A. Firm Information
Global Assets Advisory, LLC (“GAA”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”) with its principal place of business in Orlando, Florida. GAA began
conducting business in 2019 and is owned by Pecunia Management, LLC (“Pecunia”), Pecunia is owned
by IAA Investment Holdings, LLC. The majority owner of IAA Investment Holdings, LLC is RIA Holding
Company, LLC which is owned by the Richard Desich Revocable Trust FBO Jeffrey Desich and Richard
Desich.
GAA has an expense sharing agreement with International Assets Advisory, LLC (“IAA”), a registered
broker-dealer, Member FINRA/SIPC and IAA Shared Services, LLC (“ISS”), to provide various
administrative and support services, facilities, personnel, equipment, etc. As part of the expense sharing
agreement, GAA pays IAA and ISS for such services. IAA, ISS and GAA are affiliated under common
ownership by Pecunia. GAA offers services through our network of independent investment advisor
representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos
are used for marketing purposes and may appear on marketing materials or Client statements. These
business names have been adopted by GAA as d/b/a names under which we provide advisory services.
The Client should understand that the businesses are legal entities of the IAR and not of GAA. The IARs
are under the supervision of GAA, and the advisory services of the IAR are provided through GAA. GAA
provides notice of all of its d/b/a names online at the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with our name or our CRD# 300460. This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided
by GAA.
GAA and its IARs serve as a fiduciary to Clients, as defined under applicable laws and regulations. When
we provide investment advice regarding your retirement plan account or individual retirement account, we
are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the
Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make
money creates some conflicts with your interests, so we operate under a special rule that requires us to act
in your best interest and not put our interest ahead of yours. As a fiduciary, GAA and its IARs uphold a duty
of loyalty, fairness and good faith toward each Client and seek to mitigate potential conflicts of interest. Our
fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code
of Ethics, please see “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading.”
B. Advisory Services Offered
GAA generally provides investment advisory services to individuals, high net worth individuals, pensions
and profit plans, charitable organizations, corporations, and other business entities (referred to individually
as a “Client” and collectively as “clients”). These services generally fall into three categories – Investment
Management Services, Referrals to Third Party Wrap Fee Programs and Financial Planning and
Consulting.
GAA will generally recommend that Clients establish accounts at Schwab Advisor Services (“Schwab”) or
IAA. Prior to September 2023 GAA also recommended that Clients establish accounts at TD Ameritrade
Institutional, Division of TD Ameritrade, Inc. (“TD”), due to Schwab’s acquisition of TD, as of September 5,
2023 all TD accounts were transferred to Schwab. IAA clears its securities transactions through RBC
Correspondent Services, a division of RBC Capital Markets, LLC, an unaffiliated entity. Clients are
encouraged to evaluate Schwab or IAA and RBC before opening an account including the account service
Fee Schedule as account service fees may differ depending on the custodian chosen. These fees are in
addition to the investment portfolio management fee.
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Investment Management Services
GAA provides customized wealth management solutions for its Clients, through continuous personal Client
contact and interaction while providing discretionary and non-discretionary investment management and
related advisory services. GAA works with each Client to identify their investment goals and objectives as
well as risk tolerance and financial situation in order to create an investment strategy. GAA will implement
the investment strategy with its internal management and/or the use of affiliated and unaffiliated money
managers or investment platforms (as described below).
GAA’s services are provided through independent IARs. This structure means that IARs are free to
implement investment strategies and plans on their own accord. This structure is distinguished from some
other registered investment advisors that mandate the Clients invest only in company-sponsored
investment programs. GAA believes strongly in the flexibility it provides to its independent IARs. To the
extent that independent IARs employ GAA-sponsored investment programs in Client accounts, it is because
the independent IAR deems the investment program to be suitable for the Client and not because of any
requirement to do so from GAA.
GAA provides investment advisory services and portfolio management services. It does not provide
securities custodial services. At no time will GAA accept or maintain custody of a Client’s funds or securities,
except for authorized deduction of GAA’s fees or as a result of a Client’s implementation of a standing letter
of authorization. All Client assets will be managed within their designated account(s) at the Custodian,
pursuant to the GAA investment advisory agreement. Please see Item 12 – Brokerage Practices.
It is important to note that none of the advisory services described herein are intended as, or meant to be
a substitute for, legal, accounting, actuarial, or tax advice. Clients should coordinate and discuss the impact
of the financial advice they receive from the IAR with their attorney, accountant, and other professionals.
Neither GAA nor its IARs (unless they have the appropriate independent qualifications) are qualified to
provide legal or accounting advice, and do not claim to tender such advice.
Below is a description of the various investment management services provided by GAA.
Internal Investment Management
GAA customizes its investment management services for its Clients. Portfolios are primarily constructed
using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The
IARs may also utilize other types of investments, as appropriate, to meet the needs of each particular Client.
GAA generally employs a long-term investment approach for Clients, but may buy, sell or re-allocate
positions that have been held less than one year to meet the objectives of the Client or due to market
conditions. IARs construct, implement and monitor each Client’s 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 GAA and IAR.
