Our Advisory Business
Anderson Financial Strategies is a registered investment adviser with the SEC, providing investment
advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations,
foundations, endowments, corporations, small businesses, churches, and retirement plans. The Advisory
Firm was founded in 2017 by Shon Anderson, who serves as Chief Compliance Officer and Managing
Member.
Services
Anderson Financial Strategies offers investment advice regarding securities, insurance, and other financial
services to clients. We are a registered investment adviser with the SEC.
We provide various asset management and financial planning and/or consulting services, with an
emphasis on building portfolios designed to meet the needs of our clients. Our focus is on helping you
develop and execute plans that are designed to build and preserve your wealth. We are available during
normal business hours either by telephone, fax, email, or in person by appointment to answer your
questions.
Active Asset Management
Tailored Asset Management Services
As part of the active asset management process we will meet with you to discuss your financial
circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you
to provide statements summarizing current investments, income and other earnings, recent tax returns,
retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other
pertinent information.
Based on the information you share with us, we will analyze your situation and tailor a portfolio with
appropriate asset allocations and investment strategy[ies]. Our recommendations and ongoing
management are based upon your investment goals, objectives and risk tolerance. We will monitor the
account, trade as necessary, and communicate regularly with you.
We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your
portfolio to keep it in line with your goals as necessary. We will be reasonably available to help you with
questions about your account.
* Please note that pursuant to the investment advisory agreement you are obligated to notify us promptly
when your financial situation, goals, objectives, or needs change. *
Under certain conditions, securities from outside accounts may be transferred into your advisory account;
however, we may recommend that you sell any security if we believe that it is not suitable for the current
recommended investment strategy. Additionally, trading may be required to meet initial allocation
targets, after substantial cash deposits that require investment allocation, and/or after a request for a
withdrawal that requires liquidation of a position.
Anderson Financial Strategies ADV Part 2A March 2024 Page 5 of 42
Periodically, your account may need to be rebalanced or reallocated in order to reestablish the targeted
percentages of your initial asset allocation. This rebalancing or reallocation will occur as required or
pursuant to the schedule we have determined together.
You will be responsible for all tax consequences resulting from the sale of any security, rebalancing or
reallocation of the account. You are responsible for any taxable events in these instances. We are not tax
professionals and do not give tax advice. However, we will work with your tax professionals to assist you
with tax planning.
You will be notified of any purchases or sales through trade confirmations and statements that are
provided by the custodian. These statements list the total value of the account, itemize all transaction
activity, and list the types, amounts, and total value of securities held. You will at all times maintain full
and complete ownership rights to all assets held in your account, including the right to withdraw securities
or cash, proxy voting and receiving transaction confirmations.
We may also provide you with annual performance statements. These statements give you additional
feedback regarding performance, educate you about our long-term investment philosophy, and describe
any changes in current strategy and allocation along with the reasons for making these changes.
Model Portfolios
AFS CIO Portfolios:
AFS CIO Conservative Portfolio
Model Objective: The AFS CIO Conservative Portfolio pursues a balance of income and growth to provide
a globally diversified balanced portfolio appropriate for investors drawing income in retirement or that
wish to invest in a low-risk portfolio.
Model Strategy: The AFS CIO Conservative Portfolio invests in a broadly diversified mix of 16 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with a conservative portfolio.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted my market, economic, regulator, or political
events.
AFS CIO Moderately Conservative Portfolio
Model Objective: The AFS CIO Moderately Conservative Portfolio pursues a balance of income and growth
to provide a globally diversified balanced portfolio appropriate for investors within 5 years of retirement
or that wish to invest in a low to medium risk portfolio.
Model Strategy: The AFS CIO Moderately Conservative invests in a broadly diversified mix of 16 asset
classes consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The
portfolio uses a modified mean-variance framework with the goal of achieving an optimized risk/return
asset allocation corresponding with a moderately conservative portfolio.
