A. Firm Information
Sharp Wealth Advisory, LLC d/b/a Sharp Financial (“Sharp Financial” or the “Advisor”) is a registered investment
advisor with the U.S. Securities and Exchange Commission (“SEC”). Sharp Financial is organized as a Limited
Liability Company (“LLC”) under the laws of the Commonwealth of Pennsylvania. Sharp Financial was founded in
December 2008, and is wholly owned by Sharp Financial Group, LLC, which is owned and operated by Michael
H. Sharp (Founder). This Disclosure Brochure provides information regarding the qualifications, business
practices, and the advisory services provided by Sharp Financial.
B. Advisory Services Offered
Sharp Financial offers investment advisory services to individuals, high net worth individuals, trusts, estates,
retirement plans and family office (each referred to as a “Client”).
The Advisor acts as a fiduciary to Clients, as defined under the applicable laws and regulations. As such, each
recommendation made as part of the advisory services are based on the belief that the recommendation is in the
Client's best interest. Sharp Financials’ fiduciary commitment to each Client is further described in the Advisor’s
Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics,
Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
Sharp Financial may provide Clients with wealth management services, which generally includes a broad range
of comprehensive financial planning and consulting services in connection with discretionary management of
investment portfolios. These services are described below.
Investment Management Services - Sharp Financial provides customized investment advisory solutions for its
Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary
investment management and related advisory services. Sharp Financial works closely with each Client to identify
their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio
strategy. Sharp Financial adopts a tactical approach to investment management. The Advisor develops
proprietary risk-based investment strategies built on internal research and quantitative analysis provided by a
third party subscription. Sharp Financial receives daily market data, market trend indicators and asset
class/sector rankings based on technical components including but not limited to supply and demand, moving
average, relative strength and momentum-based approaches. The Advisor utilizes a strategy based off
diversification and risk mitigation. Each strategy has pre-determined rebalance frequencies as well as the
potential to reallocate upon a change in market indicators. The strategies consist of mutual funds, exchange-
traded funds (“ETFs”) with exposure to traditional asset classes, equity sectors, bond sectors, commodities, and
individual stocks. The underlying asset allocation weightings for each strategy are dynamic and can shift
significantly as changes in market indicators occur. The Advisor may retain certain legacy investments based on
portfolio fit and/or tax considerations.
Sharp Financial’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Sharp Financial will construct, implement and monitor the portfolio to ensure it meets the goals,
objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to
place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to
acceptance by the Advisor.
Sharp Financial evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Sharp Financial may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Sharp Financial may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market
movement. Sharp Financial may recommend selling positions for reasons that include, but are not limited to,
harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities,
overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating
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cash to meet Client needs, due to market conditions, or any risk deemed unacceptable for the Client’s risk
tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No Client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
At no time will Sharp Financial accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at
the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12 – Brokerage Practices
Use of Independent Managers - Sharp Financial may recommend that a Client utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a
Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an
advisory agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] will provide investment management and related services. The Advisor may also assist in the
development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will
perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the
Independent Managers’ strategies and target
allocations remain aligned with its clients’ investment objectives
and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s]
or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that
makes the appropriate disclosures).
Sub-Advisory Services - Sharp Financial may provide its advisory services to other registered investment
advisors (“Independent Advisors”) and their Clients, including fee reporting and debiting, transaction data
processing, and proposed model strategies. As part of its sub-advisory services, Sharp Financial offers periodic
portfolio rebalancing when instructed by the Independent Advisor, which is designed to keep portfolios consistent
with the Client’s desired asset allocation target amounts based off the Client’s risk profile. Sharp Financial will
also provide a mechanism for collection of investment advisory fees from Clients on behalf of Independent
Advisors. Upon request of the Independent Advisor, Sharp Financial will provide reports regarding the model
strategies to the Independent Advisor and may also be available to meet with the Independent Advisor’s Clients
on a periodic basis.
Financial Planning Services
Sharp Financial will typically provide a variety of financial planning and consulting services to Clients as a part of
its wealth management services. However, Sharp Financial may also be engaged for financial planning services
on a standalone basis pursuant to a written financial planning agreement. Services are tailored to the Client,
depending on their goals and objectives. Generally, such financial planning services involve preparing a formal
financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives.
This planning or consulting may encompass one or more areas of need, including but not limited to, investment
planning, retirement planning, personal savings, education savings, tax planning, insurance needs, estate
planning and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
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Sharp Financial may also refer Clients to an accountant, attorney or other specialists, as appropriate for their
unique situation. For certain financial planning engagements, the Advisor will provide a written summary of
Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the
Advisor may not provide a written summary.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients increase the level of
investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients
are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship
with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is
under no obligation to implement the transaction through the Advisor.
Retirement Plan Advisory Services
Sharp Financial provides retirement plan advisory services to retirement plans (each a “Plan”) and the company
(the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in
meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the
needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Performance Reporting
• Ongoing Investment Recommendation and Assistance (ERISA 3(21) Services)
These services are provided by Sharp Financial serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of Sharp Financial’s fiduciary status, the specific services
to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Sharp Financial to provide investment advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client. These services may include:
• Establishing an Investment Strategy – Sharp Financial, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Sharp Financial will develop a tactical asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Sharp Financial will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
• Investment Management and Supervision – Sharp Financial will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Sharp Financial typically includes, in addition to securities transaction fees for certain mutual funds and custodial
costs (herein “Covered Costs”) together with its investment advisory fees. Including these fees into a single
asset-based fee is considered a “Wrap Fee Program Brochure”. The Advisor customizes its wealth management
services for its Clients and certain Clients may not participate in the Wrap Fee Program Brochure. The Advisor
sponsors the Sharp Financial Wrap Fee Program Brochure solely as a supplemental disclosure regarding the
combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the
Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 –
Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure.
www.sharpllc.com/wealth
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E. Assets Under Management
As of December 31, 2023, Sharp Financial manages $304,724,354 in Client assets, $170,102,549 of which are
managed on a discretionary basis and $134,621,805 on a non-discretionary basis. Clients may request more
current information at any time by contacting the Advisor.