9AT: SANCTUARY ADVISORS, LLC

SANCTUARY ADVISORS, LLC

other names

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Adviser Profile

As of Date	04/21/2025
Adviser Type - Large advisory firm
Number of Employees	622 21.96%
of those in investment advisory functions	332 16.90%
Registration	SEC, Approved, 07/10/2015

AUM^*	27,696,000,000 70.75%
of that, discretionary	27,586,800,000 74.83%
Private Fund GAV^*	0
Avg Account Size	498,668 19.69%
% High Net Worth	20.92% 25.38%
SMA’s	Yes
Private Funds	0
Contact Info	317 xxxxxxx
Websites

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans
- Charitable organizations
- Corporations or other businesses not listed above

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses
- Pension consulting services
- Selection of other advisers
- Educational seminars/workshops

Compensation Arrangments

- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

Reported AUM

16B 14B 11B 9B 7B 5B 2B

2015 2016 2017 2018 2019 2020 2021 2022 2023

Discretionary

Non-discretionary

Private Funds

GAV Count

Employees

Brochure Summary

Overview

4.A. Description of Advisory Firm Sanctuary Advisors, LLC, an Indiana limited liability company (“Sanctuary Advisors” or the “Firm”), was formed in 2015 and is a registered investment advisor firm with the United States Securities and Exchange Commission (the “SEC”). Sanctuary Advisors is a wholly owned subsidiary of Sanctuary Wealth Group, LLC (“Sanctuary Wealth”). Sanctuary Advisors’ principal business is offering investment advisory services to entities, institutions, and individuals. Sanctuary Advisors has an affiliated FINRA member broker-dealer, Sanctuary Securities, Inc (“Sanctuary Securities”). When describing arrangements that include both Sanctuary Advisors and Sanctuary Securities, the more inclusive name “Sanctuary Wealth” will be used. Sanctuary Advisors offers its services through its network of investment advisor representatives (“IARs”). IARs are independent contractors and may organize their own business entity (“IAR Business Entities”) to provide certain support services to the IAR and their team as they perform investment advisory services for clients and such entity may provide services other than investment advisory services. However, all investment advisory services are provided through Sanctuary Advisors. IARs may also conduct or market advisory services under a trade name (“DBA”) other than Sanctuary Advisors. The name and logo of the IAR Business Entities and/or DBAs may appear on marketing materials, as approved by Sanctuary Advisors, or client statements, as approved by the custodian. For a full list of DBAs under Sanctuary Advisors, please refer to Sanctuary Advisor’s ADV Part 1A. Most of Sanctuary’s IARs are dually licensed (i.e., they are licensed as both broker-dealer representatives and IARs) which means that they can offer investment advisory services through Sanctuary Advisors and brokerage services through Sanctuary Securities. Your IAR will disclose to you whether he or she is dually licensed and if there are any limitations on services offered due to their registrations and qualifications. The following information in this Brochure is meant to provide a detailed description of Sanctuary Advisors, its various services, associated fees and compensation, important customer disclosures, as well as conflicts of interest disclosures. Clients should carefully review information regarding conflicts of interest as these conflicts can have an effect on services, costs, and investment advice provided by Sanctuary Advisors and its IARs. Sanctuary Advisors has policies and procedures in place to ensure that recommendations are made in the best interest of the client and, when possible, to eliminate conflicts altogether. 4.A.1. Client Assets Under Management As of December 29, 2023, total client assets under management are approximately $22,024,300,000.00, of which approximately $21,890,000,000.00 is managed on a discretionary basis and $134,300,000.00 is managed on a non-discretionary basis. 4.B. Description Of Advisory Services Offered Sanctuary Advisors’ menu of advisory services is designed to address many different types of investors and their particular styles, needs, and preferences. Through Sanctuary Advisors, clients will have access to a variety of services, which include financial planning services, portfolio management for individuals and businesses, portfolio management for institutional clients other than investment companies, and selection of other advisors. When clients engage with Sanctuary Advisors in an investment advisory account relationship, Sanctuary Advisors acts as a “fiduciary” with respect to the investment advisory services it provides. Sanctuary Advisors acts as your investment advisor only when Sanctuary Advisors has entered into a written advisory agreement with you that describes the advisory relationship and the Firm’s obligations to you. Sanctuary Advisors renders discretionary and non-discretionary investment advisory services to clients that consists of programs sponsored by us, as well as advisory services offered through unaffiliated third- party investment managers. Client accounts are managed pursuant to the client’s advisory agreement with Sanctuary Advisors. Advisory services may include but are not limited to: (i) Advisor Directed, (ii) Separately Managed Accounts (“SMAs”), (iii) Unified Managed Accounts (UMAs). All programs can be implemented in either a wrap or non-wrap fee structure. Please refer to the chart located in Item 5 for further details. Sanctuary Advisors’ investment recommendations are not limited to any specific product or service and will generally include advice regarding the securities and transactions further described in Item 8. Methods of Analysis. For additional information about our wrap fee programs, please see the Wrap Fee Brochure 2A Appendix 1. IARs, subject to Sanctuary Advisor’s supervision, can develop their own investment philosophies and strategies. Investment philosophies and strategies can differ considerably between and among IARs. There is no guarantee, stated or implied, that a strategy or client’s investment goals or objectives will be achieved. Clients have access to a wide range of securities products, including common and preferred stocks, municipal, corporate, and government fixed income securities; mutual funds; exchange traded funds (ETFs), options, variable annuity products, as well as a wide range of other investment products. IARs offer advice on these and other types of investments based on the individual circumstances of each client. Advisor Directed The Advisor Directed program offers advisors the ability to implement a fee-based asset management program using a large selection of investments. The investments are all within one consolidated account. The