Firm Brochure (Part 2A of Form ADV)

Transcription

1 Firm Brochure (Part 2A of Form ADV) Saffer Insurance & Investment Services, Ltd. dba Saffer Wealth Strategies N. 19 th Place Phoenix, AZ Phone: Fax: This brochure provides information about the qualifications and business practices of Saffer Wealth Strategies. If you have any questions about the contents of this brochure, please contact us at: , or by at: The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Saffer Wealth Strategies is available on the SEC s website at May 12, 2015 Saffer Wealth Strategies

2 Material Changes Annual Update The Material Changes section of this brochure will be updated annually when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update The U.S. Securities and Exchange Commission issued a final rule in July 2010 requiring advisers to provide a Firm Brochure in narrative plain English format. The new final rule specifies mandatory sections and organization. Full Brochure Available Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: or by at: Ron@Safferws.com. i Saffer Wealth Strategies

3 Table of Contents Material Changes... i Annual Update... i Material Changes since the Last Update... i Full Brochure Available... i Advisory Business... 1 Firm Description... 1 Principal Owners... 1 Types of Advisory Services... 1 Tailored Relationships... 1 Types of Agreements... 1 Wealth Management Consultations... 2 No Load or Fee Waived Fund Consultations... 2 On-Going Wealth Management Consultations... 2 Qualified Retirement Plan Consultations... 3 Third Party Money Manager (TPMM)/Sub-Advisor:... 3 Hourly Consultations... 3 Strategic Investment Solutions (SIS) Program (Wrap Program)... 4 Hourly Planning Engagements... 5 Asset Management... 5 Termination of Agreement... 6 Fees and Compensation... 6 Description... 6 Fee Billing... 6 Other Fees... 6 Expense Ratios... 6 Past Due Accounts and Termination of Agreement... 7 Performance-Based Fees... 7 Sharing of Capital Gains... 7 Types of Clients... 7 Description... 7 Account Minimums... 7 Methods of Analysis, Investment Strategies and Risk of Loss... 7 Methods of Analysis... 7 Investment Strategies... 7 Risk of Loss... 8 TOC 1

4 Disciplinary Information... 8 Legal and Disciplinary... 8 Other Financial Industry Activities and Affiliations... 8 Financial Industry Activities... 8 Outside Business Activities and/or Other Affiliations... 9 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading... 9 Code of Ethics... 9 Participation or Interest in Client Transactions... 9 Personal Trading... 9 Brokerage Practices... 9 Selecting Brokerage Firms... 9 Best Execution Order Aggregation Review of Accounts Periodic Reviews Review Triggers Regular Reports Client Referrals and Other Compensation Incoming Referrals Referrals Out Other Compensation Custody Account Statements Performance Reports Investment Discretion Discretionary Authority for Trading Voting Client Securities Proxy Votes Financial Information Financial Condition Requirement for State-Registered Advisors Executive Officers and Management Persons Other Business Activities TOC 2

5 Business Continuity Plan General Disasters Alternate Offices Information Security Program Information Security Privacy Notice TOC 3

6 Advisory Business Firm Description Saffer Wealth Strategies (SWS), ( Firm ) was founded in SWS provides personalized confidential wealth management to individuals, pension and profit sharing plans, trusts, estates, charitable organizations and small businesses. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning, pension and profit sharing plans, trusts, estates, or charitable organizations, and small businesses corporations or business entities. SWS is strictly a fee-only wealth management firm. The firm does not sell annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned products. The firm is affiliated with entities that sell financial products or securities and may receive commissions from the sale of annuities, insurance, UITs, stocks, bonds, ETFs, and mutual funds. No finder s fees are accepted. SWS does not act as a custodian of client assets. The client always maintains asset control. SWS places trades for clients under a limited power of attorney. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended. Other professionals (e.g., lawyers, accountants, insurance consultants, appraisers, etc.) are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. SWS is not in the habit of paying referral fees however a referral fee may be paid to properly licensed professionals. The initial two meetings, in person, are free of charge and are considered exploratory in nature and consultative to determine the extent to which wealth management may be beneficial to the client. Principal Owners Ronald G. Saffer is 100% owner of Saffer Insurance and Investment Services, Ltd. dba Saffer Wealth Strategies. Types of Advisory Services SWS provides wealth management services and furnishes investment advice through consultations. As part of wealth management, on an informal basis, SWS furnishes advice on matters not involving securities, such as financial planning matters, taxation issues, and trust advice that often include estate planning on an hourly fee basis. As of February 1, 2015, SWS manages approximately $18 million in assets for approximately 75 clients. Approximately 90% is managed on a discretionary basis, and 10% is managed on a non-discretionary basis. Tailored Relationships The goals and objectives for each client are documented in our client relationship management system. Agreements may not be assigned without client consent. SWS provides customized financial solutions for each client based on the client s needs. Types of Agreements The following agreements define the typical client relationships

