INTRODUCTION
Integrity Advisory Solutions, LLC (referred to as “we,” “our,” “us,” “Firm,” “Adviser,” or “Integrity Advisory
Solutions”) is a Delaware Limited Liability Company, founded in 2017, with its principal office located in
Burlington, North Carolina. Integrity Advisory Solutions has provided investment advisory services since March
2018 as a state-registered investment adviser and was approved as a U.S. Securities and Exchange Commission
(“SEC”) registered investment adviser on January 20, 2022. The Firm provided investment advisory services
under the name “Burlington Alliance Capital Management, LLC” until September 2023, when its name was
legally changed. The Firm is a wholly owned, indirect subsidiary of Integrity Marketing Group, LLC (“Integrity
Marketing Group”).
As an investment adviser, Integrity Advisory Solutions is a fiduciary to our clients under the Investment Advisers
Act of 1940 (“Advisers Act”), as interpreted. As a fiduciary, we seek to uphold a duty of loyalty, care, fairness
and good faith towards each client and to disclose and mitigate conflicts or potential conflicts of interest.
Integrity Advisory Solutions primarily offers wrap and non-wrap, directly managed, and sub-advised portfolio
management services (including the Wealth Solutions and Retirement Ally wrap fee programs sponsored and
sub-advised by our affiliate, Brokers International Financial Services, LLC (“Brokers Financial”)) to individuals,
high net-worth individuals, trusts, estates, or charitable organizations, corporations or other business entities
(each referred to as a client or collectively as “clients”) as described below. This Form ADV, Part 2A, Appendix
1, Wrap Brochure summarizes the IAS Aspire Wrap Program developed and sponsored by the Firm. The Firm’s
other services, which include financial planning, consulting, retirement plan consulting, and retirement plan
participant consulting services, are summarized in our Form ADV, Part 2A, Disclosure Brochure. If you would
like a copy of our Form ADV, Part 2A, Disclosure Brochure, please contact your investment adviser
representative or Integrity Advisory Solutions at (214) 919-2165 or by email at
[email protected].
A wrap fee program is an 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 may include portfolio
management or advice concerning the selection of other investment advisers) and the execution of client
transactions. In other words, transactions in a client’s wrap fee account are generally effected without separate
commission charge to the client and a portion of the wrap fee is generally considered as being in lieu of
commissions. In a non-wrap program, a client will separately incur commissions and other transaction charges
for each trade placed in the client’s account in addition to investment advisory fees.
When recommending an appropriate investment program, including whether to recommend a wrap or non-wrap
fee program, the investment adviser representative will generally consider, among other circumstances, the
client’s account size and advisory fees to be charged, the anticipated trading volume, the types and quantities of
securities to be purchased or sold, and commission rates to be charged for transactions should a non-wrap account
be selected. In general, a wrap fee account is more cost effective for the client when trading activity is anticipated
to be high, though a wrap fee account may be more expensive than a non-wrap fee account when trading activity
is low.
Recommendations presented to clients by Integrity Advisory Solutions and the implementation of such
recommendations are dependent upon the information provided by the client to build the client’s financial
profile, which outlines each client’s current situation (e.g., income, investment objectives, and risk tolerance
levels) and is used to construct a client specific action plan to aid in the selection of an investment program, and
portfolio, that matches their restrictions, needs, and targets.
Our business model is based on a network of investment adviser representatives with offices located throughout
the United States. Investment adviser representatives generally operate their businesses as independent
contractors of Integrity Advisory Solutions and are subject to our supervision and oversight from a centralized
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location. Many investment adviser representatives have their own business entities whose trade names and logos
are used for marketing purposes and may appear on marketing materials and/or client statements. More
information about the investment adviser representative servicing your account can be found in the individual
investment adviser representative’s Form ADV, Part 2B, Brochure Supplement provided to you when you
opened your account. If you did not receive a copy of your investment adviser representative’s Form ADV Part
2B, Brochure Supplement, please contact your representative or Integrity Advisory Solutions by phone at (214)
919-2165 or by email at
[email protected].
When transferring your account to be invested, generally, existing positions in the account will be liquidated,
and the cash transferred to a qualified independent custodian. The liquidation of your account likely will have
tax consequences, which you should discuss with your tax adviser. Also, liquidating securities positions will
likely incur one-time transaction charges that are not included in the wrap fee charged for the IAS Aspire Wrap
Program. However, if there are certain securities you own that you do not want to liquidate, you must notify
your investment adviser representative in writing and they will be transferred in-kind for custody, but we will
not advise on those positions. Any transaction costs incurred in the liquidation of your transferred assets are not
included in the wrap fee described below and will be the responsibility of the client.
