Ifrah Financial Services, Inc. is a SEC-registered investment adviser with its principal place of
business located in Arkansas. We began conducting business in 2006.
Listed below are the firm’s principal shareholders (i.e., those individuals and/or entities
controlling 25% or more of this company):
Patrick Ifrah, President & CEO
Stephen DeSalvo, Chairman of the Board
Micah Brown
We offer investment supervisory services, individual portfolio management, and model portfolio
management services to Clients.
Our investment recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. We offer advice on a broad range of securities such as:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• Exchange Traded Funds (“ETF”)
• United States governmental securities
• Interests in partnerships (for example: real estate, oil and gas, among others)
• Structured Notes
Because some types of investments involve certain additional degrees of risk, they will only be
utilized when consistent with the Client’s stated investment objectives, tolerance for risk,
liquidity and suitability. Please refer to Item 8 for a discussion of our methods of analysis,
investment strategies, and risk.
Our firm provides investment supervisory and management services to Clients that may use
model asset allocation portfolios. Model asset allocation portfolios are offered through either
Goldman Sachs Custody Solutions (“GSCS”), formerly known as FOLIOfn and hereinafter
referenced as “GSCS” or Charles Schwab. Our available model portfolios are listed below. Each
is designed to meet a particular investment goal. Our firm can also provide discretionary
management of accounts outside of the model managed programs in certain circumstances.
FolioAdvantage Models
FolioAdvantage is a multi-strategy for money management. It attempts to diversify among types
of equities as well as the types of strategies used. It is based on the premise that there are various
times when certain types of securities and management styles go in and out of favor during the
economic cycles. FolioAdvantage models are managed at “GSCS”. See Item 12 (Brokerage
Practices) below for information related to “GSCS”.
Based on the planning process, the Planner may allocate among several sub-portfolios (“Folios”)
described below. Folios may be passive or actively managed (or a combination of both) and may
use multiple strategies and styles. Folios are used as part of the following allocations:
Standard Allocations:
• Ultra Conservative 40/60: 40% Equities - 60% Fixed Income & Cash
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash
Folios may also be created for Small Account Models (using ETFs only)
• Small Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Small Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Small Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash
• Ultra-Small Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Ultra-Small Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Ultra-Small Aggressive 90/10: 90% Equities – 10% Fixed Income & Cash
The following Folios may be used in any of the Standard and Small Account Models:
FOUNDATION FIXED INCOME
This Folio uses fixed income ETFs to create a core diversified portfolio of taxable fixed income
with the objective of matching or outperforming the Barclays Aggregate Bond Index on a risk-
adjusted basis. It is passive in nature however it is reviewed at least annually to consider changes
in the yield curve and to reallocate between short, intermediate, and long maturities if
appropriate. It may include corporate general and high yield bonds as well as inflation protected
treasury bonds as appropriate. Allocations are made in consideration of the trade-offs on the
yield curve between yield and maturities as well as quality spreads between Treasuries,
Corporates and other credit type securities made available through ETFs.
FOUNDATION EQUITY US
This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature. The
ETFs used are in various asset class categories attempting to cover the US market and are
allocated in a manner that is based on distributing the holdings among the following style boxes:
• Small Cap Growth
• Small Cap Value
• Mid Cap Growth
• Mid Cap Value
• Large Cap Growth
• Large Cap Value
This Folio may also include a Real Estate Investment Trust (“REIT”) component. The allocations
will shift over time and given the passive nature of this Folio it could be a year or more before
any changes are made.
ADVANTAGE TRADING
This Folio is an actively managed portfolio of primarily US Equities; however it can contain some
foreign securities if they are traded on a US exchange (typically in the form of an American
Deposit Receipt (“ADR”)). This Folio Places additional consideration on the technical
characteristics of a stock to select and determine when to purchase and sell stocks from a pre-
screened list of securities with quantitative criteria which fall into an acceptable range. This
strategy looks for a wide range of opportunities and does not necessarily limit itself to
fundamental data.
ADVANTAGE LEADERS
This Folio is an actively managed portfolio of primarily US Equities; however it can contain some
foreign securities if they are traded on a US exchange (typically in the form of an American
Deposit Receipt (“ADR”)). This Folio uses an investment screen in search of companies with
strong margins and consensus in earnings estimates along with acceptable measures of
profitability. Selection of securities will take into consideration valuation, momentum and other
quantitative criteria falling into an acceptable range.
