Elevated Capital Advisors, LLC (hereafter “ECA”) is an investment adviser registered with the SEC under
The Investment Adviser Act of 1940, and is a limited liability company (LLC) formed under the laws of the
State of Utah. The Firm was formed in June 2015 and became SEC Registered in August 2017. The
Principal Owners of the firm are SPL Financial, Inc. and Global Plains. Sean Lee, Managing Member,
owns SPL Financial. Scott Dougan, Managing Member, owns Global Plains.
ECA provides investment management and financial planning services to individuals, trusts, estates,
charitable organizations, foundations, endowments, corporations, qualified retirement plans, or other
businesses not listed above (collectively referred to herein as “client” or “clients”). ECA’s services include
the review of client investment objectives and goals, recommending investment products such as cash,
portfolios, stocks, mutual funds, exchange-traded-funds (“ETFs”), bonds, annuities, alternatives, and
preparing an Investment Policy Statement (“IPS”). ECA’s investment advice is tailored to meet the clients’
needs and investment objectives. clients may impose restrictions on investing in certain securities or
types of securities (such as a product type, specific companies, specific sectors, etc.) by providing a
signed and dated written notification, of which an e-mail is also an acceptable form of notification.
ECA provides investment advisory and other financial services through independent financial advisors
who have either affiliated with ECA or have an investment sub-advisory agreement with the independent
financial advisor’s registered investment advisory firm (“Financial Advisor” or “Financial Advisors”). ECA
provides discretionary and non-discretionary investment advisory services to its clients through managed
advisory accounts. ECA and the Financial Advisor will assist clients in determining the investments that
are in the best interest of the client. The Financial Advisor is compensated based on a percentage of
assets and the account may be assessed other brokerage and account transaction fees. ECA and the
Financial Advisor, as appropriate, will be responsible for the following:
• Perform due diligence in order to select the investments.
• Perform ongoing monitoring and replacement oversight of the investments.
• Provide a client risk profile assessment.
• Provide research and analytics on investment product options, as needed.
• Recommend investments that are in the best interest of the client based on:
- Risk profile assessment
- Age
- Retirement date
- Investible assets
- Financial goals
• Prepare a customized IPS for the client.
• Provide ADV Part 2A (Firm Brochure) and Form CRS.
• Obtain the investment advisory agreement from the client with the required IPS and investment
selection for each new account or change in investment.
• Perform client best interest compliance review for new accounts including account
documentation, IPS, and investment selections.
ECA’s Financial Advisors may also provide a comprehensive financial plan for clients. As part of the plan,
the Financial Advisor will advise clients on how to achieve their short-term and long-term financial goals.
This may include saving for education, planning for retirement, managing taxes, and insurance. The
following elements are addressed, and revised as necessary:
Elevated Capital Advisors, LLC Page 4 Form ADV Part 2A Disclosure Brochure
• Develop a retirement strategy for accumulating the retirement income needed.
• Develop a comprehensive risk management plan that may include a review of insurance.
• Develop a long-term investment plan that includes a customized plan based on specific
investment objectives and a personal risk tolerance profile.
• Develop a tax reduction strategy for minimizing taxes as allowed by the tax code.
• Develop an estate plan for the benefit and protection of heirs (generally prepared in conjunction
with an Estate Attorney).
As of 12/31/2023, ECA disclosed $375,281,038 in Regulatory Assets under Management (“AUM”). This
includes $369,405,720 in discretionary assets, and $5,875,317 in non-discretionary assets.
Additional information regarding ECA’s investment advisory services to wealth management and
retirement plan clients are described below.
Wealth Management
As part of the financial planning process, the Financial Advisor conducts a personal discussion with the
client and completes a risk tolerance assessment to determine the client's goals and objectives. The
Financial Advisor then determines the appropriate investment or investments that is in the best interest of
the client. Under this arrangement, the client retains individual ownership of all securities.
ECA’s investment recommendations will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Corporate debt securities (other than commercial paper)
• Options
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• Exchange Traded Funds (“ETFs”)
• Unit Investment Trusts (“UITs”)
• Collective Investment Trust (“CITs”)
• United States governmental securities
• Structured products
ECA continuously monitors the performance of managed portfolios and will make changes when such
action is deemed appropriate and in the best interest of the client. Because some types of investments
involve certain additional degrees of risk, they will only be implemented/recommended when consistent
with the client's stated investment objectives, tolerance for risk, liquidity, and best interest. To ensure that
the initial determination of an appropriate portfolio remains in the best interest of the client and that the
account continues to be managed in a manner consistent with the client's financial circumstances, the
Financial Advisor will:
Elevated Capital Advisors, LLC Page 5 Form ADV Part 2A Disclosure Brochure
1. Conduct a client review, at least annually, to determine whether there have been any changes
in the client's financial situation or investment objectives, and whether the client wishes to impose
investment restrictions or modify existing restrictions.
2. Ensure that they be available to consult with the client.
3. Maintain client suitability information and the IPS in each client's file.
Financial Advisors can choose from the following investment management services:
Managed Model Portfolios – May include various third-party money manager portfolios and/or
proprietary model portfolios selected and monitored by ECA. ECA has full oversight over the investments
and ECA executes the trades on behalf of the client based on direction from the appointed ECA advisor.
The client will enter into an ECA Investment Advisory Agreement (IAA). There are no trading or
transaction costs for individual
stocks and ETFs. client pays all transaction and trading costs for mutual
funds and any regulatory fees.