SERVICES
Integrity Advisory Solutions is the sponsor of the IAS Aspire Wrap Program (the “Aspire Program”). Through
the Aspire Program, clients receive ongoing investment advice regarding the investment of their account from
their investment adviser representative. The investment adviser representative is responsible for selecting an
investment strategy fitting the client’s investment objectives and risk tolerance as well as the particular securities
and the allocation among securities used within the selected strategy. Certain investment adviser representatives
will develop models or strategies that are generally applied, as appropriate, in the management of their client
accounts, while other investment adviser representatives will develop customized portfolios for each client to
meet a client’s specific investment goals and objectives.
Investment strategies, models, and philosophies used within the Aspire Program will vary based on the
investment adviser representative servicing your account. Models and strategies used by one investment adviser
representative are likely to be different than the models and strategies used by other investment adviser
representatives. Some investment adviser representatives limit their advice to mutual funds and exchange traded
funds (ETFs) and others will provide advice on a full range of securities including but not limited to: exchange-
listed securities, securities traded over the counter, foreign issues, ETFs, warrants, corporate debt securities,
commercial paper, certificates of deposit, mutual fund shares, municipal securities, United States government
securities, and options contracts on securities. As a result of these varied approaches, the portfolios of clients
enrolled in the Aspire Program with similar investment needs and profiles will not necessarily be similarly
invested or experience the same performance.
The Aspire Program allows for both discretionary and non-discretionary trading authority. With discretionary
trading, the investment adviser representative has the authority to buy or sell securities without obtaining a
client’s approval prior to each transaction. With non-discretionary trading, the investment adviser representative
must obtain a client’s approval before each transaction, which means that the client makes the ultimate decision
regarding the purchase or sale of investments in their account. Clients grant the investment adviser representative
discretion when signing an Investment Management Agreement for the Aspire Program that includes a provision
conferring discretionary authority. Integrity Advisory Solutions requires the investment adviser representative
to meet certain qualifications, as established by the Firm, before they are permitted to exercise discretion over
client accounts. Your investment adviser representative is required to notify you if they will exercise discretion
with respect to your account.
Clients may place reasonable restrictions on the types of investments that may be purchased in their Aspire
Program account. Clients may also place reasonable limitations on the discretionary power granted to investment
adviser representatives, so long as the restrictions and limitations are specifically set forth in writing or included
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as an attachment to the appropriate client Investment Management Agreement. Discretionary authority will
remain in place unless revoked by you in writing or until you or we terminate the relationship.
Integrity Advisory Solutions will manage only the securities, cash and other investments held within a client’s
account, and in making investment decisions for a client’s account. Clients also should note, in providing
advisory services, we are not required to verify any information we receive from you or from your other
professionals (e.g. attorney, accountant, etc.). Furthermore, unless you indicate to the contrary, we will assume
that there are no restrictions on our services, other than to manage your account in accordance with your
designated investment objectives. It is your responsibility to promptly notify us if there are changes in your
financial situation or investment objectives for the purpose of reviewing, evaluating, and/or revising our previous
recommendations or services. Integrity Advisory Solutions makes no guarantee, either oral or written, that a
client’s investment objectives will be achieved.
The Custodians and Brokers We Use
Client Aspire Program account assets must be maintained in an account at a “qualified custodian,” generally a
broker-dealer or bank.
For the Aspire Program, we typically recommend Pershing, LLC (“Pershing”), Charles Schwab & Company, Inc.
(Schwab”), or Fidelity Brokerage Services LLC (together with all affiliates, “Fidelity”) as the client’s account
custodian. Not all investment advisers restrict or limit the custodians/broker-dealers their clients can use. Some
investment advisers permit their clients to select any custodian/broker-dealer of the client’s own choosing.
For accounts custodied with Pershing, Brokers International Financial Services, LLC (“Brokers Financial”), an
affiliate of Integrity Advisory Solutions, will serve as the introducing/executing broker, for which it will receive
direct and/or indirect compensation. As Brokers Financial is affiliated with Integrity Advisory Solutions through
common ownership, the potential to receive compensation for providing brokerage services to Integrity Advisory
Solutions client accounts custodied with Pershing creates a conflict of interest when we recommend a custodian for
the client’s account. This is because any compensation received by Brokers Financial while acting in this capacity
will ultimately inure to the benefit of Integrity Marketing Group, which indirectly owns both Integrity Advisory
Solutions and Brokers Financial. Integrity Advisory Solutions seeks to address this conflict of interest by making a
number of investment programs available to clients, by ensuring that the Aspire Program is made available through
custodians other than Pershing, and by adopting policies reasonably designed to ensure that investment adviser
representatives make recommendations to clients based on their best interests. Clients are not obligated to select
Pershing as their Aspire Program account custodian.
