a discretionary basis, in accordance
with their stated investment discipline(s) and strategy(ies) and without soliciting the Client's consent
prior to engaging in portfolio transactions. You will have the ability to impose reasonable restrictions on
the investments made in your account, contribute or withdraw securities and/or cash from your
account, and/or to request the sale of individual securities for tax planning purposes (also called "tax
harvesting") within your account. Our role is to consult with you and select and adjust (or assist you in
selecting and adjusting) the particular TPMM(s) to be engaged
for management of the assets within
your account. In summary, these accounts are intended to provide our Clients with flexibility in
developing a customized portfolio diversified across multiple investment disciplines or one which is
targeted to an individual or more concentrated investment discipline through the use of a diverse set of
available TPMMs. Please see the respective RJA Wrap Fee Brochure for additional details concerning
these programs.
Other Asset Management Services
SPIA also offers asset management services to former clients of Monaco Capital Management, LLC and
Saling Simms Associates Inc. These specific services, as described in more detail below, are not offered
to new clients of SPIA.
Monaco Capital Management, LLC
Clients of these services are provided with continuous advice regarding the investment of client funds
based on the individual needs of the client. Through personal discussions in which goals and objectives
based on a client’s particular circumstances are established, we develop a client’s personal investment
policy and create and manage a portfolio in accordance with that policy. Account supervision is guided
by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, growth and
income, etc.).
A portfolio consists of one or all of the following: individual equities, bonds, no-load mutual funds, load-
waived mutual funds, exchange-traded funds or funds whose sales charge is waived, and/or other
investment products. We allocate the client’s assets among various investments, taking into
consideration the overall management style selected by the client. Clients can place reasonable
restrictions on the types of investments that will be made on the client’s behalf. Clients will retain
individual ownership of all securities.
Services may be provided on a discretionary basis, meaning that we possess the discretion to buy and
sell individual stocks, funds, bonds, and other investments. Please refer to the terms the advisory
agreement for details.
Saling Simms Associates Inc.
This program is a wrap fee investment advisory account administered by SPIA. Your IAR will manage
your account on a discretionary or non-discretionary basis according to your objective.
This account offers you the ability to pay an asset based advisory fee which includes transaction costs
within the advisory fee in lieu of a commission for each transaction. Please refer to the terms the advisory
agreement for details.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to
Clients regarding the management of their financial resources based upon an analysis of their individual
needs. These services can range from broad-based financial planning to consultative or single subject
planning. If you retain our firm for financial planning services, we will meet with you to gather
information about your financial circumstances and objectives. Your IAR may also use financial planning
software to determine your current financial position and to define and quantify your long-term goals
and objectives. Once we specify those long-term objectives (both financial and non-financial), we will
develop shorter-term, targeted objectives. Once we review and analyze the information you provide to
our firm and the data derived from our financial planning software, we will deliver a written plan to you,
designed to help you achieve your stated financial goals and objectives.
While reviews and updates to the financial plan are not part of the contracted services, at your request
we will review your financial plan to determine if the investment advice provided is consistent with your
investment needs and objectives. We will also update the financial plan at your request. At our sole
discretion, reviews and updates can be subject to a negotiable flat fee, hourly rate, or percentage of
assets. If you implement the financial planning advice provided by our firm, you will receive trade
confirmations and monthly or quarterly statements from relevant custodians, for a securities account.
Financial plans are based on your financial situation at the time we present the plan to you, and on the
financial information you provide to us. You must promptly notify our firm if your financial situation,
goals, objectives, or needs change.
Financial Consulting Services
We offer financial consulting services that primarily involve advising Clients on specific financial-related
topics. The topics we address include but are not limited to: risk assessment/management, investment
planning, retirement planning, financial organization, or financial decision making.
