Item 5 Additional Compensation.............................................................................................................. 24
Item 6 Supervision .......................................................................................................................................... 24
Firm Description
STRIDE Investments, LLC formerly known as At World Investments, LLC was founded in
2013. Samuel A. McElroy, Tad Cook, and Patricia McElroy are owners of the firm.
STRIDE Investments offers
personalized investment management to all clients. Each client’s
situation will determine the investment recommendation and may vary from client to client.
STRIDE Investments is a fee based investment management firm. STRIDE Investments does
not act as a custodian of client assets.
The investment advisory services of STRIDE Investments are provided to you through an
appropriately licensed and qualified individual who is an investment adviser representative
of STRIDE Investments (referred to as your investment adviser representative throughout
this brochure). An evaluation of each client's initial situation is provided to the client, often
in the form of a proprietary report referred to as a Retirement Income Summary, which may
include a net worth statement, cash flow assessment, risk analysis or similar document.
Periodic reviews are also communicated to provide reminders of the specific courses of
action that need to be taken. More frequent reviews occur but are not necessarily
communicated to the client unless immediate changes are recommended.
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are
engaged directly by the client on an as-needed basis and may charge fees of their own. For
example, tax preparation and to the extent your estate plan needs to be updated, the tax
preparer and/or attorney will bill the client separately. For the majority of these situations,
the third-party professional will bill the client directly and the client will be responsible for
paying fees to the third-party. However, in some instances STRIDE Financial or STRIDE
Investments will act as a liaison between other professionals and the client to assist in the
collection and remittance of fees to other professionals.
We primarily market our collective services under the brand-name of “STRIDE Financial”.
STRIDE Investments is affiliated with and under common ownership with STRIDE Financial
LLC. Therefore, clients of STRIDE Investments can also be and commonly are clients of
STRIDE Financial LLC.
STRIDE Financial provides a suite of financial planning, consulting and insurance services.
All such services are non-investment related because all “investment advisory services” (i.e.,
investment recommendations, investment analysis and consulting related to investments
and securities) are provided through STRIDE Investments. Services provided by STRIDE
Financial include, but are not limited to, the following:
• Retirement Planning
• Financial Planning (non-investment related)
• Social Security Maximization
• Estate Planning
• Tax Planning
• College Planning
• Business Planning
• Life Insurance
• Annuities
• Health Insurance
• Property and Casualty Insurance
• Long-Term Care Insurance
• Disability Insurance
The preceding services provided by STRIDE Financial are offered on a fixed-fee basis unless
STRIDE Financial decides to waive its fee and provide services on a complimentary basis. To
the extent that you personally engage STRIDE Financial, you will be responsible for the
payment of the fees for their services. Fees for the services of STRIDE Financial will be in
addition to and separate from the fees charged by STRIDE Investments. In no event will any
fees for services through STRIDE Financial be owed without your express approval.
As a client of STRIDE Investments, your investment adviser representative or a different
investment adviser representative can also serve as an insurance agent under STRIDE
Financial, which is an insurance agency. This means your investment adviser representative,
acting as an insurance agent, will recommend you place your assets in insurance products
and annuities when he or she believes it is in your best interest to do so.
Insurance products and annuities pay commissions to STRIDE Financial and to the owners
and investment adviser representatives of STRIDE Investments in their separate capacity as
insurance agents. This presents a conflict of interest to your investment adviser
representative as he or she will be more inclined to recommend you place your assets in
either insurance products or an advisory account depending on which would pay us more.
STRIDE Investments has taken steps to manage this conflict of interest by requiring that
each investment adviser representative (i) only recommend insurance and annuities when
in the best interest of the client and without regard to the financial interest of STRIDE
Investments, its owners and its investment adviser representative or STRIDE Financial and
its insurance agents, and (ii) not recommend insurance and/or annuities which result in
your investment adviser representative acting as an insurance agent and/or STRIDE
Investments or STRIDE Financial receiving unreasonable compensation related to the
recommendation and (iii) disclosing in writing to a client any material conflicts of interest
related to insurance recommendations.
Types of Advisory Services
ASSET MANAGEMENT
STRIDE Investments offers asset management services, which involves STRIDE Investments
providing you with continuous and ongoing supervision over your specified accounts.
You must appoint our firm as your investment adviser of record on specified accounts
(collectively, the “Account”). The Account consists only of separate account(s) held by
qualified custodian(s) under your name. The qualified custodians maintain physical custody
of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to
withdraw securities or cash, exercise or delegate proxy voting and receive transaction
confirmations) of the Account. Refer to Item 12 – Brokerage Practices for more information.
The Account is managed by us based on your financial situation, investment objectives and
risk tolerance. We actively monitor the Account and implement advice by buying, selling,
reinvesting or holding securities, cash or other investments of the Account.