7 Wealth Management Consultations SWS offers either oral or written wealth management options that can be comprehensive or segmented in nature. Plans will include recommendations to help clients meet their financial goals and objectives. In some cases, SWS may enter into a sub-advisor relationship at the request and approval of the client. Client will be responsible for any additional fees. In this relationship, SWS s associated person can use the services and expertise of other TPMMs to prepare the client's investment plan. SWS's associated person gathers all required information and documentation from the client and provides it to the sub-advisor. The sub-advisor then prepares the requested wealth management plan and forwards it to SWS's associated person. SWS's associated person is responsible for presenting the plan to the client and assisting in implementing any of the recommendations that the client elects to follow. SWS s associated person may also charge the client additional advisory fees as part of a separate client agreement. No Load or Fee Waived Fund Consultations Clients may also contract with the SWS's associated persons for consultations on portfolios containing only no load or fee waived mutual funds. The SWS's associated persons will charge a fee for these consultations that will not exceed 2.00% of the portfolio value at the time of the consultation for the first year of consultation. This negotiable fee will be based upon the complexity of the client's financial situation and will be disclosed prior to any services being provided. The fee will be due upon completion of the consultation. Fees of more than $500 will never be charged more than six months in advance. After the first year the client chooses whether or not to continue the engagement with SWS. Should client chose to continue engaging SWS for consulting services fees will not exceed 2.00% or alternatively the client may pay hourly fees. The fee will be negotiated with the client and will depend on frequency, dollar amount, complexity of the situation, number of meetings and potentially other factors. Either party may terminate services at any time by notifying all appropriate parties in writing. If services are terminated within five business days of executing a client agreement with SWS, services will be terminated without penalty. After the initial five business days, termination will be effective 30 days from the receipt of the termination notice. During this 30 day period, SWS's associated persons will not undertake any additional work on behalf of the client unless specifically requested by the client. The client will be responsible for time and expenses rendered by the associated person to the date that the notice of termination was received. The time and expenses rendered by the associated persons will be negotiated with the client. Also, if the client has selected the associated persons to implement transactions in their capacities as registered representatives or an independent advisor representative, the transactions originally requested may be in process and irreversible. There is no termination or refunds once a transaction has been completed. On-Going Wealth Management Consultations Clients may also contract with SWS's associated persons for on-going wealth management consultation services on an annual retainer basis. Clients will contract with SWS's associated persons to provide advice on various areas of financial concerns and accounts. SWS's associated persons will charge an annual fee for on-going wealth management consultations services. Fees will generally range from $1,200 to $12,000 per year, with a minimum annual fee of $600. Fees will be determined based upon the complexity of the client's financial situation, the services being provided and the estimated amount of time the client will use SWS during the course of the year. Fees will be billed monthly or quarterly, in advance. Fees will be due and payable upon receipt of billing notice from SWS. The amount of the fee and the manner in which the fee will be billed will be determined prior to services being provided and will be disclosed in the client agreement executed by SWS and the client. Either party may terminate services at any time by notifying all appropriate parties in writing. If services are terminated within five business days of executing an agreement with SWS, services will be terminated without penalty. After the initial five business days, termination will be effective at the end of the billing period (monthly or quarterly) in which the notice of termination is received. No refunds will be given after the initial five business days