advisor creates his or her own investment strategies that are designed to help clients achieve their investment goals. There are two options within the Advisor Directed program. In one, the advisor is responsible for placing his or her own trades to implement the strategy. In the second, an overlay manager is responsible for placing the trades. All accounts in the Advisor Directed program are discretionary with the exception of where the advisor acts as the portfolio manager and enters his/her own trades. Separately Managed Account Separately Managed Account (“SMAs”) program offers the advisors the ability to offer a multitude of solutions to meet their clients fee-based asset management objectives. SMA solutions are discretionary asset management with the choice of external third-party managers or Sanctuary’s affiliate Sanctuary Asset Management. SMA solutions include a wide range of security portfolios that they manage for our Advisors and clients. They include but are not limited to: ETFs, Mutual Funds, Equities, ADRs, Cash, and several Fixed Income securities. Sanctuary also provides offshore SMA solutions to our non-US resident clients. The SMA solutions have minimum investments which may vary depending upon the selected solution. Please see the Chart in Item 5 for additional detail. Unified Managed Account The Unified Management Account (“UMAs”) program provides the advisor fee-based asset management solutions that are managed on a discretionary basis. UMAs incorporate SMAs, Models, Mutual Funds, ETFs, and Equities in a single account to help our Advisors meet their clients' objectives. UMA solutions do have a minimum investment; please refer to the Chart in Item 5 for additional details. The Advisor Directed Program can be provided on either a discretionary or non-discretionary basis. The Advisor Direct Model as well as SMA and UMA solutions are provided on a discretionary basis only. When Sanctuary Advisors provides non-discretionary advice or recommendations, you decide whether to implement the recommendation and, if approved and requested by the client, Sanctuary Advisors implements the recommendation. This may result in a delay in executing recommended trades, which could adversely affect the performance of your account. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to client’s account. When a discretionary investment solution is selected, it allows Sanctuary Advisors to buy and sell investments in your advisory account without contacting you in advance (a “discretionary advisory account”). Sanctuary Advisors requires clients to participate in the formation of the investment plan, investment advice, and recommendations by discussing, among other things, the client’s investment experience, financial circumstances, investment objectives, tolerance for risk, and identifying goals. However, clients are obligated to immediately inform Sanctuary Advisors in writing of any changes in the foregoing. Sanctuary Advisors is held to a fiduciary standard with respect to its investment advisory clients; however, clients should be aware that Sanctuary Advisors is not a fiduciary in certain situations, including (but not limited to): Recommendations with respect to brokerage, or commission-based, accounts you maintain with Sanctuary Securities. Communications that are educational or informational and not intended to be viewed or construed as an individualized/personalized suggestion for you to take a particular course of action with respect to your investment assets. Examples include: Information Sanctuary Advisors provides about the performance of a security in your account. Information and education about alternatives you have when deciding whether to roll out of an employer plan or transfer assets from one IRA to another (including between brokerage and advisory accounts or among different advisory accounts). Information we provide regarding our products and services when you are considering whether to leave one financial institution, including (but not limited to) when you are considering leaving to follow your financial professional to Sanctuary Wealth. Marketing materials, including information, education, or general descriptions of our services, the products that we make available to you, the fees we charge, and the reasons we think you should hire us to provide services to you for your retirement and other accounts. Transactions (including rollovers) or trades you execute without a recommendation from us, such as an unsolicited trade. Recommendations and interactions that are episodic or sporadic or are not provided as part of an ongoing or regular basis advice relationship, or recommendations made when there is no mutual understanding that our investment advice will serve as a primary basis for your investment decision. 4.B.1. Client-Tailored Services And Client-Imposed Restrictions As outlined above, Sanctuary Advisors will develop an investment portfolio plan with asset allocations to meet the client’s specific investment needs and goals. Additionally, clients may, with written notice to Sanctuary Advisors, request reasonable restrictions on the management of their accounts, such as prohibiting investing in certain securities or types of securities. Clients must promptly notify Sanctuary Advisors in writing of any changes in such restrictions. All restrictions must be communicated clearly and accurately. In addition to providing your written communication, a review of your restriction should be conducted with your Advisor. Each client should note, however, that restrictions, if accepted by Sanctuary Advisors, may adversely affect the composition and performance of the client’s investment portfolio. 4.C. Financial Planning Services Sanctuary Advisors makes available financial planning services including but not limited to wealth accumulation, wealth distribution, cash flow analysis, higher education planning, retirement planning, estate planning, and legacy planning. If a client chooses to implement the financial plan through an IAR, the IAR and Sanctuary Advisors will receive additional compensation which creates a conflict of interest. A client has no obligation to implement any financial planning recommendation through Sanctuary Advisors or its affiliated entities. Sanctuary Advisors is not an accounting firm, is not a law firm, and does not provide accounting, tax, or legal advice through its financial planning services. Accordingly, clients are advised to consult with their tax advisor or legal counsel for tax, estate planning, and other recommendations made by Sanctuary Advisors. 4.D. Sub-Advisers Sanctuary Advisors may delegate some or all of its investment advisory functions over a particular client account or accounts to another investment advisor (“Sub-Advisor”). Prior to delegating advisory functions, Sanctuary Advisors