We will need to obtain certain information from you to determine your financial situation
and investment objectives. In the process of obtaining the information from you, we provide
ancillary financial planning and consultative services including asset allocation, risk
management and income planning. Such financial planning and consultative services are
intended to better understand your financial situation and design an investment portfolio
consistent with your long-term needs and goals.
You will be responsible for notifying us of any updates regarding your financial situation,
risk tolerance or investment objective and whether you wish to impose or modify existing
investment restrictions; however we will contact you at least annually to discuss any
changes or updates regarding your financial situation, risk tolerance or investment
objectives. We are always reasonably available to consult with you relative to the status of
your Account. You have the ability to impose reasonable restrictions on the management of
your accounts, including the ability to instruct us not to purchase certain securities.
It is important that you understand that we manage investments for other clients and may
give them advice or take actions for them or for our personal accounts that is different from
the advice we provide to you or actions taken for you. We are not obligated to buy, sell or
recommend to you any security or other investment that we may buy, sell or recommend for
any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts that we
manage. We strive to allocate investment opportunities believed to be appropriate for your
account(s) and other accounts advised by our firm among such accounts equitably and
consistent with the best interests of all accounts involved. However, there can be no
assurance that a particular investment opportunity that comes to our attention will be
allocated in any particular manner. If we obtain material, non-public information about a
security or its issuer that we may not lawfully use or disclose, we have absolutely no
obligation to disclose the information to any client or use it for any client’s benefit.
STRIDE Investments offers discretionary and non-discretionary direct asset management
services. Investment strategies, investment selection, asset allocation, portfolio monitoring
and the overall investment program will be based on the above factors.
Discretionary
When the client provides STRIDE Investments discretionary authority the client will sign a
limited trading authorization or equivalent. STRIDE Investments will have the authority to
execute transactions in the account without seeking client approval on each transaction.
Clients can grant STRIDE Investments discretionary authority to select one or more
unaffiliated third-party investment adviser firms to serve as sub-advisors. This will allow
STRIDE Investments, when deemed appropriate for the client, to hire sub-advisors to
manage all or a portion of the assets in the client account. STRIDE Investments has full
discretion to hire and fire sub-advisors as they deem suitable. Sub-advisors will maintain
the models or investment strategies agreed upon between sub-advisor and STRIDE
Investments. Sub-advisors execute all trades on behalf of STRIDE Investments in client
accounts. STRIDE Investments will be responsible for the overall direct relationship with
the client. STRIDE Investments retains the authority to terminate the sub-advisor
relationship at STRIDE Investments’s discretion.
Non-discretionary
When the client elects to use STRIDE Investments on a non-discretionary basis, STRIDE
Investments will determine the securities to be bought or sold and the amount of the
securities to be bought or sold. However, STRIDE Investments will obtain prior client
approval on each and every transaction before executing any transactions.
ERISA PLAN SERVICES
STRIDE Investments provides service to qualified and non-qualified retirement plans
including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans,
and deferred compensation plans.
Limited Scope ERISA 3(21) Fiduciary. STRIDE Investments typically acts as a limited scope
ERISA 3(21) fiduciary that can advise, help and assist plan sponsors with their investment
decisions on a non-discretionary basis. As an investment advisor STRIDE Investments has a
fiduciary duty to act in the best interest of the client. The plan sponsor is still ultimately
responsible for the decisions made in their plan, though using STRIDE Investments can help
the plan sponsor delegate liability by following a diligent process.
1. Fiduciary Services are:
Provide non-discretionary investment advice to the Client about asset classes and
investment alternatives available for the Plan in accordance with the Plan’s
investment policies and objectives. Client will make the final decision regarding the
initial selection, retention, removal and addition of investment options.
Assist the Client in the development of an investment policy statement (“IPS”). The
IPS establishes the investment policies and objectives for the Plan. Client shall have
the ultimate responsibility and authority to establish such policies and objectives
and to adopt and amend the IPS.
Provide non-discretionary investment advice to the Plan Sponsor with respect to
the selection of a qualified default investment alternative for participants who are
automatically enrolled in the Plan or who have otherwise failed to make investment
elections. The Client retains the sole responsibility to provide all notices to the Plan
participants required under ERISA Section 404(c) (5) and 404(a)-5.
Meet with Client on a periodic basis to discuss the reports and the investment
recommendations.
Assist in monitoring investment options by preparing periodic investment reports
that document investment performance, consistency of fund management and
conformance to the guidelines set forth in the IPS and make recommendations to
maintain, remove or replace investment options.
