Sunbelt Securities, Inc. (“SUNBELT or “Sunbelt”) was formed in 1995 as a corporation
organized under the laws of the State of Texas. Sunbelt is not a publicly traded corporation,
and no one owns 25% or more of the company.
Sunbelt is registered as a broker/dealer and as an investment adviser with the U.S. Securities
and Exchange Commission (“SEC”). Sunbelt is a member of the Financial Industry
Regulatory Authority (“FINRA”), the Municipal Securities Rulemaking Board (“MSRB”) and the
Securities Investor Protection Corporation (“SIPC”). Registered Persons affiliated with
Sunbelt Securities, Inc. recommend certain securities for which they receive a commission,
markup or markdown. Registered Persons affiliated with Sunbelt Securities, Inc., who offer
various advisory services for which they receive a fee are called Investment Advisory
Representatives (“IARs”). For purposes of this document, Sunbelt Securities, Inc.
(“Sunbelt”) refers to its registration as a Registered Investment Adviser. The advisory
services offered through Sunbelt Securities, Inc. are described in this Disclosure Brochure.
The following paragraphs describe our services and fees. Refer to the description of each
investment advisory service listed below for information on how we tailor our advisory
services to your individual needs. As used in this brochure, the words "we," "our," and "us"
refer to Sunbelt Securities, Inc. and the words "you," "your," and "client" refer to you as either
a client or prospective client of our firm. "IAR" refers to your financial professional (also
known as an investment adviser representative) in their role of providing investment advice
on behalf of SUNBELT.
Sunbelt’s IARs may offer the following services to their clients:
A. Sunbelt Rep Directed Wrap Fee Program;
B. Financial Planning and Non-Asset Management Services; and
C. Recommendation of Third-party Money Managers/Sub-Advisors.
Below is specific information about each service:
The Sunbelt RD Wrap Fee Program
The Sunbelt Rep Directed Wrap Fee Program (“Sunbelt RD”) is a wrap program designed to
provide investment advisory services to the client by a Sunbelt IAR through an Investment
Advisory Agreement - Wrap (“Agreement”) and to assist in the determination of an asset
allocation utilizing selected securities designed to meet the client’s individual investment
needs and goals. Generally, the client must invest a minimum of $25,000.00 to open a
Sunbelt RD account, however this requirement can be waived at the discretion of Sunbelt.
Through Sunbelt RD, Sunbelt’s IARs provide discretionary portfolio management services
where the investment advice provided is tailored to meet the needs and investment
objectives of the client. At the inception of the relationship, the IAR will gather relevant
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information from the client such as the client’s risk tolerance, investment objectives and
other relevant information and will recommend an initial portfolio to the client.
Pursuant to a grant of discretionary authority, subject to any written guidelines or restrictions
the client may set, the IAR executes transactions without further approval from the client.
Once the portfolio is constructed, the IAR monitors the account on a continuous basis and
re-balances the portfolio as changes in market conditions and client circumstances may
require.
A wrap pricing structure allows the client to pay an inclusive fee for account management,
brokerage, and clearance. Sunbelt RD accounts are not managed differently from non-wrap
fee accounts. A portion of the fee is paid to the IAR and to Sunbelt for the respective services
of each. clients should consider that, depending upon the level of the wrap fee charges, the
amount of portfolio activity in their accounts, the value of services that are provided under
the investment program and other factors, the wrap fee may or may not exceed the aggregate
cost of services if they were to be provided separately. Generally, wrap programs are
relatively less expensive for actively traded accounts; however, wrap programs may result in
higher overall costs to the client in accounts that experience infrequent trading activity.
Clients opening a Sunbelt RD should receive a copy of the Sunbelt RD Wrap Fee Program
Brochure. The Sunbelt RD Wrap Fee Program Brochure contains additional information
concerning wrap programs in general and the Sunbelt RD program in specific, including
disclosure of fees payable by the client.
Financial Planning and Non-Asset Management Services Program
Sunbelt’s Financial Planning and Non-Asset Management Services Program (“Financial
Planning Services”) do not involve the active management of client accounts, but instead
focus on a client’s overall financial situation. Financial planning typically involves helping
individuals determine and set long-term financial goals, through investments, tax planning,
asset allocation, risk management, retirement planning and other areas.
Upon execution of the Financial Planning Agreement, the client’s IAR will provide financial
planning services in the form of a written financial plan. Area(s) that may be addressed
include, but are not limited to:
Cash Flow Analysis;
College Planning;
Tax Planning;
Liability Review;
Retirement Planning;
Insurance Review; and/or
Estate Planning
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Following are important items that Financial Planning Services clients should be aware of:
The U.S. Department of Labor uses the term “fiduciary” to describe persons who
provide advice and/or services to Employee Retirement Income Security Act (“ERISA”)
qualified retirement plans. Persons or organizations requesting these types of
services are strongly advised to consult with attorneys and tax advisors who are
familiar with ERISA regulations that affect retirement accounts to ensure that the
retirement plan follows all applicable regulations. While Sunbelt’s IARs may offer
some advice, they may not act as an administrator of the retirement plan itself.
When Sunbelt IARs advise clients on securities and/or accounts which are not held at
Sunbelt, the IAR offers advice only. The accounts are not discretionary—the IAR will
not be able to make any changes within the account(s). Clients may request that their
chosen IAR advise them on asset allocation within those accounts. As Sunbelt and
IAR are unable to view the accounts directly, the client must provide the IAR with
updated account statements, listings of available choices within the account and the
amount and regularity of contributions. In these situations, the IAR will provide the
client(s) with allocation advice; however, the client is responsible for completing the
transactions within the account. The client may not give usernames and passwords
to the IAR for accounts.