STRATEGIC EQUITY US
This Folio is an actively managed portfolio of primarily US Equities; however it can contain some
foreign securities if they are traded on a US exchange (typically in the form of an American
Deposit Receipt (“ADR”)). This Folio is invested using a quantitative ranking process and will
attempt to limit excessive concentrations in any given sector as deemed appropriate by Advisor.
This Folio will include the use of valuation and momentum factors. Valuation factors will include
both company intrinsic and relative valuation considerations. Momentum factors will
incorporate analyst earning revisions as well as a price momentum model. Momentum is used
in addition to valuation because certain securities could remain undervalued for extended
periods of time and adding momentum can assist with timing of selections. The valuation and
momentum-based models have historically reflected lower correlation to each other over time
and thereby the ability to reduce volatility.
FOCUS LEADERS
This Folio uses domestic ETFs to focus in certain sectors, and stock types and styles based on
momentum and technical indicators. This Folio will focus on selected areas of the market and
may also invest in ETFs focusing in commodities, currencies as well as target outcome (among
others). Allocations also consider volatility and potential risks as well in the current market
environment.
FOUNDATION EQUITY INTERNATIONAL
This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature.
The ETFs covers the various markets around the world and will include exposure to developed as
well as emerging countries.
STRATEGIC EQUITY INTERNATIONAL
This Folio uses foreign ETFs to focus in certain geographical areas of the world based primarily on
momentum and technical considerations. It may invest in individual country ETFs, or broader
geographical areas. Allocations also consider volatility and potential risks as well in the current
market environment.
ULTRA-SMALL AGGRESSIVE
The Ultra- Small Aggressive Portfolio uses three broad ETFs to provide US and International Equity
exposure as well as fixed income exposure. This portfolio is used for smaller accounts as deemed
appropriate by advisor.
ULTRA-SMALL MODERATE
The Ultra-Small Moderate Portfolio uses three broad ETFs to provide US and International Equity
exposure as well as fixed income exposure. This portfolio is used for smaller accounts as deemed
appropriate by advisor.
ULTRA-SMALL CONSERVATIVE
The Ultra-Small Conservative Portfolio uses three broad ETFs to provide US and International
Equity exposure as well as fixed income exposure. This portfolio is used for smaller accounts as
deemed appropriate by advisor.
A security may be held in multiple Folios and may be bought/sold at different times in those
Folios based on considerations for the overall portfolio.
Although our FolioAdvantage strategies incorporate the use of quantitative rankings and
technical considerations to assist in the selection of securities, investment manager judgment
may be used in conjunction with the use of external research to refine the investment selections
and the timing on executing specific buy and sell trades.
iFocus Models
iFocus is a multi-strategy and is based on screening concepts of known successful market
professionals and our own quantitative rankings overlaid for a portion of the portfolio that uses
individual stocks and a core and passive component made up of exchange traded funds for
diversification. iFocus models are managed at “GSCS”. Like the FolioAdvantage Models, the
Planner may allocate among several Folios as part of an allocation described below.
Standard iFocus Model allocations include:
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash
Folios used in iFocus Model allocations include:
iFocus Fixed Income
This Folio uses fixed income ETFs to create a core diversified portfolio of taxable fixed income.
The objective is to match or outperform the Barclays Aggregate Bond Index on a risk adjusted
basis. This portfolio is passive in nature; however it is reviewed at least annually to consider
changes in the yield curve and reallocate between short, intermediate and long maturities when
appropriate. It also may include corporate general and high yield bonds as well as inflation
protected treasury bonds, when appropriate.
iFocus US Equities
This Folio uses ETFs to construct a core portfolio that is diversified and passive in nature. The
ETFs used are in various categories attempting to cover the US market and are allocated in a
manner based on distributing the holdings among the following style boxes:
• Small Cap Growth
• Small Cap Value
• Mid Cap Growth
• Mid Cap Value
• Large Cap Growth
• Large Cap Value
The allocations will shift over time and given the passive nature of this Folio it could be a year or
more before any changes are made.
iFocus International
This Folio uses ETFs to construct a core portfolio that is well diversified and passive in nature.