Anderson Financial Strategies ADV Part 2A March 2024 Page 6 of 42
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Moderate Portfolio
Model Objective: The AFS CIO Moderate Portfolio pursues a balance of growth and income to provide a
globally diversified balanced portfolio appropriate for investors within 5-10 years of retirement or that
wish to invest in a medium risk portfolio.
Model Strategy: The AFS CIO Moderate Portfolio invests in a broadly diversified mix of 16 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with a moderate portfolio.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Moderately Aggressive Portfolio
Model Objective: The AFS CIO Moderately Aggressive Portfolio pursues a balance of growth and income
to provide a globally diversified balanced portfolio appropriate for investors within 10-15 years of
retirement or that wish to invest in a medium to higher risk portfolio.
Model Strategy: The AFS CIO Moderately Aggressive Portfolio invests in a broadly diversified mix of 16
asset classes consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The
portfolio uses a modified mean-variance framework with the goal of achieving an optimized risk/return
asset allocation corresponding with a moderately aggressive portfolio.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Aggressive Portfolio
Model Objective: The AFS CIO Aggressive Portfolio pursues a balance of growth and income to provide a
globally diversified balanced portfolio appropriate for investors with greater than 15 years until
retirement or that wish to invest in a higher risk portfolio.
Model Strategy: The AFS CIO Aggressive Portfolio invests in a broadly diversified mix of 16 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with an aggressive portfolio.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
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Tax Aware Model Portfolios
AFS CIO Conservative Portfolio - Tax Aware
Model Objective: The AFS CIO Conservative Portfolio pursues a balance of income and growth to provide
a globally diversified balanced portfolio appropriate for investors drawing income in retirement or that
wish to invest in a low-risk portfolio.
Model Strategy: The AFS CIO Conservative Portfolio invests in a broadly diversified mix of 17 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with a conservative portfolio while considering the tax impact.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Moderately Conservative Portfolio - Tax Aware
Model Objective: The AFS CIO Moderately Conservative Portfolio pursues a balance of income and growth
to provide a globally diversified balanced portfolio appropriate for investors within 5 years of retirement
or that wish to invest in a low to medium risk portfolio.
Model Strategy: The AFS CIO Moderately Conservative invests in a broadly diversified mix of 17 asset
classes consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The
portfolio uses a modified mean-variance framework with the goal of achieving an optimized risk/return
asset allocation corresponding with a moderately conservative portfolio while considering the tax impact.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Moderate Portfolio - Tax Aware
Model Objective: The AFS CIO Moderate Portfolio pursues a balance of growth and income to provide a
globally diversified balanced portfolio appropriate for investors within 5-10 years of retirement or that
wish to invest in a medium risk portfolio.
Model Strategy: The AFS CIO Moderate Portfolio invests in a broadly diversified mix of 17 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with a moderate portfolio while considering the tax impact.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
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AFS CIO Moderately Aggressive Portfolio - Tax Aware
Model Objective: The AFS CIO Moderately Aggressive Portfolio pursues a balance of growth and income
to provide a globally diversified balanced portfolio appropriate for investors within 10-15 years of
retirement or that wish to invest in a medium to higher risk portfolio.
Model Strategy: The AFS CIO Moderately Aggressive Portfolio invests in a broadly diversified mix of 17
asset classes consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The
portfolio uses a modified mean-variance framework with the goal of achieving an optimized risk/return
asset allocation corresponding with a moderately aggressive portfolio while considering the tax impact.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
AFS CIO Aggressive Portfolio - Tax Aware
Model Objective: The AFS CIO Aggressive Portfolio pursues a balance of growth and income to provide a
globally diversified balanced portfolio appropriate for investors with greater than 15 years until
retirement or that wish to invest in a higher risk portfolio.
Model Strategy: The AFS CIO Aggressive Portfolio invests in a broadly diversified mix of 17 asset classes
consisting of individual equities, ETFS, Closed-End Funds and Open-end Mutual funds. The portfolio uses
a modified mean-variance framework with the goal of achieving an optimized risk/return asset allocation
corresponding with an aggressive portfolio while considering the tax impact.