Financial Planning Services offered by IARs should not be considered comprehensive
and clients are advised to consult with other professionals including but not limited to
accountants, tax advisors, attorneys, insurance professionals, etc. for a more
comprehensive review and evaluation of the effects of advice offered by the IAR on a
client’s particular situation.
The services provided through Financial Planning Services are based on the client’s
financial situation at the time and are based on the financial information disclosed by
the client to IAR. clients are advised that certain assumptions may be made with
respect to interest and inflation rates and the use of past trends and performance of
the market and economy. Past performance is in no way an indication of future
performance. Sunbelt cannot offer any guarantees or promises that the
client’s
financial goals and objectives will be met. As the client’s financial situation, goals,
objectives or needs change, the client should notify the IAR promptly.
Recommendation of Third-party Money Manager/Sub-Advisor
After gathering information about a client’s financial situation, investment objectives, risk
tolerance and other data, an IAR of Sunbelt may assist the client in selecting a particular
Third-party Money Manager/Sub-Advisor. IARs may utilize several factors in determining a
prudent Third-party Money Manager/Sub-Advisor including but not limited to performance,
investment objectives, fees and methods of analysis, and comparing those factors to the
client’s goals and objectives (determining risk tolerance and investment styles).
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Sunbelt’s IARs may refer a client to one of various Third-party Money Managers/Sub-Advisors
for asset management services. Third-party Money Manager/Sub-Advisors may have differed
minimum account requirements and a variety of fee ranges. All securities transactions are
decided upon and executed by the Third-party Money Manager/Sub-Advisor. IARs may
contact the client periodically and may review the client’s financial situation, objectives, and
restrictions and communicate information to the Third-party Money Manager/Sub-Advisor;
and may assist the client in understanding and evaluating the services provided by the Third-
party Money Manager/Sub-Advisor.
Clients who are referred to a Third-party Money Manager/Sub-Advisor are directed to the
disclosure document for the Third-party Money Manager/Sub-Advisor and any separate
written agreement(s) between the client and the Third-party Money Manager/Sub-Advisor for
more complete information regarding the terms and conditions of the client’s relationship
with the Third-party Money Manager/Sub-Advisor.
Each Third-party Money Manager/Sub-Advisor maintains its own separate execution, clearing
and custodial relationships.
When clients are referred to Third-party Money Manager/Sub-Advisors, the IAR does not
manage the client’s assets. The assets are directly managed by the selected Third-party
Money Manager/Sub-Advisor.
Other Important Information Regarding these Programs
Types of Investments
Sunbelt IARs may advise you on various types of investments based on your stated goals and
objectives including, but not limited to, equities, fixed income, mutual funds, options,
alternative investments and variable annuities. We may also provide advice on any type of
investment held in your portfolio at the inception of our advisory relationship. Refer to Item 8,
Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures
on this topic.
Since our investment strategies and advice are based on each client’s specific financial
situation, the investment advice we provide to you may be different or conflicting with the
advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s
Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are
providing the following acknowledgment to you.
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When we provide investment advice to you regarding your retirement plan account or
individual retirement account, we are fiduciaries within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are
laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest
and not put our interest ahead of yours. Under this special rule’s provisions, we must:
Meet a professional standard of care when making investment
recommendations (give prudent advice);
Never put our financial interests ahead of yours when making
recommendations (give loyal advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice
that is in your best interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an
account that we manage or provide investment advice, because the assets increase our
assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend
a rollover when we believe it is in your best interest.
Changes In the client's Circumstances
Clients are advised that changes in your financial situation, investment objectives, tolerance
for risk, or investment time horizon may cause the program or strategy selected by the client
to no longer be suitable. In the event of any change, the client should contact their IAR or
SUNBELT promptly in order to identify another program or strategy, if required.
Negotiability of Program Fees, Account Minimums, & Other Terms
For all services, we have the discretion to negotiate our fees, minimum account size,
minimum annual fees, and other terms of each client’s relationship with us, and to negotiate
alternative fees, minimums, or other terms on a client-by-client basis.
When considering and negotiating these matters, we usually consider, among other factors,
the dollar amount of assets to be placed under management by the client and related
accounts, anticipated future revenues and anticipated future additional assets or accounts
from the client or related persons, and other existing or anticipated relationships. We may
elect, in our discretion, to aggregate related client accounts for the purpose of achieving the
minimum account size requirements and determining annualized fees. Waivers, discounts or
more favorable terms not generally available to other clients may be offered to family
members and friends of our current and former employees and affiliates. The specific terms
of each client’s advisory relationship will be agreed upon in writing by SUNBELT and the
client.
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There are risks associated with any investment or advisory service. There is no guarantee of
success for any particular investment or strategy, and it is possible that some, or all, of your
principal could be lost. Past performance is not a guarantee of future performance; You
invest at their own risk.
Tax implications are a critical component of any investment strategy. Therefore, depending
on the strategy that you choose to implement, it is possible that any trading activity could
result in a taxable event and lower investment return. Investments may have tax or legal
consequences, so you should contact your own tax professional and attorney to answer your
questions about specific situations or needs.
When investing in mutual funds, variable annuities and alternative investments, you are strongly
encouraged to review the applicable prospectus. Mutual funds, variable annuities and certain
variable annuity riders may impose certain restrictions on the frequency, timing and dollar amount of
transactions and may impose penalty fees based upon short-term trading patterns. These restrictions
may impact the services provided by the IAR or a Third-party Money Manager/Sub-Advisor.
As of December 31st, 2023, the total amount of assets managed by Sunbelt’s IARs on a discretionary
basis is $1,907,674 and $0 on a non-discretionary basis. Discretion means that an IAR does not need
prior permission to conduct transactions or render advisory services in client accounts.