will perform due diligence on the Sub-Advisor, enter into a sub-advisory contract with the Sub-Advisor. Although Sanctuary Advisors retains authority to engage or terminate Sub-Advisors under a discretionary advisory agreement, Sanctuary Advisors typically informs clients prior to engagement or termination of the Sub-Advisor to which it delegates investment advisory functions and what portion of the client’s account is being given over to the Sub-Advisor to manage when it is practicable to do so. Having access to various Sub-Advisors offers a wide variety of manager styles and provides the opportunity to utilize more than one adviser for the account. Factors that Sanctuary Advisors considers in recommending/selecting Sub-Advisors generally include, without limitation, the client’s stated investment objective(s), management style, performance, risk level, reputation, financial strength, reporting, pricing, and research. With respect to assets managed by Sub-Advisors, Sanctuary Advisors’ role will be to monitor the overall financial situation of the client, monitor the investment approach and performance of the Sub-Advisor, and to assist the client in understanding the investments in the client’s account. Clients will be provided each Sub-Advisors Form ADV Part 2A Brochure, which contains important information regarding the strategies, fees, and risks of the Sub-Advisor. 4.E. Managed Account Platforms Sanctuary Advisors has contracted with BNY Melon Advisors, Inc. (“BNY”) and Adhesion, an affiliate of AssetMark Financial Holdings, Inc. (“Adhesion”, together the “Platforms”), for access to a managed account. The Platforms provide access to a variety of model portfolios created and managed by various investment advisers, including Sanctuary Advisors. The model providers and portfolios available to clients are reviewed and selected by each Platform. A subset is then selected by the investment committee of Sanctuary Advisors to offer to Sanctuary Advisory clients. The strategies of the model portfolios are not tailored to the particular needs or circumstances of a client. Instead, the strategies are provided by advisers to the Platforms as impersonal, generalized, non-discretionary advice that the Sanctuary IAR will implement as such IAR deems appropriate pursuant to the authority granted to them. When Sanctuary Advisors uses a Platform for a client account, Sanctuary Advisors will allocate all or a portion of the client’s account to one or more strategies selected for the client. The applicable adviser of the Platform strategy will then monitor the account and implement the strategy. Sanctuary Advisors’ role will be to monitor the overall financial situation of the client, to monitor the investment approach and performance of the Platform advisers, and to assist the client in understanding the investment of the model portfolio. Clients will be provided the applicable Sub- Advisers Form ADV Part 2A Brochure, which contains important information regarding the strategies, fees, and risks of the adviser. 4.F. Retirement Plan Services Sanctuary Advisors offers services to qualified and non-qualified retirement plans including 401(k) plans, 403(b) plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. Sanctuary Advisors may act as a 3(21) advisor: Depending on the type of the plan and the specific arrangement with a plan sponsor, Sanctuary Advisors will provide one or more of these services. The plan sponsor will execute a Retirement Plan Services Agreement that outlines the specific services and fees. Limited Scope ERISA 3(21) Fiduciary. Sanctuary Advisors acts as a limited scope ERISA 3(21) fiduciary that can advise, help, and assist plan sponsors with their investment decisions. As an investment advisor, Sanctuary Advisors has a fiduciary duty to act in the best interest of the Plan Sponsor. The Plan Sponsor is still ultimately responsible for the decisions made in their plan, though using Sanctuary Advisors can help the Plan Sponsor delegate liability by following a diligent process. 1. Fiduciary Services include:
• Providing investment advice to the Plan Sponsor about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Plan Sponsors will make the final decision regarding the initial selection, retention, removal, and addition of investment options. Sanctuary Advisors acknowledges that it is a fiduciary as defined in ERISA section 3 (21) (A) (ii).
• Assisting the Client in the development of an investment policy statement (“IPS”). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the IPS.
• Providing investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404© (5) and 404(a)-5.
• Assisting in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meeting with the Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services include:
