Symphony has been registered as an investment adviser since June 23, 2014, and is wholly owned by
Wallace Carr Burgoyne, Jr. As of March 4, 2024, Symphony had $860,973,427 in assets under
management, all of which is managed on a discretionary basis.
While this brochure describes the business of Symphony, certain sections also discuss the activities of its
Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a
similar status or performing similar functions), employees or any other person who provides investment
advice on Symphony’s behalf and is subject to the Firm’s supervision or control.
Description of the Program
The Symphony Financial wrap program provides its portfolio management services through programs
offered by LPL Financial Services LLC (“LPL Financial”) and Fidelity Investments. All custodians are
independently owned and operated, not affiliated with the Firm. This Brochure discusses those services
offered through wrap fee programs. Please refer to Symphony’s ADV Part 2A Brochure for a description of
non-wrap program services and fees.
A wrap fee is a program which provides clients with the ability to trade in certain investment products
without incurring separate brokerage commissions or transaction charges. A wrap fee program is considered
any arrangement under which clients receive investment advisory services (which may include portfolio
management or advice concerning the selection of other investment advisers) and the execution of client
transactions for a specified fee or fees not based upon transactions in their accounts. Clients must also open
a new securities brokerage account and complete a new account agreement with a custodian mentioned above.
Investment Management Services
Symphony manages client investment portfolios on a discretionary basis through wrap-fee programs
offered by LPL Financial Services LLC (“LPL Financial”) and Fidelity Investments. All custodians are
independently owned and operated and not affiliated with the Firm. Symphony tailors its advisory services
to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios
are managed in a manner consistent with those needs and objectives. Symphony consults with clients on an
initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other
related factors relevant to the management of their portfolios. Clients are advised to promptly notify
Symphony if there are changes in their financial situation or if they wish to place any limitations on the
management of their portfolios. Clients may impose reasonable restrictions or mandates on the management
of their accounts if Symphony determines, in its sole discretion, the conditions will not materially impact
the performance of a management strategy or prove overly burdensome to the Firm’s management efforts.
Within the aforementioned program, Symphony primarily allocates client assets among various mutual
funds, exchange-traded funds (“ETFs”), individual debt and equity securities, options and independent
investment managers (“Independent Managers”) in accordance with their stated investment objectives. In
addition, Symphony may also recommend that certain eligible clients invest in privately placed securities,
which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds).
Where appropriate, the Firm may also provide advice about any type of legacy position or other investment
held in client portfolios. Clients may engage Symphony to manage and/or advise on certain investment
products that are not maintained at their primary custodian, such as variable life insurance and annuity
contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans).
In these situations, Symphony directs or recommends the allocation of client assets among the various
investment options available with the product. These assets are maintained at the underwriting insurance
company or the custodian designated by the product’s provider.
Use of Independent Managers
In some instances, Symphony may deem it appropriate to recommend programs and third-party manager
programs offered by LPL to actively manage a portion of its clients’ assets. The specific terms and
conditions under which a client engages an Independent Manager will be set forth in a separate written
agreement with the designated Independent Manager. In addition to this brochure, clients will also receive
the written disclosure documents of the respective Independent Managers engaged to manage their assets.
The use of Independent Managers are not required to be held at LPL Financial, but are limited to those
managers approved by LPL Financial.
Prior to Symphony rendering any of the foregoing advisory services, clients are required to enter into one
or more written agreements with Symphony setting forth the relevant terms and conditions of the advisory
relationship (the “Advisory Agreement”).
ERISA Fiduciary
Symphony Financial understands and attests that they are an ERISA fiduciary as defined in the Fiduciary
Rule under the Employee Retirement Income Security Act of 1974 and the Internal Revenue Code of 1986.
Symphony Financial adheres to the Impartial Conduct Standards (including the “best interest” standard,
reasonable compensation and no misrepresented information), as a condition for relying upon the Best
Interest Contract Exemption and the Class Exemption for Principal Transactions in Certain Assets Between
Investment Advice Fiduciaries and Employee Benefit Plans and IRA during the transition period from June
9, 2017, through January 1, 2018. This relates to all ERISA accounts including Individual Retirement
Accounts (IRAs).
Symphony Financial does not act as a non-discretionary or discretionary investment manager of the Plan
as defined in Section 3(21) or 3(38) of the Employee Retirement Income Security Act of 1974.
Fees for Participation in the Program
LPL Financial SWM II, and Fidelity Wrap Accounts
Symphony offers investment management services for an annual fee based on the amount of assets under
the Firm’s management. This management fee varies between 0 and 250 basis points (0.00%
– 2.50%), depending upon the size and composition of a client’s portfolio and the type of services rendered.
All fees will be disclosed in the Discretionary Investment Management Agreement.