8 Qualified Retirement Plan Consultations SWS's associated persons provide wealth management advice and financial educational seminars to sponsors of and participants in qualified retirement plans. The associated persons will consult with the plan sponsor on the plan design, review and recommend funds for inclusion in the plan, provide seminars for plan participants and meet with and make recommendations to plan participants concerning their plan investments. The associated persons will be the investment advisor representatives (IAR) of record for the plan accounts. SWS's associated persons will charge an hourly fee for initial consultations ranging from $150 to $300 per hour based on the complexity of the various qualified retirement plans and detail of the services that to be provided. The hourly fee will be charged until the qualified plan is established. Upon the qualified plan being established, SWS will charge the plan a minimum of $300 monthly or up to a maximum of 1.25%, whichever is greater, of assets in the plan annually. The fees will be due monthly, in advance, and will be based on the total account value of the plan at the end of the preceding month. When 1.25% of assets exceed the minimum fee of $300 per month in the plan, the IAR and the plan sponsor can determine who will pay the fees going forward. The IAR has the option of maintaining the maximum fee of 1.25% until the assets are adequate to warrant a discount from the maximum fee. Fees will be due and payable upon receipt of billing notice from SWS up to a minimum account size of $500,000 before any discounts. After the establishment of the plan either party may terminate services with a 90-day notice in writing. Normal fees will be due and payable during the 90-day period. If any additional services are requested by the plan sponsor, those services will be billed at the rate of $150 $300 per hour to be negotiated between the parties involved. Third Party Money Manager (TPMM)/Sub-Advisor: SWS's associated persons may establish agreements with third party money managers (TPMM) offering a wide range of advisory services which can include global asset allocation, tactical trend following, risk and volatility management with discretion. SWS's associated persons will solicit the services of the recommended TPMMs. SWS's associated persons will not refer a client to a money manager unless the money manager is registered or exempt from registration as an investment advisor in the client's state of residence. A client may select a recommended money manager based on the client's needs. SWS's associated persons will be available to meet with the client on a continuous basis. SWS and/or its associated persons will be compensated either by a solicitor's fee, a sub-advisor fee, or the advisor fee. Those fees will be paid from the client s investment account. Additionally, SWS will have access to the services of various Third Party Money Manager RIA's to assist the clients in managing their investments. SWS will assist the client to evaluate the varying strategies of the TPMM to determine which one meets the client's investment objectives. SWS may review TPMM's past performance, management style, location, minimum account size, assets under management, fees and other relevant information. Clients are asked to provide pertinent data including, financial data, risk tolerance, investment objectives, time horizon and investment experience. Client will receive both SWS's ADV Part II and the TPMM RIA's ADV Part II or other brochures. After opening, the TPMM will manage the client's account, SWS will not participate in the execution of securities transactions. SWS will review the account(s) with the client at least annually to determine if the TPMM is continuing to meet the investment objectives of the client. Fees, and their method of calculation for each TPMM RIA's services are described in the Form ADV Part II or other brochures. Fees are typically charged in advance quarterly or monthly and are debited directly from the client's account. Clients should consult the TPMM's form ADV Part II or equivalent brochure to determine how client can terminate an account and how fees are refunded if charged in advance. Advisory services provided in such a manner may have fees higher or lower than if client obtained similar services separately. For clients using the services of TPMM these fees may be negotiated between client and SWS at the time of opening an account. Hourly Consultations SWS's associated persons provide wealth management consultations for closely held businesses and individuals. SWS's associated persons charge an hourly fee of $150 to $300 for consultation services. Fees are negotiable depending on the complexity of the client's financial situation and the services to be provided. In some instances, a retainer fee may be due at the time the client agreement is signed. The total fee and any retainer required will be disclosed to the client prior to any services being provided. If a retainer is required, the remainder of the quoted fee will be due and payable upon completion of the services. If a retainer is not required, all fees will be due and payable upon completion of services