Model Risk: All investments carry some degree of risk. The portfolio is subject to the volatility of the
equity and fixed income markets and may be impacted by market, economic, regulatory, or political
events.
“Held-away” assets
We use a third-party platform called Pontera Solutions Inc. to facilitate discretionary management of held
away assets (e.g. 401(k) accounts, 403(b) accounts, HSA’s, and 529 plans). The platform allows us to avoid
being considered to have custody of Client funds since we do not have direct access to Client log-in
credentials to affect trades. We are not affiliated with the platform in any way and receive no
compensation from them for using their platform. A link will be provided to the Client allowing them to
connect an account(s) to the platform. Once a client account(s) is connected to the platform, your adviser
will review the current account allocations. When deemed necessary, we will rebalance the account
considering client investment goals and risk tolerance, and any change in allocations will consider current
economic and market trends. The goal is to improve account performance over time, minimize loss during
difficult markets, and manage internal fees that harm account performance. Client account(s) will be
reviewed at least quarterly and allocation changes will be made as deemed necessary. There is no
additional fee for this service.
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Financial Planning
We provide services such as comprehensive financial planning, estate planning, business planning and
educational planning. Fee based financial planning is a comprehensive relationship which incorporates
many different aspects of your financial status into an overall plan that meets your goals and objectives.
The financial planning relationship consists of face-to-face meetings and ad hoc meetings with you and/or
your other advisors (attorneys, accountants, etc.) as necessary.
In performing financial planning services, we typically examine and analyze your overall financial situation,
which may include issues such as taxes, insurance needs, overall debt, credit, business planning,
retirement savings and reviewing your current investment program. Our services may focus on all or only
one of these areas depending upon the scope of our engagement with you.
It is essential that you provide the information and documentation we request regarding your income,
investments, taxes, insurance, estate plan, etc. We will discuss your investment objectives, needs and
goals, but you are obligated to inform us of any changes. We do not verify any information obtained from
you, your attorney, accountant or other professionals.
If you engage us to perform these services, you will receive a written agreement detailing the services,
fees, terms and conditions of the relationship. You will also receive this Brochure. You are under no
obligation to implement recommendations through us. You may implement your financial plan through
any financial organization of your choice.
We obtain information from a wide variety of publicly available sources. We do not have any inside private
information about any investments that are recommended. All recommendations developed by us are
based upon our professional judgment. We cannot guarantee the results of any of our recommendations.
Choosing which advice to follow is your decision.
We can also work with you, in a consulting capacity, to create an Investment Policy Statement (IPS) that
will serve as the roadmap to guide your wealth management program. Your IPS will incorporate many
different aspects of your financial status into an overall plan designed to meet your goals and objectives.
We will create a formal IPS and deliver it to you upon completion.
If you decide to implement our recommendations, we will help you open a custodial account(s). The funds
in your account will generally be held in a separate account, in your name, at an independent custodian,
and not with us. We recommend using Charles Schwab & Co., Inc. (“Schwab”) as the custodian for your
account(s); however, you may use any custodian you wish.
Retirement Plan Services
For our firm’s Retirement Plan accounts, our service begins with an analysis of the current retirement plan
structure, custodian, third-party administrator, daily record keeper, investments, managed investment
models, and fees. The analysis is designed to determine if we are able to add value to the plan and what
areas, if any, may be deficient from both a regulatory perspective and from a financial advisory
perspective.