With respect to client accounts custodied with Pershing, for which our affiliate, Brokers Financial, acts as
introducing/executing broker, instructions
have been provided requesting that Pershing rebate 12b-1 fees charged
by mutual funds held in client accounts to their investors and incurred by the Firm’s clients. For client accounts
custodied with Schwab, or Fidelity, where Brokers Financial is not the executing broker, Schwab or Fidelity, as
applicable, will generally retain any 12b-1 fees charged to clients from mutual funds held in their accounts. These
differing approaches will result in client accounts being more costly to maintain when holding mutual funds
charging 12b-1 fees at Schwab versus Pershing. Clients should consider the differing treatment of 12b-1 fees by
account custodians, including whether the client expects to hold mutual funds in their account, when selecting an
account custodian. Please refer to Item 9 – Additional Information for more information regarding 12b-1 fees.
The qualified custodian selected will hold your assets in a brokerage account and will buy and sell securities when
we instruct them to. We do not open the account for you, although we will assist you in doing so.
Directed Brokerage
Integrity Advisory Solutions does not accept the discretionary authority to determine the broker dealer to be used
in connection with trades placed in the client’s account. Instead, Integrity Advisory Solutions requires that clients
direct the Firm to place trades through the broker dealer custodying the client’s account, or, in the case of
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Pershing, through Integrity Advisory Solutions’ affiliate, Brokers Financial, in its capacity as
introducing/executing broker dealer to Pershing. (Pershing acts as a custodian for client accounts but does not
also act as executing broker with respect to trades placed in those accounts).
Because our affiliate, Brokers Financial, will act as introducing broker to accounts custodied at Pershing,
selecting Pershing as your account custodian is also a selection of Brokers Financial as the directed broker on
your account. Requiring that clients direct the use of its affiliate, Brokers Financial, as introducing/executing
broker for accounts custodied with Pershing creates certain conflicts of interest, as disclosed above and at Item
9 – Additional Information of this Wrap Brochure, which clients should carefully consider when selecting a
custodian and providing instructions to direct brokerage for their account.
Integrity Advisory Solutions has evaluated Pershing, whose services will be provided in combination with those
of our affiliate, Brokers Financial, and Schwab, and Fidelity, and believes that these entities will provide Integrity
Advisory Solutions clients with a blend of execution services, custodial services, and professionalism that will
assist Integrity Advisory Solutions in meeting its fiduciary obligations to clients. We conduct periodic reviews
of these entities and the services they provide to our clients to reasonably ensure that this continues to be true.
In directing the use of a particular broker it should be understood that Integrity Advisory Solutions will not have
authority to negotiate commissions on a trade-by-trade basis or to necessarily obtain volume discounts, and best
execution may not be achieved. Clients should note, while Integrity Advisory Solutions has a reasonable belief
that Schwab, Fidelity, and Brokers Financial/Pershing will be able to obtain quality execution and competitive
prices, Integrity Advisory Solutions will not independently seek best execution price capability through other
broker dealers on a trade-by-trade basis.
In evaluating our arrangements with custodians, the client should consider that transactions in the client’s
account are generally effected without separate trading costs to the client, and a portion of the total wrap fee is
considered to be in lieu of such transaction costs.
Integrity Advisory Solutions reserves the right to decline acceptance of any client account for which the client
directs the use of a broker dealer other than the client’s account custodian, or, in the case of client accounts
custodied with Pershing, Brokers Financial.
Integrity Advisory Solutions (and, in certain cases, our affiliate, Brokers Financial) receive certain benefits from
Pershing, Schwab, and Fidelity in connection with Aspire Program accounts. You should refer to Item 9 –
Additional Information below for details regarding these benefits, conflicts of interest that arise as a result, and
how we seek to address these conflicts.
Approved custodians offer NTF (no-transaction fee) mutual funds, which allows investment adviser
representatives to select mutual funds that trade without a transaction fee. The availability of NTF mutual funds
creates a conflict of interest with respect to the Aspire Program, in which the investment adviser representative
or Integrity Advisory Solutions is responsible for transaction costs because the more costs that can be avoided
with respect to the Aspire Program account, the more of the wrap fee is retained. At the same time, NTF mutual
funds often have higher internal expense ratios than other share classes of the same or other similar funds that
may be recommended for the client’s account. Please refer to Item 9 – Additional Information below for
additional information regarding this arrangement, resulting conflicts of interest, and how we seek to address
them.
Our affiliate, Brokers Financial, is a participant in Pershing’s FUNDVEST® ticket charge program, which offers
no-transaction fee (“NTF”) mutual funds. Brokers Financial’s participation in this Program gives rise to certain
additional conflicts of interest when we recommend custodians and investments to clients that clients should
carefully consider including the ability to share in service fees paid by certain mutual funds to Pershing. Please
refer to Item 9 – Additional Information for important additional information regarding our affiliate’s
participation in this program and resulting conflicts of interest.