Advised Retirement Plan Accounts Program
We utilize an unaffiliated third-party platform that can allow an IAR of the Firm to facilitate the
management of held-away assets for certain employer-sponsored retirement plan assets on a
discretionary basis. Through this platform, the Firm does not take custody of your funds and does not
have direct access to your account(s). A link will be provided to the Client, allowing them to connect
account(s) to the platform. Once your account(s) is connected to the third-party platform, your IAR will
review the current account(s) allocations and, when necessary, will make any changes in the current
holdings and/or future allocations based on their understanding of your goals, objectives, risk tolerance,
and any other circumstances necessary to make investment changes within the account. Account
allocations are limited based on the options made available by the employer-sponsored plan and such
limitations may impact the IARs ability to effectively manage the assets. Please be mindful that should
your employer-sponsored plan make a “brokerage window” available, your IAR will not be able to
manage securities through this feature.
Pension Consulting Services
We offer pension consulting services to employee benefit plans and their fiduciaries based upon the
needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these
services include an existing plan review and analysis, plan-level advice regarding fund selection and
investment options, education services to plan participants, investment performance monitoring, and/or
ongoing consulting. These pension consulting services will generally be non-discretionary and advisory
in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other
named fiduciary.
• We also offer assistance with participant enrollment meetings and provide investment-related
educational seminars to plan participants on such topics as: diversification, asset allocation, risk
tolerance, and time horizon.
Our educational seminars include other investment-related topics specific to the particular plan.
We also provide additional types of pension consulting services to plans on an individually negotiated
basis. All services, whether discussed above or customized for the plan based upon requirements from
the plan fiduciaries (which may include additional plan-level or participant-level services) shall be
detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
We will determine with the Client in advance the scope of services to be performed and the fees for all
requested services. Prior to engaging us to provide consulting services, the Client will be required to
enter into a written agreement with us setting forth the terms and conditions of the engagement,
describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements.
The services outlined above that we provide are explained in more detail in the written agreement. We
will also provide additional disclosures about our services and fees, where required by ERISA. When we
perform the agreed upon services, we will rely on the Client to provide accurate and consistent
information, and we will not be required to verify the accuracy or consistency of any information
provided by the Client. We will serve in a non-discretionary ERISA fiduciary capacity with respect to
some but not all of the services that we provide, which will be further explained in the written
agreement we sign with the Client. The Client is always free to seek independent advice about the
appropriateness of any recommendations made by us.
The agreement we sign with the Client includes the disclosures required of Advisory Representative
under Section 408(b)(2) of ERISA, in particular, (i) the services to be provided by Advisory Representative,
(ii) the extent to which Advisory Representative is acting as a fiduciary, (iii) the compensation to be
received by Advisory Representative, and the manner of receipt of that compensation, and (iv) any fees
payable on termination of the agreement. Advisory Representative receives no indirect compensation
in respect of the services provided pursuant to the agreement. We retain a portion of the compensation
described in the agreement for our services in connection with the agreement, the amount of which
varies with our arrangement with each Advisory Representative. Pursuant to the agreement, Advisory
Representative neither provides recordkeeping services nor makes available any designated
investment alternative for the plan nor advises any investment contract, fund or entity in which the
plan has a direct equity investment, and no disclosures under Section 408(b)(2) are thus required to be
provided in respect of those matters.
Assets Under Management
As of December 31, 2023, we provide continuous management services for $13,361,566,226 in Client
assets managed on a discretionary basis. We also manage $2,026,889,831 in Client assets on a non-
discretionary basis.
Fiduciary Responsibility for Retirement Accounts
When we provide investment advice to a Client, on a regular basis, regarding a retirement plan account
or individual retirement account, SPIA is a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act (ERISA) and/or the Internal Revenue Code of 1986, as applicable. The
way SPIA makes money creates some conflicts with your interests, so we operate under regulations that
require us to act in the best interest of the Client and not put SPIA’s interest ahead of the Client’s interest.
Pursuant to these regulations, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put SPIA’s financial interests ahead of the Client’s financial interests when making
recommendations (give loyal advice);
Avoid misleading statements about conflicts of interests, fees, and investments;
Follow policies and procedures designed to ensure that SPIA gives advice that is in the best interest
of the Client;
Charge no more than is reasonable for services provided; and
Give the Client basic information about conflicts of interest.