A. Firm Information
Legacy Financial Independent Advisors LLC (“LFIA” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Kentucky. The Advisor commenced operations in January 2023. The
Principal Officers of LFIA are Bruce McCrea (Partner and Financial Advisor / Chief Compliance Officer),
Christopher R. McCrea, CFP® (Partner and Financial Advisor), and Bryan S. McCrea (Partner and Financial
Advisor).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by LFIA. For information regarding this Disclosure Brochure, please contact Bruce McCrea
(Chief Compliance Officer) at (502) 873-0522.
B. Advisory Services Offered
LFIA offers advisory services to individuals, high net worth individuals, families, trusts, estates, businesses, and
retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness, and good faith towards each Client and seeks to mitigate conflicts
of interest. LFIA’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Wealth Management Services
LFIA provides customized wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary wealth management and related advisory
services. LFIA works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to design a portfolio strategy. LFIA will then construct an investment
portfolio, primarily consisting of individual stocks, mutual funds, and/or exchange-traded funds (“ETFs”) to
achieve the Client’s investment goals. The Advisor may also utilize individual bonds and other types of
investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain legacy investments
based on portfolio fit and/or tax considerations.
LFIA will select, recommend and/or retain mutual funds on a fund by fund basis. Due to specific custodial and/or
mutual fund company constraints, material tax consideration, and/or systematic investment plans, LFIA will
select, recommend and/or retain a mutual fund share classes that do not have trading costs when possible.
These will in most cases be institutional share classes but in some cases may be share classes with higher
internal expense ratios than institutional share classes. LFIA will seek to select the lowest cost share class
available that is in the best interest of each Client weighing the expected investment pattern, expense ratios and
potential ticket charges, and will ensure the selection aligns with the Client’s financial objectives and stated
investment guidelines.
LFIA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. LFIA
will construct, implement, and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and
risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on
the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
LFIA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. LFIA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. LFIA may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against the market movement. LFIA may recommend
selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or
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sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s]
in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed
unacceptable for the Client’s risk tolerance.
Use of Independent Managers – LFIA may recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. In certain instances, the Client may be required
to authorize and enter into a wealth management agreement with the Independent Manager[s] that defines the
terms in which the Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing
oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients
investment objectives and overall best interests. The Advisor will also assist the Client in the
development of the
initial policy recommendations and managing the ongoing Client relationship. The Client, prior to entering into an
agreement with an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A -
Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning Services
LFIA will typically provide a variety of financial planning and consulting services to Clients. LFIA may including
financial olanning services as part of its overall wealth management services and fee or as a separate
engagmeent. Services are offered in several areas of a Client’s financial situation, depending on their goals and
objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a
specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting
may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. LFIA may also refer Clients to
an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain financial
planning engagements, the Advisor will provide a written summary of the Client’s financial situation,
observations, and recommendations. For project-based or ad-hoc engagements, the Advisor may not provide a
written summary. Project-based financial plans or consultations are typically completed within six (6) quarters of
contract date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for wealth management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
LFIA provides non-discretionary retirement plan advisory services on behalf of the retirement plans (each a
“Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to
assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each
engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment monitoring and oversight
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
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These services are provided by LFIA serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of LFIA’s fiduciary status, the specific services to be rendered and
all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging LFIA to provide advisory services, each Client is required to enter into a written advisory
agreement with the Advisor that define the terms, conditions, authority, and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – LFIA, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – LFIA will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation, and tolerance for risk for each Client or unique client goal.
• Portfolio Construction – LFIA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Wealth Management and Supervision – LFIA will provide wealth management and ongoing oversight of
the Client’s investment portfolio.
D. Wrap Fee Programs
LFIA does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by LFIA.
E. Assets Under Management
As of December 31, 2023, LFIA manages $429.4mm in assets, all of which are on a discretionary basis. Clients
may request more current information at any time by contacting the Advisor.