• Assisting in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. Plan Sponsor understands Sanctuary Advisors’ assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, Sanctuary Advisors is not providing fiduciary advice as defined by ERISA 3(21)(A)(ii) to the Plan participants. Sanctuary Advisors will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assisting in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Sanctuary Advisors may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Sanctuary Advisors and Plan Sponsor. 3. Sanctuary Advisors has no responsibility to provide services related to the following types of assets (“Excluded Assets”):
• Employer securities;
• Real estate (except for real estate funds or publicly traded REITs);
• Stock brokerage accounts or mutual fund windows;
• Participant loans;
• Non-publicly traded partnership interests;
• Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or
• Other hard-to-value or illiquid securities or property.
• Excluded Assets will not be included in the calculation of Fees paid to Sanctuary Advisors on the ERISA Agreement. Specific services will be outlined in detail to each plan in the 408(b)2 disclosure. 3(38) Investment Manager. Sanctuary Advisors offers ERISA 3(38) Investment Management through select IARs or a third party which has discretionary management and control of a given retirement plan’s assets. The third-party or select IAR would then become solely responsible and liable for the selection, monitoring and replacement of the plan’s investment options. Fiduciary Services include:
• Advisor has discretionary authority and will make the final decision regarding the initial selection, retention, removal, and addition of investment options in accordance with the Plan’s investment policies and objectives.
• Assist the Plan Sponsor with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder.
• Assist the Plan Sponsor in the development of an investment policy statement. The IPS establishes the investment policies and objectives for the Plan.
• Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c)(5).
• Assist in monitoring investment options by preparing investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options.
• Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. Non-fiduciary Services include:
• Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. The Advisor’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the advisor is not providing fiduciary advice as defined by ERISA to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. Sanctuary Wealth may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between the Advisor and Plan Sponsor. 4.G. Retirement Plan Advisory Services Sanctuary Advisors provides retirement plan consulting services to 401(k) Plan Participants. Ongoing investment management, monitoring of available investment options, rebalancing and implementation of investment strategies will be implemented in the same way we manage non-retirement advisory accounts, including at least annual reviews and allocation changes, as necessary. When applicable, we will have discretionary authority to make all decisions to buy, sell, or hold securities, cash or other investments for the designated retirement plan without first consulting with the plan participant. We use a third-party platform, Pontera, to facilitate the management of 401(k) accounts. We are not affiliated with the platform in any way and receive no compensation from them for using their platform. A link will be provided to the Client by Pontera allowing the Client to connect their account(s) to the platform. Once a Client’s account(s) is/are connected to the platform, the IAR will review the current account allocations and, when necessary, will rebalance the account based on the Client’s individual investment goals and risk tolerance. The details of this service are described in the Advisory Agreement between Sanctuary Advisors and the Client. With respect to any account for which we meet the definition of a fiduciary under Department of Labor rules, we acknowledge that both the firm and its related persons are acting as fiduciaries. 4.H. IRA Rollover Considerations If you decide to roll assets out of a retirement plan into a Sanctuary Advisors individual retirement account (“IRA”), Sanctuary Advisors and your IAR will be paid advisory fees based on the amount of assets in that account. Such fees are likely to be higher than those you pay through your employer-sponsored plan and may include custodial or other maintenance fees. A conflict of interest exists because Sanctuary Advisors and its IAR have a financial incentive to recommend that you rollover assets from a retirement plan to an IRA. When we provide investment advice to you regarding your retirement plan account or IRA we are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean we are acting as fiduciaries for purposes of other applicable laws. This acknowledgement of fiduciary status does not confer contractual rights or obligations on you, Sanctuary Advisors, or the IAR.