The specific advisory program selected by the Client will cost the Client more or less than purchasing
program services separately. Factors that bear upon the cost of a particular advisory program in relation to
the cost of the same services purchased separately include, but may not be limited to, the type and size of
the account, the historical or expected size or number of trades for the account, the types of securities and
strategies involved, and the number and range of supplementary advisory and Client-related services
provided to the account.
GAA and/or its IARs may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. GAA and/or IARs may recommend specific positions to increase sector or asset class weightings.
IARs may recommend employing cash positions as a possible hedge against market movement. IARs 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
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overweighting of the position(s) in the portfolio, change in risk tolerance of Client, generating cash to meet
Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Promoter Based Third Party Asset Manager Programs
For appropriate Clients, the IAR may recommend that all or a portion of a Client’s portfolio be implemented
by utilizing one or more affiliated or unaffiliated money managers or investment platforms (“TPAMs”). The
Client will be required to enter into one or more separate agreements with the TPAM(s) that provide for
discretionary management by the TPAM(s) of the investment platform.
GAA may act as a compensated promoter (“Promoter”) (formerly known as “solicitor”) capacity when
making TPAM programs available to clients. When GAA acts as a Promoter, GAA serves as both a
Promoter of accounts to the TPAM and as the Client’s primary advisor and relationship manager and will
oversee the account to ensure the TPAM is managing consistent with the selected investment strategy or
strategies. However, the TPAM will assume discretionary authority for the day-to-day investment
management of those assets placed in their control. The IAR will assist and advise the Client in establishing
investment objectives for their account, the selection of the TPAM, and defining any restrictions on the
account.
TPAM services generally begin with the IAR obtaining the necessary financial data from the Client to assist
with setting an appropriate investment objective, determining the suitability of the program and in opening
an account with the TPAM. Depending on the program, the IAR may also assist the Client with selecting a
model portfolio of securities designed and managed by either the TPAM or a selected portfolio management
firm available through the TPAM responsible for providing discretionary asset management services. The
TPAM or other third-party investment advisor is granted authority in its Client agreement to purchase and
sell securities on a discretionary basis pursuant to the investment objective chosen
by the Client. In doing
so, the TPAM or other third-party investment advisor typically constructs various model investment
portfolios that are managed according to specific investment strategies associated with the respective
models, and that are not generally customized for individual Clients (subject to the Client’s ability to request
reasonable investment restrictions on investing in securities or other special accommodations that may be
made). In addition to portfolio management services, the TPAM sponsor will also generally arrange for
custody of Client assets, trade execution, cashiering services, and such other services as outlined in the
TPAM’s separate Client agreement and Disclosure Brochure.
GAA and your IAR are compensated for referring you to the TPAM. This compensation generally takes the
form of the TPAM sharing with IAIM and your IAR a percentage of the advisory fee that you pay to the
TPAM. When we act as Promoter for a TPAM, and prior to entering into an agreement with a TPAM you
will receive a Promoter disclosure statement (“Disclosure Statement”) describing the nature of our
relationship with the TPAM and the terms of our compensation arrangement with the TPAM, including a
description of the compensation that we will receive for referring you to the TPAM Program
GAA does not receive any compensation from these TPAMs or Investment Platforms, other than GAA’s
investment advisory fee (described in “Item 5 – Fees and Compensation”)
The following paragraph contains important conflicts of interest to consider. Assets managed by a TPAM
are not considered assets under management of GAA. Many investment advisory firms are measured, in
part, by the amount of assets under management as reported in this Disclosure Brochure. The fact that
GAA cannot count assets advised in a TPAM program as its assets under management creates a conflict
of interest inasmuch as it acts as a barrier to recommending TPAM programs. The effect of this conflict is
mitigated by the independence of GAA’s IARs, who are not required to have Client account
recommendations approved by GAA.
Sub-Adviser Based Third Party Asset Management Programs
GAA can enter into sub-advisory relationships in which it contracts with a TPAM to provide investment
management services to a Client account. GAA and the sub-adviser are jointly responsible for the ongoing
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management of the account. Your IAR is responsible for assisting you with completing the investor profile
questionnaire or any account opening documentation. While each TPAM may have a different name for
their questionnaire, your responses will assist your IAR with understanding your investment objectives,
financial situation, risk tolerance, investment time horizon and other personal information. Based on the
answers that you provide to your IAR, he/she will assist you in determining which TPAM model or portfolio
strategy is appropriate for you. As part of establishing a new account, you will receive both our Disclosure
Brochure as well as the TPAM’s Disclosure Brochure.
Since each TPAM is uniquely structured with different investment products, please ensure that you carefully
review all documents provided to you on behalf of the TPAM. These documents include, but are not limited
to:
The TPAM’s Form ADV Part 2A or Disclosure Brochure for specific program descriptions.
The TPAM’s Client Agreement as well as any other agreement entered into regarding a TPAM
Program, for specific contractual terms (including fees, billing methods, administrative and other
fees, etc.).
