This Form ADV Part 2A Disclosure Brochure (“Brochure”) relates to StoneX Advisors Inc.(“SAI”, “we”, “us”, or “our”).
StoneX Advisors Inc.Disclosure Brochure – December 19, 2023Page | 3
StoneX Advisors Inc. is registered as an investment adviser with the Securities and Exchange Commission (“SEC”) and has been providing
financial services since February 2015. In June of 2022, an SEC filing was made to add an Other Name, StoneX Wealth Management, to be used
for co-branding by both StoneX Securities Inc. (“SSI”), an SEC-registered broker-dealer and member FINRA/SIPC and StoneX Advisors Inc.
(collectively “StoneX Wealth Management” or “SAWM”). In December of 2023, the board of directors approved a name change for SA Stone
Investment Advisors Inc., to StoneX Advisors Inc., to more closely align the legal entity’s name with that of the parent company, StoneX Group
Inc. We will continue to market our services through SA Stone Investment Advisors Inc., StoneX Wealth Management, StoneX Advisors Inc. and
certain Financial Advisor’s DBA names as more fully described below.
SAI is wholly owned by StoneX Group Inc., a publicly held financial holding company (NASDAQ: SNEX), and affiliated through common
ownership with SSI, an “introducing broker-dealer”, and StoneX Financial Inc. (“SFI”), a “clearing broker-dealer”, each of which is a member of
the Financial Industry Regulatory Authority (“FINRA”) and registered with the SEC as a broker-dealer. SFI is also a Futures Commission Merchant
registered with the Commodity Futures Trading Commission and a member of the National Futures Association. SEC registration does not
imply a certain level of skill or training.
SAI’s business model focuses on providing advisory platforms, support systems and services to independent Investment Advisor
Representatives (known as “Independent Financial Advisors”) and to its employee, in-house advisor group, the Private Client Group (“PCG”).
PCG Financial Advisors and Independent Financial Advisors are collectively referred to as “Financial Advisors.” Financial Advisors then offer
our advisory services through one of our names, as discussed above, or, with respect to Independent Financial Advisors only, through a business
pseudonym (or DBA) which is used by some to build name recognition and promote their independent business. We currently support 68
unique DBA names of our Independent Financial Advisors. SAI is responsible for initial approval, ongoing oversight and supervision of the
advisory services Financial Advisors provide you, regardless of the name under which our services are presented.
We offer discretionary asset management and non-discretionary advisory services as well as planning and consulting services, such as
personalized financial planning and ERISA Plan consulting (to be referred to interchangeably as “services” throughout this Brochure). Your
Financial Advisor may recommend utilizing a single service, multiple services, or none of the services described in this Brochure. Our Financial
Advisors are generally also associated with SSI. Accordingly, he/she may offer you a broad range of financial or insurance products and
brokerage services through SSI in addition to the investment advisory services described in this Brochure. Generally, during initial consultations
with your Financial Advisor, he/she will typically ask a comprehensive series of questions about your priorities and concerns, and/or you will
complete a questionnaire intended to elicit information such as your investment objective, risk tolerance and time horizon. During this
cooperative process, you should notify your Financial Advisor of any additional information relevant to our provision of services to you. Once
your Financial Advisor determines your investment objectives, risk tolerance, time horizon and other relevant factors, he/she will work with
you to determine which of our services is most appropriate for your investment needs. Your Financial Advisor will review your investment
goals, objectives and other parameters with you annually. Between reviews, you should notify your Financial Advisor if there are any changes
to your financial situation or any other information relevant or necessary to assessing your financial situation, investment objectives or risk
tolerance.
Depending on your particular needs, you can choose from among different types of accounts, services, products and levels of service offered
by us and our affiliates and selected 3rd party, unaffiliated providers. These choices have important implications regarding your relationship
with us and/or our affiliates, including our obligations to you, the expenses you incur, and the compensation we receive. You should consider
these factors when deciding which type of account and/or service best suits your needs. Please see the Customer Relationship Summary at the
back of this Brochure for more information.
You should consider the importance and value of ongoing advisory services (including ongoing advice) when comparing options for obtaining
advice or clearing/custodian services (i.e., custody and safekeeping, reporting and trade execution). You should also consider your anticipated
trading activity when selecting between different types of services or accounts and assessing your overall potential cost. In an investment
advisory relationship, you generally pay for ongoing advisory services; whereas in a brokerage relationship, you typically pay only when you
buy or sell securities. If there are prolonged periods of infrequent trading or your portfolio contains significant cash holdings, an advisory
account will probably result in higher overall expenses versus a brokerage account where commissions are paid separately for each transaction.