We will offer you one or more of the following services:
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• Plan design and asset selection consultation
• Develop and annually review Investment Policy Statement (“IPS”)
• Develop investment menu according to the IPS
• Review plan sponsor’s stated financial criteria for each investment option
• Monitor each investment option according to the IPS
• Quarterly portfolio statements, rate of return reports, asset allocation statements
• Provide investment research and performance information on investment options
• Investment option replacement guidance
• Personal consultations with the plan sponsor as necessary
• Develop Plan Investment Committee Charter, as needed
• Fiduciary due diligence assistance
• Attendance at Plan Committee and other meetings
• Annual Fiduciary Plan Review
• Fiduciary education services to Plan Committee
• Participant education, guidance, and enrollment
• Vendor coordination assistance
• Benchmarking services
Plan Structure
We will assist our client in evaluating the current plan’s structure to determine if a change in the design
of the plan better suits the needs of plan participants. We will facilitate any changes with the appropriate
parties including the third-party administrator, record keeper, and custodian as well as facilitating the
execution of the required plan document amendments or new plan documents. However, we will not
draft any amendments as an attorney or a TPA will need to perform this service.
Participant Meetings
We offer one
on one financial advice for retirement plan participants on an ongoing basis when requested.
We may also coordinate and/or conduct periodic investment, enrollment and/or retirement education
meetings for Plan participants as determined by the Plan .
Investment Committee
We will assist you in the establishment of the Investment Committee (if a Committee is deemed
appropriate) and the establishment of a formal investment committee charter, delineating committee
responsibilities and fiduciary roles.
The Investment Committee may be charged with the fiduciary responsibility of the prudent management
of the investment portfolio, selecting and retaining professional advisors to the portfolio including
investment managers, investment consultants, custodians, attorneys, and clerical staff, and the
establishment, execution, and interpretation of an Investment Policy Statement for the portfolio. We will
assist the Investment Committee in meeting the committee’s responsibilities according to the investment
committee charter, and fulfilling its fiduciary duty to the plan, including their review of service providers,
Anderson Financial Strategies ADV Part 2A March 2024 Page 11 of 42
third-party administration firms, daily record keeper, and custodian to ensure that their services, along
with ours, remain competitive to other alternatives that are available to the client.
Investment Policy Service
Our Investment Policy Service is designed to assist you in creating a written investment policy statement
(“IPS”) to document the plan’s investment goals and objectives as well as certain policies governing the
investment of assets. The IPS also identifies an investment strategy that seeks to attain the plan’s goals.
The service is generally designed for corporate retirement plans that are managed on a non-discretionary
basis.
We will assist the Investment Committee with the establishment, execution, and interpretation of the
Investment Policy Statement. The Investment Policy Statement serves as a guide to assist the Investment
Committee in effectively supervising, monitoring, and evaluating the investment of the plan’s assets. We
will prepare a draft of the IPS based upon information furnished by you and your firm designed to profile
various factors for the account such as investment objectives, risk tolerances, projected cash flow, and
demographics of your retirement plan participants. It is the client’s responsibility to provide all necessary
information for the preparation of the IPS, particularly any limitations imposed by law or otherwise. This
draft IPS is then submitted to you for review and approval. We recommend that your professional
advisors, such as an attorney, actuary, and/or accountant, also review the IPS. The review and acceptance
of the IPS is the responsibility of the plan fiduciary and your retirement program’s governing entity.
Upon client’s final approval, the IPS is ready to be sent to client’s Investment Committee. It is client’s
responsibility to confirm the Investment Committee’s acceptance of the IPS, and it is the Investment
Committee’s responsibility to adhere to the IPS in managing the retirement program. We encourage you
to review accounts periodically to verify the investment committee’s compliance with the IPS.
The Investment Policy Statement will be reviewed at least annually to determine whether stated
investment objectives are still relevant and the continued feasibility of achieving those objectives.
However, the Investment Policy Statement is not expected to vary much from year to year and the IPS will
not be updated to account for short-term changes in market conditions or the economic environment.
Investment Selection, Monitoring, and Replacement
We will conduct research to determine allocations and to project potential ranges of returns and market
values over various time periods and using various cash flows. As the financial advisor to the Plan, we will
assist the Investment Committee in selecting the non-managed investment line up including evaluating
investment managers and mutual fund companies, individual mutual funds, and money market funds
which may be retained or replaced.