Any additional disclosure or offering documents provided by the TPAM in connection with
investment products.
The following paragraph contains important conflicts of interest to consider. Assets managed in a sub-
advised account program are counted as assets under management of GAA and the sub-adviser. Many
investment advisory firms are measured, in part, by the amount assets under management as reported in
this Disclosure Brochure. In a sub-advised investment program, both the sub-adviser and GAA are
responsible for the management of the invested assets, though in practice, investment management is
vested almost entirely in the sub-adviser. This structure increases GAA’s risk of Client complaints stemming
from account management by the sub-adviser and prompts GAA to engage in time consuming and costly
oversight of sub-advisory relationships.
GAA’s Relationships with Other Investment Advisers
GAA may serve as a Promoters for or recommend clients to third-party investment advisers. GAA is
compensated for referring your advisory business to these third-party investment advisers. This
compensation generally takes the form of the third-party investment adviser sharing with GAA a portion of
the advisory fee the third-party investment adviser charges you for providing investment management
services. GAA performs reasonable due diligence on these third-party investment advisers on an initial and
ongoing basis. Clients who are referred to these third-party investment advisers will receive a Disclosure
Statement that describes, among other things, the compensation that will be paid to GAA and the IAR by
the third-party investment adviser.
The following paragraph contains important conflicts of interest to consider. GAA has a conflict of interest
to refer clients to those third-party investment advisers who pay referral fees to GAA rather than those who
do not. Additionally, GAA has a conflict of interest to refer clients to those third-party investment advisers
who pay higher referral fees over those who pay lower referral fees.
Referrals to Wrap Fee Programs
IARs may also use one or more third party Wrap Fee programs sponsored by unaffiliated third-party broker
dealers/investment advisors. Please see the Part 2A, Brochure Supplement that you are provided for each
of these programs (the Wrap Fee Disclosure Brochure). This Wrap Fee Disclosure Brochure identifies all
relevant fees, expenses, and other charges (and how the program works) to you.
Financial Planning and Consulting Services
GAA provides a variety of financial planning and consulting services to individuals and families, pursuant
to a written financial planning and consulting agreement. Services are offered in several areas of a Client’s
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financial situation, depending on their goals, objectives and financial situation. Financial planning is a
separate service from GAA’s investment management services. Clients have full discretion as to how they
choose to implement the recommendations discussed in the financial plan.
Financial planning and consulting services 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. GAA may also refer Clients to an accountant, attorney or other
specialist as appropriate for their unique situation. For certain financial planning engagements, the IAR 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. Plans or consultations
are typically completed within six months of contract date, assuming all information and documents
requested are provided promptly. An additional agreement will be required if the Client chooses to utilize
the representative for further investment management services.
The following paragraph contains important conflicts of interest to consider. Financial planning
recommendations may pose a conflict between the interests of the IAR and the interests of the Client. For
example, a recommendation to engage the IAR for investment management services or to increase the
level of investment assets with the IAR would pose a conflict, as it would increase the advisory fees paid to
the IAR. The effect of this conflict is mitigated by the independence of the Clients. Clients are not required
to use GAA or any of its IARs for investment services incorporated into a financial plan or consulting
engagement.
Retirement Plan Advisory Services
GAA provides plan advisory services to company retirement plans (each a “Plan”) and the sponsor of the
Plan (herein the “Plan Sponsor”). Services are tailored to the size and complexity of the Plan and the needs
of the Plan Sponsor and/or the participants in the Plan, pursuant to the terms of the retirement plan advisory
agreement. GAA may provide retirement plan advisory services on behalf of the Plan and Plan Sponsor as
defined under ERISA 3(21). IARs do not act as investment managers and are not considered to be a Section
3(38) fiduciary.
Client Role and Obligations Relative to GAA’s Advisory Services
GAA relies on forthright communication from its Clients in order to provide them with investment services.
It is imperative that Clients be direct, honest and fulsome with their investment criteria, investment
knowledge, holdings, goals, time horizon and other important factors. Clients are obliged to report changes
in their financial situation including the factors enumerated above, as soon as possible.
C. Tailored Relationships
GAA, makes available through its IARs, advisory services to meet most individual Client needs and
objectives. The IAR’s role is to meet with Clients and determine which option(s) are most suitable in
assisting the Clients with meeting their investment needs. Certain programs available through GAA may
be utilized by multiple Clients that have similar time horizons, needs and objectives. GAA offers Clients the
ability to place restrictions on their advisory account(s). In general, the restrictions may include security
type, specific securities, and cash balance requirement. Under certain situations, a restriction may prevent
GAA from providing investment choices to meet a Client’s needs. In the event a restriction does impair
GAA’s ability to manage a portfolio effectively, the Client engagement may be terminated under the terms
of the contract.
D. Assets Under Management
As of December 31, 2023, GAA’s total assets under management were $303,128,795, of which
$303,128,795 are managed on a discretionary basis. Clients may request more current information at any
time by contacting their IAR.
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