9 If either party wishes to terminate services, they may do so at any time by notifying all appropriate parties. Any verbal notification must be followed with written notification. Termination will be effective upon receipt of such notice. The client will have a period of five business days to terminate services with no penalty. After the initial five business days, the client will be responsible for payment of fees for any hours expended prior to notice of termination being received. If fees were paid in advance, fees will be refunded on a pro-rated basis based on the number of hours of service completed. Strategic Investment Solutions (SIS) Program (Wrap Program) SWS offers asset management services based on the client's individual needs. SWS will gather information on a client's financial history, goals, objectives, and financial concerns and assist client in developing an investment strategy. All information gathered from client is confidential. Client will establish an Account through various custodians and deposit cash, cash equivalents and securities and engage SWS to manage the account. Based on client's investment objectives, risk tolerance, and financial situation, SWS will manage the Account on a continuous basis. SWS will not maintain custody of client's funds or securities, with the exception of SWS's fees may be withdrawn directly from the client's account upon client's authorization granted in the advisory agreement. Custodial services for the managed Account will be provided through a limited number of custodians. The client may also choose any approved Sub-Advisors to direct their portfolio. Custody of assets and funds are maintained through a fully disclosed clearing arrangement with various custodians at the discretion of sub-advisor. The Sub-Advisor will be granted written discretionary authority via the Sub-Advisor Agreement which allows the Sub- Advisor to determine the securities to be purchased or sold and the amount of securities that are purchased or sold. Clients have the right to restrict this discretionary authority by notifying the IAR and/or the Sub-Advisor in writing of any and all limitations. The Sub-Advisor is responsible for selecting portfolio holdings, executing trades and monitoring performance. The Sub-Advisor will be solely responsible for directing the investment and reinvestment of the assets in the account, in accordance with the information provided by the client. The Sub-Advisor may choose to utilize independent research to assist in directing client investments. The independent research is unaffiliated with SWS in anyway and the cost is paid to the Sub-Advisor and passed on to the research firm. Clients are advised that transactions in the account, account reallocations and rebalancing may trigger a taxable event for the client, with the exception of IRA accounts, 401k accounts, 403(b) accounts, 457(b), 457(f) and other qualified retirement accounts. SWS will meet with clients at least annually or at client's request to discuss the client's investment portfolio and to update the client's financial information should any changes have occurred. Fee Schedule: Advisory fees will be charged in advance on a monthly or any other calendar basis based upon the value of each of the client's accounts on the last business day of the just completed calendar month. Accounts managed for a part of the year or month will be charged a prorated portion of the advisory fees for the year or month. The advisory fees payable upon initial implementation of the account may be paid by client upon receipt of the invoice from SWS or collected directly from the account provided the client has given SWS written authorization. Advisory fees for all subsequent periods will be charged to and collected directly from the client's Account. Additionally, clearing firm will provide clients with an account statement reflecting the deduction of the advisory fee. If the Account does not contain sufficient funds to pay advisory fees, SWS has limited authority to sell or redeem securities in sufficient amounts to pay advisory fees. Client may reimburse the account for advisory fees paid to SWS, except for ERISA and IRA accounts. Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds. Advisory fees are in accordance with the following fee schedule: - 4 -

10 Maximum Account Size Maximum Annual Fee $0 to $100, % $100,001 to $250, % $250,001 to $500, % $500,001 to $1,000, % $1,000,001 to $2,500, % $2,500,001 to $5,000, % $5,000,001 to $10,000, % Negotiable after $10,000,001 Each managed account (based on account registration) will be assessed a fee based upon the value of the individual account. In addition to the advisory fees above, client may pay fees for custodial services, account maintenance fees, transaction fees, and other fees associated with maintaining the Account. SWS does not share in any portion of such fees. Additionally, client may pay their proportionate share of the fund's management and administrative fees as well as the mutual fund adviser's fee of any mutual fund they purchase. Such fees are not shared with SWS and are compensation to the fund-manager. Clients should read the mutual fund prospectus prior to investing. Additionally, client may be assessed a nominal annual fee for performance reports. The SIS Program is considered a Wrap Fee Program. Advisory services as such may have fees higher or lower than if the client obtained similar services separately. Clients may make additions to the Account or withdrawals from the Account, provided the Account continues to meet minimum account size requirements. Fee adjustments will be made for partial withdrawals from the account and additional deposits to the account. Accounts will be credited a pro-rated portion of the advisory fee for any partial withdrawals and will be charged not later than the following quarter or monthly billing a prorated portion of the advisory fee for any additional deposits to the account. Clients may terminate investment advisory services obtained from SWS, without penalty, upon written notice within five (5) business days after entering into the advisory agreement with SWS. Client will be responsible for any fees and charges incurred by client from third parties as a result of maintaining the Account such as transaction fees for any securities transactions executed and Account maintenance or custodial fees. Thereafter, client may terminate investment advisory services with 30 days prior written notice to SWS. Should client terminate investment advisory services during a quarter or month, client will be refunded a pro-rata portion of the advisory fee for the quarter or month from the date of termination to the end of the calendar quarter or month. Hourly Planning Engagements SWS provides hourly planning services for clients who need advice on a limited scope of work. The hourly rate for a limited scope engagements is in the $150 - $300 range. Asset Management Assets are invested primarily in no-load or commission-waved at NAV mutual funds and exchange-traded funds. Fund companies charge each fund an investment management fee that is disclosed in the fund prospectus. Third Party Custodians may charge a transaction fee for the purchase of some funds. Those transaction fee charges are the responsibility of the client. Stocks and bonds may be purchased or sold through a brokerage account when appropriate. If transaction fees are included, those fees will be deducted from the client account as well. Investments may also include: equities (stocks), corporate debt securities, certificates of deposit, municipal securities, investment company securities ETFs, mutual funds shares, U. S. government securities, options contracts