The data used to select the investment options is based on estimated, forward-looking performance of
various asset classes and subclasses to create forward looking capital markets assumptions (e.g., expected
return, expected standard deviation, correlation, etc.). Past performance and the return estimates of the
asset classes and the indices that correspond to these asset classes may not be representative of actual
future performance. Actual results could differ, based on various factors including the expenses
associated with the management of the portfolio, the portfolio’s securities versus the securities
comprising the various indices and general market conditions. Before a specific investment is selected,
other factors such as economic trends, which may influence the choice of investments and risk tolerance,
Anderson Financial Strategies ADV Part 2A March 2024 Page 12 of 42
should be considered. We have the responsibility and authority to recommend the investment line up
including evaluating investment managers and mutual fund companies, individual mutual funds, and
money market funds which may be retained or replaced. The plan sponsor has the responsibility and
authority to make the final decision regarding what investments to include in the model portfolio and
when to add or exclude a specific security.
We also encourage you to consult with your other professional advisors since Anderson Financial
Strategies does not provide tax or legal advice that may affect asset classes or allocations used in the
modeling. We will apply guidelines you supply, as directed; however, compliance with these restrictions
or guidelines is the client’s responsibility.
We will also monitor the current non-managed investment line up including the investment’s
performance, performance compared to an applicable benchmark index, fees, management changes,
style and fundamental investment strategy changes, and fund composition to determine if an investment
no longer meets the criterion defined in the Investment Policy Statement. If the Investment Committee
determines that a fund no longer meets the IPS criterion, we will advise the Investment Committee on
possible alternatives and assist in the selection of a replacement investment.
If you decide to implement any of the firm’s recommendations, we will help you open a custodial
account(s) for the plan, if you do not have one established. The funds in this account will generally be
held in a separate account, in the plan’s name, at an independent custodian, not with us. The identity of
your custodian will be communicated to you before the account is opened. The custodian will affect
transactions, deliver securities, make payments, etc. You will at all times maintain full and complete
ownership rights to all assets held in the account for the benefit of the plan participants.
We are available during normal business hours either by telephone, email, or in person by appointment
to answer your questions.
Reporting
We will send a quarterly performance report detailing the overall performance of the plan’s assets and a
detailed list of the investment holdings.
Sub-advisory Services
There may be instances in which we will enter into an agreement with a sub-advisor who will provide 3(21)
or 3(38) fiduciary services to the Plan. In those instances, in which we have entered into an agreement
with a subadvisor to provide 3(21) fiduciary services, we will monitor the performance of the subadvisor
and the products made available to the Plan. We will also make recommendations to change the
subadvisor or products made available to the plan, if necessary. Your Retirement Plan Consulting
Agreement will further describe the 3(21) or 3(38) fiduciary services that will be provided by Anderson
Financial Strategies and/or a sub-advisor.
ERISA Fiduciary
Both parties acknowledge that if the Account is subject to the Employee Retirement Income Security Act
of 1974, as amended (ERISA), the following provisions will apply:
Anderson Financial Strategies ADV Part 2A March 2024 Page 13 of 42
• The Adviser acknowledges that it is a “fiduciary” with respect to the Client as that term is defined
under Section 3(21)(A) of ERISA.
• The person signing this Agreement on behalf of the Client acknowledges its status as a “named
fiduciary” with respect to the control and management of the assets held in the Account, and
agrees to notify the Adviser promptly of any change in the identity of the named fiduciary with
respect to the Account;
• The Adviser agrees to obtain and maintain an ERISA bond satisfying the requirements of Section
412 of ERISA and include The Adviser and its members, agents and employees among those
insured under that bond.
When delivering ERISA fiduciary services, we will perform those services for the retirement plan as a
fiduciary under ERISA Section 3(21)(A)(ii) will act in good faith and with the degree of diligence, care and
skill that a prudent person rendering similar services would exercise under similar circumstances.