If you do not need ongoing advice and do not anticipate at least a moderate amount of trading, or if you would rather pay your investment
professional based on each transaction you execute, a brokerage account is likely the right choice for you. There is no long-term commitment
with any investment advisory service offered by SAI, and you can cancel your agreement, with written notice, without penalty at any time
should your needs or objectives change. This information is not intended to address all issues or questions concerning differences between
brokerage and advisory accounts. When considering a fee-based investment advisory service you should understand the different investment
solutions that are available to you. For example, you can decide that you want a brokerage account for certain investments and an advisory
account for others. You should discuss the different account and service options and ask any questions you need answered before investing.
If you have questions about the difference between brokerage and advisory accounts, ask your Financial Advisor or contact SAI’s Compliance
Department at (800) 292-2411.
For more information about your Financial Advisor, you should refer to your Financial Advisor’s Form ADV – Part 2B or Brochure Supplement,
or by going to the SEC’s Investment Adviser Public Disclosure website athttps://www.adviserinfo.sec.gov/. The Brochure Supplement is a
separate document containing information about your Financial Advisor that he/she will provide to you at or before the time you sign an
agreement for services. If you did not receive a Brochure Supplement from your Financial Advisor, you may obtain one by contacting your
Financial Advisor or by requesting one in writing, mailed to our home office address on the cover page of this Brochure or by e-mail to
[email protected].
StoneX Advisors Inc.Disclosure Brochure – December 19, 2023Page | 4
Discretionary Asset Management Services
Our Discretionary Asset Management Services allow us to buy and/or sell securities on your behalf in your securities account(s) (“Advisory
Account”) and/or delegate our authority to do so to 3rd party money managers (“TPMMs”) without first obtaining your approval. You have
the option of imposing reasonable investment restrictions on management of your portfolio, such as forbidding the purchase or sale of certain
securities, industries, sectors or asset classes by providing us with written instructions when you execute your advisory agreement or at any
time thereafter. Such restrictions will be reflected in the investment guidelines or other documentation applicable to your Advisory Account .
We will apply such restrictions based on our internal policies and/or those of our service providers, which may change without notice to you.
Depending upon the clearing/custodian firm you choose, you may be required to open an account with SSI, our affiliated broker-dealer. An
account opened with SSI will be used for clearing/custody services while SAI is providing asset management services. If asset management
services are terminated, your account will remain open as a brokerage account, unless also terminated. Choosing either SFI (our affiliate) or
Pershing Advisor Solutions LLC (“Pershing”) for clearing/custodian services will require you open an SSI account. Conversely, when selecting
Charles Schwab & Co., Inc. (Schwab Advisor Custodial Services, or “Schwab ACS”) you will open your Advisory Account directly with Schwab
ACS acting as a clearing/custodian firm and broker. Please refer to Item 12 and speak with your Financial Advisor for more detailed information
on how SAI evaluates potential custodians and potential conflicts of interest that may impact you. Your Financial Advisor, in his/her discretion,
will determine the asset allocation and manage your portfolio utilizing one, some, or all of the options listed below.
•Advisor as Portfolio Manager(“APM” or “APM Service”): In our APM Service, your Financial Advisor will have broad discretionary
authority to manage your investment portfolio by (1) personally constructing and managing a securities portfolio, or (2) by utilizing
proprietary or TPMM models , or (3) a combination thereof. Because you pay us a single Management Fee (as defined in Item 5) which
covers the cost of our asset management services regardless of how it is achieved and because there are additional costs (borne by your
Financial Advisor) associated with utilizing proprietary or TPMM models, your Financial Advisor has a conflict of interest that incentivizes
him/her not to use proprietary or TPMM models. A wide variety of securities may be utilized by your Financial Advisor or our proprietary
or TPMMs, including, but not limited to: U.S. and foreign stocks, bonds, options, American Depository Receipts, foreign Ordinary Shares,
open-end and closed-end funds, unit investment trusts (“UITs”), real estate investment trust (“REITs”), exchange-traded funds (“ETFs”),
and money market funds. SAI has an incentive to encourage Financial Advisors to recommend our proprietary models, the StoneX Model
Solutions, as the more assets invested in these models the more revenue SAI earns. SAI makes these models available to its Financial
Advisors at no or a reduced cost compared to similar non-proprietary models. Your Financial Advisor has a conflict of interest in utilizing
the StoneX Model Solutions over a TPMM’s models because the added cost of TPMMs’ models reduces the Financial Advisor’s net payout.
SAI has developed and implemented policies and procedures to monitor client Advisory Accounts for adherence to investment objectives
that help mitigate such potential conflicts. The minimum account size is for APM is $50,000. We may waive minimum account sizes in our
discretion.