11 Termination of Agreement A Client may terminate any of the aforementioned agreements at any time by notifying SWS in writing. SWS may terminate any of the aforementioned agreements at any time by notifying the client in writing. Each aforementioned agreement has its own specific termination policy. Please see individual agreements for that specific information. Fees and Compensation Description SWS bases its fees on a percentage of assets under management, hourly charges, or fixed fees. Fees are negotiable. Each aforementioned agreement has its own specific fee arrangement. Please see individual agreements for that specific information. Fee Billing Investment management fees are billed monthly or quarterly, in advance or in arrears. Each aforementioned agreement has its own specific billing arrangement. Please see individual agreements for that specific information. Payment in full is expected upon invoice presentation. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account. Other Fees Custodians may charge transaction fees on purchases or sales of certain mutual funds and exchange-traded funds. These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security SWS, in its sole discretion, may waive its minimum opening account size and SWS may charge less than the maximum advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Expense Ratios Mutual funds generally charge a management fee for their services as investment managers. The management fee is called an expense ratio. For example, an expense ratio of 0.50 means that the mutual fund company charges 0.5% for their services. These fees are in addition to the fees paid by you to SWS. Performance figures quoted by mutual fund companies in various publications are after their fees have been deducted. Mutual fund holdings may incur additional undisclosed costs over and above the stated expense ratios (including trading costs, legal and accounting fees, expenses due to turnover)

12 Past Due Accounts and Termination of Agreement SWS reserves the right to terminate any wealth management engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in SWS s judgment, to providing proper wealth management advice. Performance-Based Fees Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. SWS does not use a performance-based fee structure because of the potential conflict of interest. Performancebased compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. Types of Clients Description SWS generally provides investment advice to individuals, pension and profit sharing plans, trusts, estates, or charitable organizations, and small businesses corporations or business entities. Client relationships may vary in scope and length of service. Account Minimums Account minimums are established at the discretion of the advisor with the maximum annual fee of up to 2%. The Advisor has the discretion to waive the minimum account size and/or to reduce the maximum fee. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis. The main sources of information include financial newspapers and magazines, direct research materials prepared by mutual fund companies others, corporate rating services, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Other sources of information that SWS may use include, TD Ameritrade Institutional, teleconference calls & webinars, direct information from Chief Investment officers of TPMM s or independent consulting firms, The Wall Street Journal (and other financial periodicals and newspapers), and the World Wide Web. Investment Strategies An investment strategy is developed based on a client s individual needs and circumstances. SWS has a variety of wealth management solutions available which are customized to each client s situation. For each specific investment strategy please see our Types of Agreements section. The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement that documents their objectives and their desired investment strategy

13 Other strategies may include long-term purchases, short-term purchases, trading short sales, margin transactions, and covers call options. Risk of Loss All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Disciplinary Information Legal and Disciplinary The firm and its employees have not been involved in legal or disciplinary events related to past or present investment clients. Other Financial Industry Activities and Affiliations Financial Industry Activities SWS is not registered as a securities broker-dealer, or a futures commission merchant, commodity pool operator or commodity trading advisor