Non-Discretionary 3(21) Fiduciary Services
When the Adviser performs “3(21) Fiduciary Services,” the Adviser will act as a co-fiduciary “investment
adviser” that provides “investment advice” as defined under Section 3(21) of ERISA. Under this
arrangement the Adviser is appointed by the plan sponsor or trustee to determine a recommended lineup
of investments to be included in the Plan. These recommendations are presented to the Plan Sponsor,
who has the ultimate responsibility to accept or reject the recommendation. The Adviser will not have
any further responsibility to communicate instructions to any third‐party, including the custodian, and/or
third‐party administrator. The Adviser will not communicate directly with the recordkeeper regarding
administrative and recordkeeping matters arising under the Adviser’s investment advisory agreement
with the Plan Sponsor, or more generally about the recordkeeper’s services to the Plan.
The Adviser will provide the Plan Sponsor with a sample investment policy statement. Each retirement
Plan Sponsor should adopt a final investment policy statement (“IPS”) which serves as a guide for the
Adviser’s investment advisory services. The Adviser offers the following 3(21) services:
• Investment screening
• The selection of replacement funds to which existing Plan balances may be transferred
• Assisting clients to finalize a Plan’s investment lineup of funds available for investment by Plan
participants and used for other administrative purposes under the Plan
• Assisting clients with electing a “qualified default investment alternative” as defined in section
404(c)(5) of ERISA
• Quarterly plan review meetings – including review of Investment Funds
In the Adviser’s capacity as a 3(21) plan fiduciary, they will conduct research to determine appropriate
investment selections and allocations and to project potential ranges of returns and market values over
various time periods and using various cash flows to assist the Plan Sponsor in determining the appropriate
investment options for the retirement plan.
The data used to select the investment options is based on estimated, forward-looking performance of
various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g.,
Anderson Financial Strategies ADV Part 2A March 2024 Page 14 of 42
expected return, expected standard deviation, correlation, etc.). Past performance and the return
estimates of the asset classes and the indices that correspond to these asset classes may not be
representative of actual future performance. Actual results could differ, based on various factors including
the expenses associated with the management of the portfolio, the portfolio’s securities versus the
securities comprising the various indices and general market conditions. Before a specific investment is
selected, other factors such as economic trends, which may influence the choice of investments and risk
tolerance, should be considered. The Adviser has the responsibility and authority to recommend the
investment line up including evaluating investment managers and mutual fund companies, individual
mutual funds, and money market funds which may be retained or replaced. The Plan Sponsor has the
responsibility and authority to make the final decision regarding what investments to include and when
to add or exclude a specific security.
The Client confirms that any instructions that have been given to the Adviser with regard to the Account
are consistent with the governing plan documents and investment policy statements of the plan.
Except as otherwise provided under ERISA the Adviser shall not be liable for any error of judgment or
mistake of law or for any loss suffered by the Client in connection with the matters to which this
Agreement relates except a loss resulting from the Adviser’s breach of its fiduciary duty, negligence,
misconduct or bad faith.
The Adviser is not (i) the “administrator” of the Plan as defined in § 3(16)(A) of ERISA or (ii) the “plan
administrator” of the Plan as defined in Section 414(g) of the Internal Revenue Code of 1986, as amended
(the “Code”);
The Adviser is neither a law firm nor a public accounting firm and Adviser will not provide legal or
accounting advice;
The Client acknowledges that the services covered by this Agreement are consultative and give no
investment authority (“discretion”) or responsibility to the Adviser over any assets of the Plan or
Participant regardless of how and where the assets are held. Throughout the term of this Agreement,
the Plan or Participant retains full discretion to supervise, manage and direct the assets that may be held
with any affiliated or unaffiliated third party.
We also encourage plan sponsors to consult with other professional advisors since we do not provide tax
or legal advice that may affect asset classes or allocations. We will apply any guidelines our client supplies,
as directed, however, compliance with these restrictions or guidelines, is our client’s responsibility.