•StoneX Model Solutions(“StoneX Models”, “StoneX Models Service”): With the StoneX Models Service, your Financial Advisor will select
one or more of our proprietary investment models to implement various investment strategies in your Advisory Account. The models are
constructed using mutual funds, exchange traded funds, individual securities, or any combination thereof, in accordance with each
models’ investment guidelines. We make the StoneX Models available to our Financial Advisors at no or a reduced cost compared to
similar TPMM models. Your Financial Advisor has a conflict of interest in recommending StoneX Models over TPMM models because the
added cost of TPMM models reduce the Financial Advisor’s net payout. We have developed and implemented policies and procedures to
monitor client Advisory Accounts for adherence to investment objectives that help mitigate such potential conflicts. The minimum account
size varies by model type, as follows: $10,000 for StoneX Foundations Model Portfolios; $25,000 for StoneX Model Portfolios, and
American Plus Model Portfolios; and $40,000 for US High Dividend Portfolio and US Growth Portfolio. We may waive minimum account
sizes in our discretion.
•StoneX Select Managers(“StoneX Managers” or “StoneX Managers Service”): With this service your Financial Advisor will construct and
manage a securities portfolio in an Advisory Account you open by choosing and appointing TPMMs to implement various investment
strategies. We will exercise our discretion in selecting the manager(s) of your Advisory Account, and the manager(s) (or an overlay
manager) will have full discretionary authority to buy and/or sell securities in your Advisory Account.
We offer three types of TPMMs: Separate Account Managers, Model Portfolio Providers and Fund Strategists (Please also reference Item
8, Methods of Analysis, Investment Strategies and Risk of Loss, for additional information).
oSeparate Account Managers (“SAMs”) are TPMMs that primarily invest in individual securities (e.g., equity securities and debt
instruments) to create portfolios and fulfill their investment objectives.
oModel Portfolio Providers are similar to SAMs in that they primarily involve investments in individual securities. A Model Portfolio
Provider supplies a model securities portfolio to an overlay manager for implementation. When changes are made to the model, the
Model Portfolio Provider supplies an updated model, and the overlay manager implements the changes.
oFund Strategists are similar to Model Portfolio Providers in that the TPMM provides a model securities portfolio to an overlay
manager. However, Fund Strategists’ portfolios typically consist of “collective investment vehicles” such as mutual funds and ETFs
and do not typically include individual securities such as stocks and bonds.
The minimum investment size varies by manager type but is generally $100,000 for SAMs and Model Portfolio Providers and $10,000 for
Fund Strategists. We may waive minimum account size in our discretion but cannot waive minimum allocation sizes for TPMMs.
StoneX Advisors Inc.Disclosure Brochure – December 19, 2023Page | 5
American Funds F2 Fund-Direct Platform: We have entered
into an agreement with American Funds Service Company (“AFS”) where your
Financial Advisor provides you with asset management/allocation services utilizing individual mutual funds offered by the American Funds
(managed by Capital Group) that AFS makes available to Advisory Accounts opened on their F2 Direct-at-Fund Platform (“the F2
Platform”). The AFS F2 Platform exclusively utilizes the F2 share class of funds which is not the lowest cost share class available from
American Funds. Your Financial Advisor has a conflict of interest in recommending the F2 Platform because it provides an online trading
and reporting interface at no cost to him/her, instead these costs are offset by the internal expenses of the F2 share class (reducing fund
performance). However, the Management Fee for the F2 Platform is fixed and non-negotiable and the maximum fee is significantly less
than the maximum Management Fee permissible for other Discretionary Asset Management Services. Whether use of the F2 Platform is
appropriate for you depends in part upon the comparative costs associated with utilizing lower cost share classes with an alternative
clearing/custodian firm, including the Management Fee your Financial Advisor is willing to accept to manage your assets utilizing an
alternative clearing/custodian firm. Please refer to the section entitled Conflicts of Interest regarding Management Fees in Item 5 (Fees
and Compensation) and discuss your options with your Financial Advisor.
The minimum fund investment is $250 per fund or fund-of-fund. AFS charges a one-time $10 set up fee and a $10 per annum custodial
fee for IRAs and Coverdell ESA accounts.
Annuity Allocation:For certain annuity holders, we offer a Discretionary Asset Management Service where we provide ongoing
investment advice regarding the allocation of the annuity contract’s cash value (within the meaning of section 72(e)(3)(A)(i) of the Internal
Revenue Code). Various minimums apply, depending on the annuity product and provider.