Advisor Directed Managed Accounts – This account type allows both discretionary or non-discretionary
investing. If discretion is provided to the advisor, investments selected are generally chosen by the
advisor, including timing of the investment and the amount. If the client chooses not to allow discretion,
then all investment decisions will need to be discussed and approved by the client previously and/or
provided directly from the client. If the client intends to make all or most of the investment decisions it
would be more advantageous for the client to open a client directed brokerage account with no advisory
or administration fees attached.
Sub-Advisory Services – ECA may enter into agreements with unaffiliated registered investment
advisors (hereafter referred to as “Independent RIA”) whereby ECA oversees and manages on a
discretionary basis some or all of the Independent RIA’s client assets according to the investment
strategy chosen by the client. In these situations, the client remains a client of the Independent RIA. The
decision as to what investment strategy(s) client assets are invested in is based on suitability information
gathered and reviewed by the Independent RIA. ECA manages these assets based on its investment
strategies and not based on overall client suitability. Strategies are managed on an ongoing basis. The
Independent RIA is responsible for the administrative paperwork and servicing the accounts. ECA
facilitates the billing on behalf of the Independent RIA.
Solicitor Services – ECA may enter into a Solicitor Agreement, which means that either ECA or a third-
party money manager will manage client assets obtained through a referral source (Solicitor). ECA will
compensate the Solicitor or be compensated as a solicitor according to the fee structure agreed upon
within the agreement. In cases where ECA splits management fees with a Solicitor, ECA will verify
whether or not Solicitor is required to be a licensed and registered associate in the state where they
reside.
Self-Directed Brokerage Account (“SDBA”) for Employer Sponsored Retirement Plans through
The Pacific Financial Group (“TPFG”) – This program is available to clients in connection with
retirement accounts under the Employee Retirement Investment Security Act of 1974 (“ERISA”), or under
Sections 401(a) or 408 of the Internal Revenue Code of 1986 (“Code”). For the SDBA Program, the client
will open a Self-Directed Brokerage Account (a “Self-Directed account”) as permitted by the client’s
retirement plan which permits the participant (i.e., the client) to direct the investments in the account and
in most cases, to appoint TPFG as the adviser to the account. Assets held in the Self-Directed account
are considered plan assets under ERISA, but are not supervised or reviewed by the plan fiduciaries. The
Elevated Capital Advisors, LLC Page 6 Form ADV Part 2A Disclosure Brochure
program is the same as the SDBA except the Model Portfolios (each a “Model”) are held in traditional
brokerage accounts and not part of a retirement plan.
When choosing SDBAs, clients are referred to TPFG by their financial adviser (“Adviser”) through ECA,
which has contracted with TPFG to allow the Adviser to offer TPFG’s products and services to the
Introducing Firm’s clients. The Introducing Firm is responsible for supervising the activities of its Advisers.
In this regard, TPFG and the Introducing Firm each have their respective and several obligations to the
client. Accordingly, the client is a client of both TPFG and the Introducing Firm. The Adviser serves as the
primary relationship contact with the client.
TPFG and Adviser will serve as fiduciaries to the client in accordance with the rules and regulations under
the Advisers Act, ERISA, and generally accepted fiduciary principles which permits the allocating of
fiduciary duties between fiduciaries. Accordingly, unless prohibited by law, the fiduciary obligations
assumed are several between TPFG and Adviser and are outlined in the IMA. When TPFG is providing
services to private clients (See TPFG as Adviser to private clients), the services provided to Private
clients, to include any fiduciary responsibilities, shall be viewed in light of the provisions of the Uniform
Prudent Investor Act as applicable under governing law.
ERISA Fiduciary Obligations - To the extent an Account is governed by the Employee Retirement Income
Security Act of 1974 (“ERISA”), TPFG and Financial Adviser shall be fiduciaries under Section 3(21)(A) of
ERISA only.
Financial Planning
Through the financial planning process, the Financial Advisor engages with the client to determine their
goals, objectives, priorities, vision, and legacy (both for the near term as well as for future generations).
With the unique goals and circumstances of each client in mind, the Financial Advisor will offer financial
planning ideas and strategies to address the client’s holistic financial picture, including estate, income tax,
charitable, cash flow, wealth transfer, and client legacy objectives. The Financial Advisor partners with the
client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to ensure a
coordinated effort of all parties toward the client’s stated goals. Such services include various reports on
specific goals and objectives or general investment and/or planning recommendations, guidance to
outside assets, and periodic updates.
Our specific services in preparing the financial plan may include:
• Review and clarification of the client’s financial goals.
• Assessment of client’s overall financial position including cash flow, balance sheet, investment
strategy, risk management, and estate planning.
• Creation of a unique plan for each goal, including personal, education, retirement or financial
independence, charitable giving, estate planning, and other personal goals.
• Development of a goal-oriented investment plan, with input from various advisors to the client
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable, and trust accounts that require special attention.
• Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and
transfer, including liquidity as well as various insurance and possible company benefits.
• Development and implementation of, in conjunction with the client’s estate and/or corporate
attorneys as tax adviser, an estate plan to provide for the client’s heirs in the event of an
incapacity or death.
Elevated Capital Advisors, LLC Page 7 Form ADV Part 2A Disclosure Brochure
A written evaluation of the client's initial situation and financial plan is provided to the client. The Financial
Advisor will review the financial plan with the client based on the terms of the financial planning
agreement.