The Adviser provides advisory services, which include providing retirement Plan Sponsors or other plan
fiduciaries (“Plan Sponsors”) investment advisory and management services by assisting plans in
establishing and/or maintaining a consistent and ongoing documented process of prudent oversight and
due diligence. The Adviser provides services to clients that sponsor a retirement plan that is qualified
under the Internal Revenue Code of 1986, as amended (the “IRC”) and/or subject to the Employee
Retirement Income Security Act of 1974 (“ERISA”). Services may include benchmarking, plan design
strategies, analysis, fiduciary consulting and oversight, plan level investment advice and investment fund
selection and monitoring services, and some employee education services.
Anderson Financial Strategies ADV Part 2A March 2024 Page 15 of 42
The Adviser does not act as, and has not agreed to assume the duties of, a Plan trustee or the “Plan
Administrator,” as defined under section 3(16) of ERISA nor as trustee as described by SEC Rule 206(4)-2.
The Adviser has no discretion to interpret the Plan documents, to determine eligibility or participation
under the Plan, to provide participant disclosures or communications, to ensure contributions are timely
received by the Plan or to exercise any other action with respect to the management, administration or
any other aspect of the Plan.
The Adviser’s services are offered to assist plan fiduciaries as they carry out their investment related
responsibilities and these services should not substitute for or diminish the careful deliberation and
determination of plan fiduciaries, after appropriate consultation with their other professional advisers
and the review of relevant plan documentation.
Discretionary 3(38) Fiduciary Services
When a client engages the Adviser to perform “3(38) Fiduciary Services”, the Adviser acts as an
“investment manager” (as defined in Section 3(38) of ERISA) with respect to the performance of
discretionary fiduciary investment services. Under this arrangement the Adviser is appointed by the Plan
Sponsor or trustee and accepts discretion over plan assets and assumes full responsibility and liability for
fiduciary functions concerning decisions related to the plan assets.
Under this arrangement the Adviser is appointed by the plan sponsor or trustee and accepts discretion
over plan assets and assumes full responsibility and liability for fiduciary functions concerning decisions
related to the plan assets. The Adviser will review the investment options available to the Plan through
documents provided by the Plan Sponsor and notifies the Plan’s record-keeper and/or the Plan Sponsor
the Adviser’s instructions to add, remove and/or replace these specific investment options offered to Plan
participants and/or used for administrative purposes under the Plan, according to the criteria set forth in
guidelines selected by the Plan Sponsor. The Plan Sponsor retains all authority, responsibility and
decision-making for investment options not available on the Plan record-keeper’s platform (i.e.,
“noncore” investment options, such as employer stock, plan loans, self-directed brokerage accounts,
frozen guaranteed investment contracts, and life insurance).
The Adviser will retain final decision-making authority with respect to removing and/or replacing
investments in the core lineup. The Plan Sponsor will not have responsibility to communicate instructions
to any third‐party, custodian and/or third‐party administrator.
The data used to determine the investment options is based on estimated, forward-looking performance
of various asset classes and subclasses to create our forward-looking capital markets assumptions (e.g.,
expected return, expected standard deviation, correlation, etc.). Past performance and the return
estimates of the asset classes and the indexes that correspond to these asset classes may not be
representative of actual future performance. Actual results could differ, based on various factors including
the expenses associated with the management of the portfolio, the portfolio’s securities versus the
securities comprising the various indexes and general market conditions. Before a specific investment is
selected, other factors such as economic trends, which may influence the choice of investments and risk
tolerance, should be considered. The Adviser has the responsibility and authority to determine the
investment line up including evaluating investment managers and mutual fund companies, individual
mutual funds, and money market funds which may be retained or replaced.
Anderson Financial Strategies ADV Part 2A March 2024 Page 16 of 42
The Adviser will also monitor the current managed investment line up including the investment’s
performance compared to an applicable benchmark. If the Adviser determines that a fund no longer
meets the criteria, they will select alternatives and replace them.
Wrap Fee
The Firm does not sponsor or participate in a third-party sponsored wrap fee program.
Assets Under Management
Anderson Financial Strategies has $245,683,085 in assets under management as of December 31, 2023.