The ETFs cover the various markets around the world and will include exposure to developed as
well as emerging countries.
iFocus Market Pros
This Folio uses individual equities based on screening concepts from well-known market
professionals and third-party research. From this initial screening, we apply our own set of
additional criteria and rankings to select the securities to be used in this Folio.
A Multi-Strategy Allocation is also available and uses a blend of FolioAdvantage folio components
as well as the iFocus Market Pro folio strategy. The aggressive allocation under the Multi-
Strategy uses 95% equities and 5% fixed income.
Although our iFocus strategies utilize quantitative rankings and technical considerations to select
securities, investment advisor judgment may apply along with the use of external or other
research to refine the investment selections and the timing on executing specific buy and sell
trades.
Schwab Management Models
The Standard Management Models include:
• Strategic Model
• Tactical Model
• Tactical + Quant Model
Standard Allocations:
• Ultra Conservative 40/60: 40% Equities - 60% Fixed Income & Cash
• Conservative 50/50: 50% Equities - 50% Fixed Income & Cash
• Moderate Conservative 55/45: 55% Equities - 45% Fixed Income & Cash
• Moderate Conservative 60/40: 60% Equities - 40% Fixed Income & Cash
• Moderate 65/35: 65% Equities - 35% Fixed Income & Cash
• Moderate 70/30: 70% Equities - 30% Fixed Income & Cash
• Moderate Aggressive 80/20: 80% Equities - 20% Fixed Income & Cash
• Aggressive 90/10: 90% Equities - 10% Fixed Income & Cash
The Strategic Model
Uses ETFs for core diversification among fixed income, small/mid/large cap stocks, and
international equities. The models are long-term strategic in nature and have very low turnover.
They can remain static for extended periods of time except for rebalancing that may occur as
determined by the specific needs of the client and the tax implications for the account.
The Tactical Model
Uses ETFs with diversification across fixed income, small/mid/large cap stocks and international
equities. The model will be allocated over time in different ETFs to gain varying exposures to
various areas of the markets by emphasizing factors such as value or growth primarily using
technical and momentum considerations. The objective is to emphasize areas that are
considered to be performing well in a given market environment and attempt to reduce risks
when warranted by using lower volatility ETFs as an example.
Tactical + Quant Management Model
Uses both ETFs and individual equities in areas of Small Cap, Mid Cap and Large Cap as an actively
managed component. It incorporates the Tactical Model in addition to using individual equities.
The model uses quantitative rankings to select stocks. Valuation and momentum considerations
are part of the quantitative rankings. Stock selections are periodically reviewed and substitutions
are made when necessary. Value judgment may apply along with the use of external or other
research to refine the investment selections and the timing on executing specific buy and sell
trades.
The Strategic, Tactical and Tactical + Quant Management Models are managed at Charles Schwab
(“Schwab”). See Item 12 (Brokerage Practices) below for information related to Schwab.
For taxable accounts, we may at our discretion defer or limit trading and we may temporarily
assign these accounts to models that have the potential to limit the tax impact of trades in these
accounts.
Schwab Institutional Intelligent Portfolio Platform
IFS occasionally uses the platform and tools made available by Schwab under their Institutional
Intelligent Portfolio Platform for the creation and management of custom portfolio models.
Charles Schwab makes this platform available at no additional cost except a requirement that
4% of the portfolio be allocated in cash.
Managed Funds Portfolio
Managed Funds Portfolio Models use mutual fund selections in up to thirteen categories to
allocate a Client portfolio. Custom allocations are created by IFS relative to the Client’s
investment objectives and risk tolerances. At the discretion of IFS, rebalancing is performed to
bring allocations back into balance when suitable and appropriate for a particular Client. During
rebalancing, mutual fund substitutions may be performed in some of the mutual fund categories.
Mutual fund selections are based on reviewing performance data over various time frames, price
momentum, return consistency, risk characteristics, ratings, fund rankings and expenses.