2. Non-fiduciary Services are:
Assist in the education of Plan participants about general investment information
and the investment alternatives available to them under the Plan. Client
understands the Advisor’s assistance in education of the Plan participants shall be
consistent with and within the scope of the Department of Labor’s definition of
investment education (Department of Labor Interpretive Bulletin 96-1). As such,
the Advisor is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the
Plan participants. STRIDE Investments will not provide investment advice
concerning the prudence of any investment option or combination of investment
options for a particular participant or beneficiary under the Plan.
Assist in the group enrollment meetings designed to increase retirement plan
participation among the employees and investment and financial understanding by
the employees.
STRIDE Investments may provide these services or, alternatively, may arrange for the Plan’s
other providers to offer these services, as agreed upon between Advisor and Client.
Specific services will be outlined in detail to each plan in the 408(b)2 disclosure.
Retirement Plan Rollover Recommendations
When STRIDE Investments provides investment advice about your retirement plan account or
individual retirement account (“IRA”) including whether to maintain investments and/or
proceeds in the retirement plan account, roll over such investment/proceeds from the
retirement plan account to a IRA or make a distribution from the retirement plan account, we
acknowledge that STRIDE Investments 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. The way STRIDE Investments
makes money creates conflicts with your interests so STRIDE Investments operates under a
special rule that requires STRIDE Investments to act in your best interest and not put our
interest ahead of you.
Under this special rule’s provisions, STRIDE Investments must as a fiduciary to a retirement
plan account or IRA under ERISA/IRC:
• Meet a professional standard of care when making investment
recommendations (give prudent advice);
• Never put the financial interests of STRIDE Investments ahead of you when
making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that STRIDE Investments
gives advice that is in your best interest;
• Charge no more than is reasonable for the services of STRIDE Investments; and
• Give Client basic information about conflicts of interest.
To the extent we recommend you roll over your account from a current retirement plan account
to an individual retirement account managed by STRIDE Investments, please know that STRIDE
Investments and our investment adviser representatives have a conflict of interest.
We can earn increased investment advisory fees by recommending that you roll over your
account at the retirement plan to an IRA managed by STRIDE Investments. We will earn fewer
investment advisory fees if you do not roll over the funds in the retirement plan to an IRA
managed by STRIDE Investments.
Thus, our investment adviser representatives have an economic incentive to recommend a
rollover of funds from a retirement plan to an IRA which is a conflict of interest because our
recommendation that you open an IRA account to be managed by our firm can be based on our
economic incentive and not based exclusively on whether or not moving the IRA to our
management program is in your overall best interest.
We have taken steps to manage this conflict of interest. we have adopted an impartial conduct
standard whereby our investment adviser representatives will (i) provide investment advice to
a retirement plan participant regarding a rollover of funds from the retirement plan in
accordance with the fiduciary status described below, (ii) not recommend investments which
result in STRIDE Investments receiving unreasonable compensation related to the rollover of
funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by
STRIDE Investments and our supervised persons and any material conflicts of interest related
to recommending the rollover of funds from the retirement plan to an IRA and refrain from
making any materially misleading statements regarding such rollover.
When providing advice to a retirement plan account or IRA, our investment advisor
representatives will act with the care, skill, prudence, and diligence under the circumstances
then prevailing that a prudent person acting in a like capacity and familiar with such matters
would use in the conduct of an enterprise of a like character and with like aims, based on the
investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without
regard to the financial or other interests of STRIDE Investments or our affiliated personnel.
Client Tailored Services and Client Imposed Restrictions
The goals and objectives for each client are documented in our client files. Investment
strategies are created that reflect the stated goals and objectives.
STRIDE Investments’s advisory services are always provided based on your individual
needs. This means, for example, that when we provide asset management services, you are
given the ability to impose restrictions on the accounts we manage for you, including specific
investment selections and sectors. We work with you on a one-on-one basis through
interviews and questionnaires to determine your investment objectives and suitability
information.
We will not enter into an investment adviser relationship with a prospective client whose
investment objectives may be considered incompatible with our investment philosophy or
strategies or where the prospective client seeks to impose unduly restrictive investment
guidelines.
Wrap Fee Programs
A wrap-fee program is defined as any advisory program under which a specified fee or fees
not based directly upon transactions in a client’s account is charged for investment advisory
services (which include portfolio management and/or advice concerning the selection of
other investment advisers) and the execution of client transactions. We do not offer or
participate in wrap-fee programs. All of our services are provided on a non-wrap fee basis
which means fees and expenses for execution of client transactions charged by your
broker/dealer and/or custodian are billed directly to your account separately from our
advisory fees.
Client Assets under Management
As of December 31, 2023, STRIDE Investments had approximately $98,762,000 in assets
under management on a discretionary basis and $43,471,000 in assets under management
on a non-discretionary basis for a total of $173,831,969.