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Also, unless directed otherwise by the client, the portion of each client account custodied with Pershing that is
allocated to cash will be automatically “swept” into FDIC-insured deposit accounts through a cash sweep
program that pays to Brokers Financial a percentage of the net interest rate available based on the amount of
client assets held in the cash sweep program. This arrangement reduces the amount of interest you earn on cash
balances in your account custodied with Pershing and creates conflicts of interest as described further at Item 9
– Additional Information below.
Similar advisory services may be available from other registered investment advisers for lower fees.
FEES
The fee charged to your Aspire Program account will equal the total of both a Program Fee, and the investment
adviser representative fee negotiated between you and your representative. Investment adviser representatives
may negotiate their fee with clients based on each client’s individual financial situation, complexity, and assets
under management, among other considerations.
The maximum Program Fee charged is equal to an annual rate of 0.20% of the Aspire Program account’s assets
under management. The maximum investment adviser representative fee is equal to 2.00% of the Aspire Program
account’s assets under management. The specific, total fee charged to each client will be outlined in, or attached
to, the Investment Management Agreement entered into with the client.
The portion of the total fee attributable to the Program Fee is not negotiable to the client, however, based on the
investment adviser representative’s total assets under management with Integrity Advisory Solutions, the
representative may be able to negotiate with Integrity Advisory Solutions for a lower Program Fee, which would
result in a client’s Program Fee being lower than 0.20%. The investment adviser representative can also negotiate
with Integrity Advisory Solutions to receive a portion of the Program Fee.
Total account fees are directly debited from your account, as authorized, quarterly, in advance, based on the
value of your account(s) at the end of the quarter. Integrity Advisory Solutions will pro rate its fees for accounts
opened mid quarter, which will be assessed at the end of the month in which the account was opened. For
example, if an account is opened on January 15, the Firm will charge its fee on February 1 for the remaining
days in January, as well as for February and March. In addition, each quarter’s fee going forward will be adjusted
for material deposits or withdrawals ($5,000 or more) made to/from the account during the quarter to “true-up”
the advance fee collected.
Comparative Cost of Program
Clients should note, the Aspire Program may cost the client more or less than purchasing advisory and trade
execution services separately. Depending on the level of fees charged by the executing broker dealer, and the
amount of trading activity in the client’s account, the value of the services provided in the Aspire Program may
or may not exceed the total cost of such services had they been provided and paid for individually. Factors the
client should consider include the size of the portfolio, the nature of the investments to be managed, the
anticipated level of trading activity, commission costs, custodial expenses, if any, and the amount of advisory
fees charged solely for managing the client’s portfolio. In addition, the wrap fee may be higher or lower than
that charged by other sponsors of comparable wrap fee programs.
Fees Not Included in Wrap Fee
In addition to the Wrap Fee, each mutual fund, ETF or ETN in which the client’s assets may be invested from
time to time pay an advisory fee to the fund’s investment adviser and charge other expenses as described in the
fund’s prospectus, which may include, but are not necessarily limited to, 12b-1 fees. Accordingly, the client
should review both the fees charged by funds held in their account and our fees to fully appreciate the total
amount of fees incurred and, thereby, evaluate the services provided through the Aspire Program.
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The wrap fee also does not cover transfer taxes, short-term redemption fees, certain brokerage related fees such
as administrative fees charged in connection with wire transfers, electronic fund transfer fees, or certificate
issuance, overnight shipping charges, fees for odd-lot differentials, step-out or “trade-away” fees (typically
imposed when trades are placed with a broker other than the custodying broker and which typically will include
commission charges imposed by the executing broker and an additional fee charged by the account custodian to
settle the trade into the client’s account), interest on loans, including margin loans, and other fees required by
law.
Representative Compensation
As disclosed above, your investment adviser representative will gather and analyze information regarding your
financial circumstances and, as appropriate, may recommend the Aspire Program. Integrity Advisory Solutions
and your investment adviser representative receive compensation as a result of your participation in the Program.
However, the investment adviser representative’s portion of the Aspire Program fee is negotiated between the
representative and the client and is capped at 2.00%. The representative does not receive increased compensation
by recommending the Aspire Program over other programs offered by Integrity Advisory Solutions, however,
the representative may have increased opportunity to negotiate a representative fee closer to the maximum
representative fee permissible when recommending a program charging a lower program fee.
We, and our investment adviser representative, have an incentive to encourage you to increase the assets in your
account as you pay the wrap fee even if no trading activity occurs in your account. We do not charge our clients
higher advisory fees based on their trading activity. You should be aware, however, that a potential conflict of
interest can arise because we are responsible for trading costs in wrap fee programs we sponsor and we, therefore,
have an incentive to limit our trading in your accounts. We seek to address this potential conflict by adopting
policies requiring that representatives provide recommendations based on client investment objectives, and by
monitoring client accounts for prolonged periods of inactivity.