Categories are defined based on Morningstar classification of mutual fund objectives. The
following categories are available:
• Aggressive Growth
• Growth
•
Growth and Income
• International Equity
• Government Bonds - Short Term (Duration 0-3 years)
• Government Bonds - Intermediate Term (Duration 3-7 years)
• Government Bonds - Long Term (Duration 7+ years)
• Municipal Bonds - Short Term (Duration 0-3 years)
• Municipal Bonds - Intermediate Term (Duration 3-7 years)
• Municipal Bonds - Long Term (Duration 7+ years)
• Corporate Bonds - Investment Grade (Duration - Varied)
• Corporate Bonds - High Yield (Duration - Varied)
• International Bonds (Duration - Varied)
• Cash/Money Market
Communications and updating of information
To ensure that our initial determination of an appropriate portfolio remains suitable and that the
account continues to be managed in a manner consistent with the Client’s financial
circumstances, we will:
Send quarterly written reminders to each Client requesting any updated information regarding
changes in the Client’s financial situation and investment objectives;
Contact each participating Client annually to determine whether there have been any changes in
the Client’s financial situation or investment objectives, and whether the Client wishes to impose
investment restrictions or modify existing restrictions and always be available to consult with the
client when requested.
FINANCIAL PLANNING
We also provide financial planning services. Financial planning is an evaluation of a Client’s
current and future financial situation by using currently known variables to analyze future cash
flows, asset values and withdrawal plans. Through the financial planning process, all questions,
information, and analysis are considered as they impact and are impacted by the entire financial
and life situation of the Client. Clients purchasing this service receive a report which provides the
Client with a general financial overview designed to assist the Client achieve his or her financial
goals and objectives.
In general, the financial plan may address any or all of the following areas:
Personal: The review of family records, budgeting, personal liability, estate information and
financial goals where applicable.
Tax and Cash Flow: The analysis of the Client’s income tax and spending and planning for past,
current and future years.
Investments: The analysis of investment alternatives in the Client’s portfolio.
Insurance: The generic review of existing policies and possible recommendation that the Client
discuss additional coverage options for life, health, disability, long-term care, liability, home and
automobile with a licensed insurance agent.
Retirement: The analysis of current strategies and investment plans to help the Client achieve his
or her retirement goals.
Death and Disability: The review of the Client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income.
Estate: Assist the Client and may recommend third party professionals to help assess and develop
long-term strategies, including as appropriate, living trusts, wills, estate tax, powers of attorney,
asset protection plans, long term care, Medicaid, and elder law.
The gathering of necessary information through personal interviews. Information gathered
includes the Client’s current financial status, tax status, future goals, return objectives and
attitudes towards risk. We carefully review documents supplied by the Client and advise
accordingly. Should the Client choose to implement the recommendations contained in the plan,
we suggest the Client work closely with his/her attorney, accountant, insurance agent, and/or
financial planner. Implementation of financial plan recommendations is entirely at the Client’s
discretion.
We may also provide general non-securities advice on topics that may include tax and budgetary
planning, estate planning and business planning.
PUBLICATION OF PERIODICALS
We publish a market commentary providing general information on various financial topics
including, but not limited to, estate and retirement planning, market trends, etc. No specific
investment recommendations are provided in these commentaries and the information provided
does not purport to meet the objectives or needs of any individual. This is distributed free of
charge to our advisory Clients and published on our website.
CONSULTING SERVICES
Clients may also receive investment advice on a more focused basis. This may include advice on
only an isolated area(s) of concern such as estate planning, retirement planning, or any other
specific topic. We also provide specific consultation and administrative services regarding
investment and financial concerns of the Client. Consulting recommendations are not limited to
any specific product or service offered by a broker-dealer or insurance company. All
recommendations are of a generic nature.
RETIREMENT PLAN SERVICES
IFS offers participant directed 401(k) plans with Vanguard Retirement Services. We provide
advisory services and participant education services. Our advisory services are tailored to the
needs of the client organization and include assistance with the selection of investment options
for the plan as well as making ourselves available to participants for guidance on their account,
investment selection and asset allocation decisions and other financial planning related matters.
Compensation for our services are through a fully disclosed advisory fee negotiated at the onset
of the relationship.
