Overview
A. Description of the Advisory Firm
Describe your advisory firm, including how long you have been in business. Identify your principal
owner(s).
SFGAM is a Delaware limited liability company formed on January 1, 2022. SFGAM is an SEC
registered investment advisor. It is a direct subsidiary of Sammons Financial Group (“SFG”).
SFGAM provides discretionary and non-discretionary investment advisory services to various
affiliated companies as described below.
B. Types of Advisory Services
Describe the types of advisory services you offer. If you hold yourself out as specializing in a
particular type of advisory service, such as financial planning, quantitative analysis, or market
timing, explain the nature of that service in greater detail. If you provide investment advice only
with respect to limited types of investments, explain the type of investment advice you offer, and
disclose that your advice is limited to those types of investments.
SFGAM is engaged in the business of managing or advising certain affiliated client accounts. In
some circumstances, SFGAM provides both investment advisory services and administrative
services to clients.
SFGAM generally has discretionary authority to determine which investments are bought and
sold and the amounts of such investments that are appropriate for each client. In addition to its
direct advice, SFGAM, subject to approval by the client, will delegate investment discretion for
all or part of the account to other investment management firms as sub-advisors. If SFGAM
delegates any portion of a client account, it will evaluate and recommend appropriate sub-
advisor(s), oversee the investment management of any sub-advisor(s), and monitor the
performance of the sub-advisor(s). SFGAM conducts due diligence on sub-advisors to evaluate
their investment processes, adherence to investment styles, strategies and techniques, and
other factors that may be relevant
to the services provided.
SFGAM will directly provide hedging and derivative services for clients. As appropriate, SFGAM
will provide direct investment recommendations to clients.
SFGAM also provides services related to, among others, risk management and oversight of total
portfolio, strategic asset allocation, and integration with asset-liability management and capital
management strategies.
SFGAM will provide clients periodic reports on the investment performance of all accounts.
SFGAM may develop new advisory services in the future that could differ materially from those
described in this Brochure, in which case SFGAM will amend this Brochure to provide applicable
information and disclosures.
C. Client Tailored Services and Client Imposed Restrictions
Explain whether (and, if so, how) you tailor your advisory services to the individual needs of
clients. Explain whether clients may impose restrictions on investing in certain securities or types
of securities.
SFGAM manages client accounts based on investment guidelines set forth in each client’s
Investment Management Agreement.
D. Wrap Fee Program
If you participate in wrap fee programs by providing portfolio management services, (1) describe
the differences, if any, between how you manage wrap fee accounts and how you manage other
accounts, and (2) explain that you receive a portion of the wrap fee for your services.
SFGAM does not offer a wrap fee program.
E. Assets Under Management
If you manage client assets, disclose the amount of client assets you manage on a discretionary
basis and the amount of client assets you manage on a non-discretionary basis. Disclose the date
“as of” which you calculated the amounts.
As of December 31, 2023, SFGAM has the following assets under management:
Discretionary Assets Non-Discretionary Amounts Date Calculated
$ 11,358,738,764
$0 December 2023