Non-Discretionary Advisory Services1
•Advisor as Financial Consultant(“AFC”): In this non-discretionary investment advisory service, your Financial Advisor provides ongoing
investment advice to you regarding which securities to buy or sell. Because it is a non-discretionary service, no securities will be bought
or sold without your advance approval. You can also make your own investment decisions (within guidelines related to our supervisory
policies and procedures), to be implemented by your Financial Advisor. You and your Financial Advisor can choose from a wide variety of
securities, including, but not limited to, U.S. and foreign stocks, bonds, options, American Depository Receipts, foreign Ordinary Shares,
open-end and closed-end funds, UITs, REITs, ETFs, and money market mutual funds. The minimum account size is $25,000. We may waive
minimum account sizes in our discretion.
•Sub-Advisory and Co-Advisory Relationships: We have relationships with certain TPMMs in which each of us may act in an advisory
capacity to you. In these relationships, we typically determine the suitability of the TPMM’s advisory services for you and act as the
primary point of contact for client communications. In consultation with you, your Financial Advisor will recommend or choose one or
more TPMMs to implement various investment strategies. You will maintain the ability to hire or fire such managers with or without
consultation and/or recommendations from your Financial Advisor. Depending upon the service elected and separate agreements
completed, we may or may not exercise discretionary authority in your Advisory Account. However, the TPMM(s) or an overlay manager
selected will have discretionary authority to buy and/or sell in your Advisory Account. You will either enter into separate agreements with
each of us and the TPMM or a single agreement to which you, the TPMM and we are parties. In these relationships, you pay us and the
TPMM a Management Fee. The amount of the fee is disclosed in the investment advisory agreement(s). TPMMs may establish minimum
account value or other account qualification requirements. Any such requirements will be disclosed in the TPMM’s Form ADV, Part 2A,
Disclosure Brochure, which will be delivered to you before or at the time you enter into the advisory agreement.
•Annuity Allocation:For certain annuity holders, we offer a non-discretionary asset advisory service pursuant to which we provide
ongoing investment advice regarding the allocation of the annuity contract’s cash value (within the meaning of section 72(e)(3)(A)(i) of
the Internal Revenue Code). Various minimums apply, depending on the annuity product or provider.
Low Balance Accounts
Notwithstanding any minimum account sizes provided above (or waivers thereof) for any type of Discretionary Asset Management Services or
Non-Discretionary Advisory Services account, we will, at our discretion, terminate our Advisory Agreement when the value of the account
drops below $5,000.
Other Planning and Consulting Services
Below is a summary description of our Other Planning and Consulting Services:
•Financial Planning: We provide financial planning services through our Financial Advisors’ utilization of approved financial planning tool(s)
(a “Financial Plan”). Financial Advisors undertake a detailed discovery process, which includes a discussion of your financial resources and
projected needs and may require the review of documents as necessary to evaluate your financial circumstances. Generally, this process
seeks information about your current assets, liabilities, income sources and expenditures, current tax status and future objectives,
educational, retirement, and other long-term financial goals, insurance, and estate planning needs. We rely on your care, completeness,
and clarity in responding to this discovery process, as your input will form the factual basis for the Financial Plan. Financial Planning
services represent a one-time plan and not an ongoing engagement for planning advice or to provide you any of our other services.
1Due to the nature of non-discretionary services and accounts, you can impose any investment restriction you chose, as you will have final say on the
investment activity in the account.
StoneX Advisors Inc.Disclosure Brochure – December 19, 2023Page | 6
•Financial Consulting: Based on client requests, our Financial Advisors can offer consulting services at an hourly or fixed rate for various
financial-related matters to address your specific needs and objectives. After an analysis of your current financial situation and goals,
your Financial Advisor will make recommendations to help your achieve those goals. Financial Consulting services represent either a
one-time engagement without ongoing financial advice, or a perpetual, ongoing agreement for ongoing financial consulting advice.
Ongoing Financial Consulting Agreements may be terminated at any time, per the terms of the agreement. Financial Consulting services,
while similar to Financial Planning services listed above, may offer you more focused assistance such as:
oEstate Settlement Assistance
oRetirement Planning
oCharitable Giving Planning
oEducation Expense Planning
oCashflow/Budgeting: Debt Analysis
oInsurance Coverage
oInvestment Analysis
oAsset Allocation Recommendations
•Investment Manager Consulting:We have relationships with TPMMs for whom we make recommendations to our clients if we determine
that the TPMM’s services are suitable for your present needs, we may recommend you utilize their services. You will enter into an
Investment Manager Consulting agreement with us and an investment advisory agreement directly with the TPMM, who will be
responsible for providing ongoing continuous investment advice to you. We will have an obligation to provide ongoing due diligence and
monitoring of the TPMM(s) we recommend to you. You will pay us a fee, which is generally taken directly from the assets in your account.