MISCELLANEOUS
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services:
To the extent specifically requested, Ifrah will generally provide planning and consulting services
regarding non-investment related matters, such as tax and estate planning, insurance, etc.
inclusive of its advisory fee set forth at Item 5 below (limited exceptions may occur based upon
assets under management, advanced planning needs, special projects, etc. for which Firm may
charge a mutually agreeable additional fee and/or require a stand-alone financial planning
engagement). Please Note: Ifrah does not serve as an attorney, accountant, or insurance agent,
and no portion of our services should be construed as same. Accordingly, Ifrah does not prepare
estate planning or any other legal documents, tax returns, or sell insurance products. To the
extent requested by a client, we may recommend the services of other professionals for non-
investment implementation purpose (i.e. attorneys, accountants, insurance, etc.). Please Note:
If the client engages any recommended unaffiliated professional, and a dispute arises thereafter
relative to such engagement, the client agrees to seek recourse exclusively from and against the
engaged professional.
Client Obligations:
In performing its services, Ifrah shall not be required to verify any information received from
the client or from the client’s other professionals and is expressly authorized to rely thereon.
Moreover, each client is advised that it remains his/her/its responsibility to promptly notify
Ifrah if there is ever any change in his/her/its financial situation or investment objectives for the
purpose of reviewing/evaluating/revising Ifrah’s previous recommendations and/or services.
Retirement Rollovers-Potential for Conflict of Interest:
A client or prospective client leaving an employer typically has four options regarding an existing
retirement plan (and may engage in a combination of these options): (i) leave the money in the
former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one
is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”),
or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse
tax consequences). If Ifrah recommends that a client roll over their retirement plan assets into
an account to be managed by Ifrah, such a recommendation creates a conflict of interest if Ifrah
will earn new (or increase its current) compensation as a result of the rollover. When acting in
such capacity, Ifrah serves as a fiduciary under the Employee Retirement Income Security Act
(ERISA), or the Internal Revenue Code, or both. No client is under any obligation to roll over
retirement plan assets to an account managed by Ifrah. Ifrah’s Chief Compliance Officer, Patrick
Ifrah, remains available to address any questions that a client or prospective client may have
regarding the potential for conflict of interest presented by such rollover recommendation.
Clients can place reasonable restrictions on the types of investments to be held in their account.
Restrictions must be provided to us in writing.
Separate Account Managers:
Ifrah may allocate a portion of a client’s investment assets among unaffiliated independent
investment managers (per the terms of a sub-advisory agreement between Ifrah and the
manager) in accordance with the client’s designated investment objective(s). In such situations,
the Independent Manager[s] shall have day-to- day responsibility for the active discretionary
management of the allocated assets. Ifrah shall continue to render investment supervisory
services to the client relative to the ongoing monitoring and review of account performance,
asset allocation and client investment objectives. Factors that Ifrah shall consider in
recommending Independent Manager[s] include the client’s designated investment objective(s),
management style, performance, reputation, financial strength, reporting, pricing, and research.
Please Note: The investment management fee charged by the separate account manager is
separate from, and in addition to, Ifrah’s advisory fee as set forth in the fee schedule at Item 5
below.
Custodian Charges-Additional Fees:
As discussed below at 12 below, when requested to recommend a broker-dealer/custodian for
client accounts, Ifrah generally recommends that Schwab and/or “GSCS” serve as the broker-
dealer/custodian for client investment management assets. Broker-dealers charge transaction
fees for effecting securities transactions. In addition to Ifrah’s investment advisory fee referenced
in Item 5 below, the client will also incur transaction fees to purchase securities for the client’s
account (i.e., mutual funds, exchange traded funds, and individual equity and fixed income
securities, including those purchased by an underlying Independent Manager discussed above.
See discussion below regarding transaction based vs. asset-based pricing. ANY QUESTIONS:
Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address any questions that a
client or prospective client may have regarding the above.
