A. Description of the Advisory Firm
Seros Financial, LLC is a Limited Liability Company organized in the state of Arizona.
The entity was formed in August of 2011. The principal owner is Jeremy Windell Smith.
B. Types of Advisory Services
Seros Financial, LLC (hereinafter “Seros”) offers the following services to advisory clients:
Portfolio Management Services
In providing portfolio management services to your account, your Investment Advisor
Representative (IAR) may utilize one or several programs that Seros Financial has authorized
through relationships with other financial service firms that are custodians and/or registered
investment advisors. Seros Financial has agreements with these financial service firms to
provide custodial services, brokerage services, investment management services and
reporting/billing services, which are further described as follows:
• Custodial services that involve the safekeeping of your assets in an account for your
benefit.
• Brokerage services that involve the buying and selling of investments in your account.
• Investment management services that involve the management of assets for your
benefit.
• Reporting/Billing services that involve account related reporting and fee billing for
various fees.
Portfolio Management Programs can be provided in different capacities. Below is a brief
description of the main types of programs. A more detailed description is provided further
down in this section. The brief descriptions are as follows:
• Managed Accounts: Managed accounts are accounts that are held at custodians
(sometimes referred as Third-Party Custodians). Currently, Seros utilizes the
institutional divisions of the following custodians: Charles Schwab and Axos Advisor
Services. Custodians may be pre-designated by the retirement plan sponsor or the
employer of the retirement plan. These accounts are typically referred to as Self-
Directed Accounts.
• Directly Held Managed Accounts: In limited situations, an IAR may also provide
portfolio management services to clients who have pre-existing accounts held directly
at product sponsors such as mutual fund and variable annuity companies.
• Third Party Money Manager (TPMM) Services: These arrangements involve the
utilization of a TPMM to primarily assist with investment management services.
In any of the aforementioned Portfolio Management Programs, the client will enter into an
investment advisory agreement (This term may vary and can also be referred to as the
Investment Management Services Agreement, Client Services Agreement, Investment
Advisory Agreement, etc.) with Seros Financial.
Managed Accounts
IAR’s may also open and manage accounts at one or more authorized Custodians, who are
also registered broker/dealers that act in the capacity of a custodian and are not affiliated
with Seros Financial. The Custodians provides safekeeping of your assets along with varying
levels of custodial service and support to both you and your IAR.
Selection of Other Advisors
Seros may direct clients to other investment advisors commonly referred as Third Party
Money Managers (TPMM). Seros will be compensated via a fee share from the advisors to
which it directs to those clients. This Relationship will be disclosed in each contract between
Seros and the client. The fees shares will not exceed any limit imposed by any regulatory
agency. Before selecting TPMM for clients, Seros will always ensure those TPMM are properly
licensed or registered as investment advisor.
TPMM services may be offered in different ways, but they are primarily offered in the
following manner:
• Solicitor Arrangements (aka Referral Model): These are arrangements where the IAR
refers you to a TPMM to manage your account. The IAR receives a solicitor fee from
the TPMM for referring the business.
• Strategist Arrangements (aka Sub-Advisor or Advisor Platform): These are
arrangements where the IAR may utilize one or more TPMMs to manage a client’s
account or a portion of a client’s account. In these cases, this is not a solicitor
arrangement and there is no solicitor fee. In some cases, these strategist arrangements
are facilitated as part of a platform that may also involve the use of Separately
Managed Accounts (SMAs) and/or Unified Managed Accounts (UMAs).
Financial Planning and Consulting Services
Pursuant to a Financial Planning & Consultation Services Agreement, your IAR will meet
with you to gather important financial information, outline financial goals, identify financial
problems, assess investment risk tolerance and define investment objectives based on the
specific needs, whether you are an individual or business. Areas for discussion and planning
for individuals may focus on cash flow management, taxes, children’s education funding and
goals, retirement and/or estate planning. Areas for discussion and planning for businesses
may focus on cash flow management, taxes, employee benefits, and/or succession planning.
IAR’s will gather specific financial information from you in order to provide you with a
written
financial plan or provide ongoing consulting services. Generally, such financial
planning & consulting services involve the preparation & delivery of a financial plan.
However, in other cases this service can also be to merely provide you various financial
analyses through various reports (such as asset allocation, risk assessments, retirement
income planning, securities analysis, cash flow analysis, budgeting, etc.). Or, in other cases,
the service can also be to merely provide you advice, insights and guidance to consult you on
your financial needs, circumstances and objectives in conjunction with actionable items that
you may have to execute on your own (such as managing your participant account at an
employer retirement plan (i.e., 401k or 403b). Analyses may encompass a variety of factors,
including but not limited to, current and anticipated assets and liabilities, insurance, savings,
investments and anticipated retirement or other employee benefits (such as 401k, 403b,
pensions, etc.). The advisor has the discretion to provide all of the aforementioned services,
in whole or in part, based on your specific needs & objectives. The specific financial planning
arrangement will be agreed upon by you and your IAR in accordance to a Financial Planning
& Consultation Services Agreement.
Retirement Plan Services
1. Seros has the ability to and may provide fiduciary and/or non-fiduciary services to
retirement plans (i.e., 401k, 403b, etc.). Retirement plans may or may not be subject to the U.S.
Department of Labor’s Employee Retirement Income Security Act (ERISA). Regardless of
whether the retirement plan is subject to ERISA, IAR’s are capable of providing services to a
retirement plan.
2. Retirement plan documents typically designate one or more persons, such as the plan
trustee(s), to undertake fiduciary responsibility for the operation of the retirement plan. Such
persons are known as Responsible Plan Fiduciaries (RPFs). Pursuant to a Retirement Plan
Services Agreement (RPSA), an IAR can offer the following types of services to a retirement
plan. Please refer to the agreement for a more detailed description of these different types of
services.
a. ERISA Fiduciary Services
• Selection of Investments
• Assessment of Investments
• Participant Investment Advice
• Investment Policy Statement Individually Designed
• Investment Policy Statement Review
• Performance Monitoring
b. Non-ERISA Fiduciary Services
• Third Party Service Provider Liaison
• Employee Enrollment
• Employee Education
• Vendor Review/Conversion
3. IAR is not permitted to act in the capacity of an RPF on behalf of a client’s retirement
plan.
Services Limited to Specific Types of Investments
Seros generally limits its investment advice to mutual funds, equities, bonds, fixed income,
REITs, insurance products including annuities, and government securities. Seros may use
other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you 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. Under this special rule’s provisions, we
must:
• Meet a professional standard of care when making investment recommendations
(give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
C. Client Tailored Services and Client Imposed Restrictions
Seros offers the same suite of services to all of its clients. However, specific client financial
plans and their implementation are dependent upon the client Investment Policy Statement
which outlines each client’s current situation (income, tax levels, and risk tolerance levels)
and is used to construct a client specific plan to aid in the selection of a portfolio that matches
restrictions, needs, and targets.
Clients may not impose restrictions in investing in certain securities or types of securities in
accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees, transaction costs, fund expenses, and any other administrative
fees. Seros does not participate in any wrap fee programs.
E. Amounts Under Management
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$245,643,113.00 $15,198,384.00 December 2023