Our fee is not a portion of the TPMM’s fees it receives for providing asset management services to you. We will provide you with a copy
of the TPMM’s Form ADV, Part 2A, Disclosure Brochure and Privacy Notice at the time we make the recommendation.
•ERISA Consulting:We offer non-discretionary advisory or administrative support services for company retirement plans. These services
are designed to assist plan sponsors of employee benefit plans (“Sponsor” or “Sponsors” as the case may be) and their participants. When
providing any non-discretionary investment advisory services, we will solely be making investment recommendations to the Sponsor, and
the Sponsor retains full discretionary authority or control over assets of the retirement plan. We agree to perform any non-discretionary
investment advisory services to the retirement plan, as a fiduciary, as defined in ERISA Section 3(21)(A)(ii) and will act in good faith and
with the degree of diligence, care and skill that a prudent person rendering similar services would exercise under similar circumstances.
When providing any administrative support services, we may consult with the Sponsor regarding plan governance and committee
education; vendor management and service provider selection and review; investment education; or provide plan participant non-
fiduciary education services. We agree to perform any administrative support services solely in a capacity that would not be considered
a Section 3(38) fiduciary or a Plan Administrator under ERISA.
Promoter Arrangements: We have relationships with certain TPMMs for whom we refer business. If we determine that the TPMM’s
services are suitable for your present needs, we may refer you to them. You will enter into an investment advisory agreement directly
with the TPMM, who will be responsible for providing ongoing continuous investment advice to you. Generally we will receive a portion
of the fee you pay the TPMM, or a dedicated fee charged by the TPMM which is paid to us, for providing services to you, but we will have
no obligation to you to provide continuing and ongoing investment advice. In some such relationships we have committed to the TPMM
to act as an intermediary between you and the TPMM and to seek to gather or update certain information from you periodically. We will
provide you with a copy of the TPMM’s Form ADV, Part 2A, Disclosure Brochure, Privacy Notice and will provide certain required
disclosures, depending upon our agreement with the TPMM, either verbally or through a Promoter’s Disclosure Statement at the time we
make the referral. The required disclosures will, among other things, describe the compensation we receive.
IRA Rollover Recommendations
For purposes of complying with the Department of Labor’s Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable,
we are providing the following acknowledgment to you. 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 of interest with you, 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 Advisory Account or provision of investment advice
to you, because the assets increase our assets under management and, in turn, our Management Fees. As a fiduciary, we only recommend
a rollover when we believe it is in your best interest.
Wrap Accounts
StoneX Advisors Inc.Disclosure Brochure – December 19, 2023Page | 7
Neither SAI nor its Financial Advisors “sponsor” a wrap fee product. However, our Financial Advisors are permitted to offer certain wrap
products sponsored by non‐affiliated wrap sponsors such as SEI Investments Management Corporation (see Relationships with 3rdParty
Advisors in Item 10). Wrap sponsors generally provide a wide range of services related to portfolio accounting, performance analysis and
access to a universe of third-party money managers. The sponsors of these programs will have their own Wrap Brochures which include
any non-transaction related fees that can be assessed to a wrap fee program, which your Financial Advisor will provide. In addition, your
Financial Advisor may choose to offer their services for one fee, and not pass transaction charges or fees ("Transaction Fees”) along to
you. These are not specific products and are available at the discretion of the Financial Advisor.
Accounts are managed similarly whether structured as a wrap account or not. Clients’ portfolio transactions will be executed without
commission or Transaction Fee in a wrap fee arrangement. You are provided investment advice, account management, and portfolio
monitoring for your account under an asset‐based fee arrangement with no separate brokerage commissions or Transaction Fees. For
more details on any formal Wrap Fee Programs, you should review and refer to the specific wrap fee program brochure offered through
the wrap sponsor. The overall costs you incur if you participate in a wrap fee program may be higher or lower than you might incur by
paying transaction costs separately with advisors. To compare the cost of the wrap fee program with non-wrap fee portfolio management
services, you should consider the frequency of trading activity associated with the investment strategies implemented, the brokerage
commissions charged by broker/dealers, and the management fees charged by third-party money managers.
Client Assets
As of September 30, 2023, StoneX Advisors Inc. had assets under management of $3,315,760,084, of which $2,139,000,607 was managed
on a discretionary basis and $1,176,759,477 was managed on a non-discretionary basis. When we consider other advisory relationships
we maintain, such as promoter relationships with TPMMs (see Item 10, Other Financial Industry Activities and Affiliations, below) our
total assets under advisement were $3,919,246,506.2