The Account Fee is based on the value of assets in the account, including cash holdings, and is payable
quarterly in advance. For purposes of calculating Account Fees, LPL calculates the fee rate using the
number of days in the quarter, while Fidelity uses the annual fee divided by 4. The account quarter will be
based on the appropriate fee cycle. Fee cycles are as follows and will be based upon the date in which the
client funds their account(s):
Cycle 1 Cycle 2 Cycle 3
January February March
April May June
July August September
October November December
The Account Fee is due at the beginning of the quarter following account inception and will include the
prorated fee for the initial quarter in addition to the
standard quarterly fee for the upcoming quarter.
Subsequent Account Fee payments are due and will be assessed at the beginning of each quarter based on
the account value as of the close of business on the last business day of the preceding quarter. Additional
deposits and withdrawals will be added or subtracted from portfolio assets on a prorated basis to adjust the
Account Fee at LPL, while Fidelity accounts are not adjusted for auto-deposits and payroll deductions.
Additionally, the Firm will consider householding client assets.
In the event the Advisory Agreement is terminated, the fee for the final billing period is prorated through
the effective date of the termination and the outstanding portion of the fee is charged to the client, as
appropriate.
Fee Comparison
As referenced above, a portion of the fees paid to Symphony are used to cover the securities brokerage
commissions and transactional costs attributed to the management of its clients’ portfolios.
Services provided through the Program may cost clients more or less than purchasing these services
separately. The number of transactions made in clients’ accounts, as well as the commissions charged for
each transaction, determines the relative cost of the Program versus paying for execution on a per
transaction basis and paying a separate fee for advisory services. Fees paid for the Program may also be
higher or lower than fees charged by other sponsors of comparable investment advisory programs.
Fee Discretion
Symphony, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing/legacy client relationship, account retention
and pro bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to Symphony, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions.
These additional charges may include, fees attributable to alternative assets, reporting charges, margin costs,
charges imposed directly by a mutual fund or ETF in a client’s account, as disclosed in the fund’s prospectus
(e.g., fund Program Fees and other fund expenses), fees and commission for assets not held with the Firm’s
custodians (such as 401(k) or 529 plan assets), deferred sales charges, odd-lot differentials, transfer taxes,
wire transfer and electronic fund fees. The fee charged by Independent Managers are paid by a portion of
the client fee and is not a separate charge to the client.
Direct Fee Debit
Clients generally provide Symphony with the authority to directly debit their accounts for payment of the
investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts,
from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients
not less than quarterly detailing all account transactions, including any amounts paid to Symphony.
Alternatively, clients may elect to have Symphony send a separate invoice for direct payment.
PayPal
Under certain circumstances the Adviser will allow the client to submit payment via PayPal. In this situation
we will submit an invoice to the client’s address of record or via electronic mail and the client will submit
payment via PayPal link accessible from the electronic invoice or our website; http://www.4-sf.com/. Fees
are due and payable upon receipt of our invoice.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to Symphony’s right
to terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account. Clients
may withdraw account assets on notice to Symphony, subject to the usual and customary securities
settlement procedures. However, Symphony designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. Symphony may consult
with its clients about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund
level (e.g., contingent deferred sales charge) and/or tax ramifications.
Use of Margin
Symphony may be authorized to use margin in the management of the client’s investment portfolio. In these
cases, the fee payable will be assessed net of margin such that the market value of the client’s account and
corresponding fee payable by the client to Symphony will not be increased.
Commissions and Sales Charges for Recommendations of Securities
Clients can engage certain persons associated with Symphony to render securities brokerage services under
a separate commission-based arrangement. Clients are under no obligation to engage such persons and may
choose brokers or agents not affiliated with Symphony.
Under this arrangement, the Firm’s Supervised Persons, in their individual capacities as registered
representatives of LPL Financial, may provide securities brokerage services and implement securities
transactions under a separate commission-based arrangement. Supervised Persons may be entitled to a
portion of the brokerage commissions paid to LPL Financial, as well as a share of any ongoing distribution
or service (trail) fees from the sale of mutual funds. Symphony may also recommend no-load or load-
waived funds, where no sales charges are assessed. Prior to effecting any transactions, clients are required
to enter into a separate account agreement with LPL Financial.
A conflict of interest exists to the extent that Symphony recommends the purchase or sale of securities
where its Supervised Persons received commissions or other additional compensation as a result of the Firm’s
recommendation over previous 12 months, prior to entering into the advisory agreement. The Firm has
procedures in place to ensure that any recommendations made by such Supervised Persons are in the best
interest of clients. For certain accounts covered by the Employee Retirement Income Security Act of 1974
(“ERISA”) and such others that Symphony, in its sole discretion, deems appropriate, Symphony may
provide its investment advisory services on a fee-offset basis. In this scenario, Symphony may offset its
fees by an amount equal to the aggregate commissions earned by the Firm’s Supervised Persons in their
individual capacities as registered representatives of LPL Financial. All 12b-1 fees are retained by the
custodian and do not offset any advisory fees received by the Firm.
Compensation for Recommending the Program
The advisor recommending the wrap fee program to the client will receive compensation as a result of the
client’s participation in the program. Symphony has no internal arrangements in place whereby persons
recommending the Program are entitled to receive additional compensation as a result of clients’ participation.