Asset-Based Pricing Arrangements and Limitations:
Ifrah generally recommends that clients enter into an “Asset-Based” pricing agreement with the
account broker-dealer/custodian. Under an asset-based pricing arrangement, the amount that
a client will pay the custodian for account commission/transaction fees is based upon a
percentage (%) of the market value of the account, generally expressed in basis points and/or a
percentage. One basis point is equal to one one-hundredth of one percent (1/100th of 1%, or
0.01% (0.0001). Generally, the applicable fixed percentage fee decreases as the account value
increases. This differs from transaction-based pricing, which assesses a separate
commission/transaction fee against the account for each account transaction. Account
investment decisions are driven by security selection and anticipated market conditions and not
the amount of transaction fees payable by you to the account custodian. Under either the asset-
based or transaction-based pricing scenario, the fees charged by the respective broker-
dealer/custodian are separate from, and in addition to, the advisory fee payable by the client to
Ifrah per Item 5 below. Ifrah does not receive any portion of the asset-based transaction fees
payable by you to the account custodian. We continue to believe that our clients can benefit
from an asset-based pricing arrangement. You are under no obligation to enter into an asset –
based arrangement, and, if you do, you can request at any time to switch from asset-based
pricing to transactions-based pricing, However, there can be no assurance that the volume of
transactions will be consistent from year-to-year given changes in market events and security
selection. Thus, given the variances in trading volume, any decision by you to switch to
transaction-based pricing could prove to be economically disadvantageous. Ifrah’s Chief
Compliance Officer, Patrick Ifrah, remains available to address any questions that a client or
prospective client may have regarding Asset-Based versus Transaction- Based pricing.
Please Note-Use of Mutual and Exchange Traded Funds:
In addition to Ifrah’s investment advisory fee described below at Item 5, and transaction and/or
custodial fees discussed above, clients will also incur, relative to all mutual fund and exchange
traded fund purchases, charges imposed at the fund level (e.g. management fees and other fund
expenses). ANY QUESTIONS: Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to
address any questions that a client or prospective client may have regarding the above.
ERISA Plan and 401(k) Individual Engagements:
Trustee Directed Plans. Ifrah may be engaged to provide investment advisory services to ERISA
retirement plans, whereby the Firm shall manage Plan assets consistent with the investment
objective designated by the Plan trustees. In such engagements, Ifrah will serve as an investment
fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974
(“ERISA”). Ifrah will generally provide services on an “assets under management” fee basis per
the terms and conditions of an Investment Advisory Agreement between the Plan and the Firm.
Participant Directed Retirement Plans:
Ifrah may also provide investment advisory and consulting services to participant directed
retirement plans per the terms and conditions of a Retirement Plan Services Agreement between
Ifrah and the plan. For such engagements, Ifrah shall assist the Plan sponsor with the selection of
an investment platform from which Plan participants shall make their respective investment
choices (which may include investment strategies devised and managed by Ifrah), and, to the
extent engaged to do so, may also provide corresponding education to assist the participants
with their decision-making process.
Client Retirement Plan Assets:
If requested to do so, Ifrah shall provide investment advisory services relative to the client’s
401(k) plan assets. In such event, Ifrah shall recommend that the client allocate the retirement
account assets among the investment options available on the 401(k) platform. Ifrah shall be
limited to making recommendations regarding the allocation of the assets among the investment
alternatives available through the plan. Ifrah will not receive any communications from the plan
sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Ifrah of any
changes in investment alternatives, restrictions, etc. pertaining to the retirement account.
Portfolio Activity:
Ifrah has a fiduciary duty to provide services consistent with the client’s best interest. As part of
its investment advisory services, Ifrah will review client portfolios on an ongoing basis to
determine if any changes are necessary based upon various factors, including, but not limited to,
investment performance, fund manager tenure, style drift, account additions/withdrawals,
and/or a change in the client’s investment objective. Based upon these factors, there may be
extended periods of time when Ifrah determines that changes to a client’s portfolio are neither
necessary nor prudent. Of course, as indicated below, there can be no assurance that investment
decisions made by Ifrah will be profitable or equal any specific performance level(s).
Investment Risk:
Different types of investments involve varying degrees of risk, and it should not be assumed that
future performance of any specific investment or investment strategy (including the investments
and/or investment strategies recommended or undertaken by Ifrah) will be profitable or equal
any specific performance level(s).
We do not manage Wrap Fee programs.
As of 12/31/2023, we were actively managing approximately $403,648,623 of client assets
broken down per the following: Discretionary basis: $360,688,138 and on a non-discretionary
basis $42,960,485.
ANY QUESTIONS: Ifrah’s Chief Compliance Officer, Patrick Ifrah, remains available to address
any questions that a client may have regarding its prospective engagement and the
corresponding conflict of interest presented by such engagement.