14 Outside Business Activities and/or Other Affiliations SWS has arrangements that are material to its advisory or its clients with a related person who is a licensed insurance company or agency. SWS's associated persons are engaged in professions other than giving investment advice. SWS's associated persons sell insurance products through Saffer Insurance & Investment Services, Ltd., to any client for commissions. Approximately 10-20% of SWS s associated person s workweek is spent on these activities SWS has established an affiliation with Osland Financial Group. The purpose is to establish a succession plan to give clients a seamless transition of services in the future. Saffer Insurance & Investment Services, Ltd. is a licensed insurance agency in the State of Arizona. Also can become licensed in other states as determined by client s state of residency. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The employees of SWS have committed to a Code of Ethics that is available for review by clients and prospective clients upon request. The firm will provide a copy of the Code of Ethics to any client or prospective client upon request. Participation or Interest in Client Transactions According to the Investment Advisers Act of 1940, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor's responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. SWS and its associated persons have a fiduciary duty to all clients. SWS has established a Code of Ethics which all associated persons must read and then execute an acknowledgement agreeing that they understand and agree to comply with SWS's Code of Ethics. SWS and associated persons' fiduciary duty to clients is considered the core underlying principle for SWS's Code of Ethics and represents the expected basis for all associated persons' dealings with clients. SWS has the responsibility to make sure that the interests of clients are placed ahead of it or its associated persons' own investment interests. All associated persons will conduct business in an honest, ethical and fair manner. All associated persons will comply with all federal and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to services being conducted. All associated persons have a responsibility to avoid circumstances that might negatively affect or appear to affect the associated persons' duty of complete loyalty to their clients. This section is only intended to provide current clients and potential clients with a description of SWS's Code of Ethics. If current clients or potential clients wish to review SWS's Code of Ethics in its entirety, a copy may be requested from any of SWS's associated persons and a copy will be provided promptly. Personal Trading The registered office administrator of SWS is Sharon E. Cistone. She places all trades each day. Her trades are reviewed by Ron Saffer. Ron advises her on all client trades. The personal trading reviews ensure that the personal trading of employees does not affect the markets, and that clients of the firm receive preferential treatment. Since most employee trades are small mutual fund trades or exchange-traded fund trades, the trades do not affect the securities markets. Brokerage Practices Selecting Brokerage Firms - 9 -

15 SWS does not have any affiliation with product sales firms. Specific custodian recommendations are made to Clients based on their choice of the TPMM. SWS recommends custodians based on the proven integrity and financial responsibility of the firm and the best execution of transactions at reasonable fees. SWS recommends multiple trust companies for client consideration (qualified custodians), such as TD Ameritrade and Trust Company of America and Templeton Trust Company, Bank of Arizona Trust Services, Reliance Trust, Dunham Trust Company and Trust Company of Arizona. SWS does not receive fees or commissions from these recommendations. Best Execution SWS reviews the execution of trades at each custodian each quarter. SWS does not receive any portion of the trading fees. Order Aggregation Most trades are mutual funds or exchange-traded funds where trade aggregation does not garner any client benefit. Review of Accounts Periodic Reviews Account reviews are performed when requested by advisor Ron Saffer, CLU. Account reviews are performed more frequently when market conditions dictate. Qualified retirement plan accounts are reviewed only upon request of the plan participant. Managed accounts will be reviewed at least annually. The calendar is the main triggering factor, although changes in the client's financial situation or changes in market conditions may trigger a more frequent review. Accounts under continuous management and supervision will be reviewed on an ongoing basis. At a minimum, accounts will be reviewed at least annually. A more frequent review may be instigated by a client inquiry due to policy changes or in the event of a change in prevailing market conditions. Clients are advised they should notify SWS promptly of any changes to the client's financial goals, objectives or financial situation as such changes may require a review of the financial plan and/or portfolio. Review Triggers Other conditions that may trigger a review are changes in the tax laws, new investment information, and changes in a client's own situation or changes within the investment managers entity. Regular Reports Account reviewers are members of the firm's Investment Committee. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client. Clients receive periodic communications on at least an annual basis. Clients will receive statements from the investment custodian or money manager at which their account is maintained at least quarterly. SWS does not prepare any reports for clients. Clients participating in any of the TPMM Programs will receive at least quarterly, account statements, transaction ledgers and quarterly reports showing the investment performance of their account from the company maintaining their accounts

16 For all managed accounts reviews will be conducted with clients not less than at least annually or as agreed by client and SWS. Clients may request more frequent reviews and may set thresholds for triggering events that would cause a review to take place. Generally, Advisory Representatives will monitor for changes or shifts in the economy, changes to the management and structure of a mutual fund or company in which client assets are invested, and market shifts and corrections. Clients are advised that they should notify their Advisory Representative promptly of any changes to the client's financial goals, objectives or financial situation as such changes may require Advisory Representative to review the client's portfolio and make recommendations for changes. All reviews will be conducted by the Investment Committee. Client Referrals and Other Compensation Incoming Referrals SWS has been fortunate to receive many client introductions over the years. The introductions came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties for these introductions. Referrals Out SWS does not accept referral fees or any form of remuneration from other professionals when a prospect or client is referred to them. Other Compensation SWS accepts commissions if it is the only means of compensation. These accounts may be transitioned to feebased accounts at a date where it can be accommodated. SWS's associated persons also sell insurance products for sales commissions and/or fees. Load and no-load mutual funds may pay annual distribution charges on a quarterly basis sometimes referred to as 12(b)-1 fees. Clients should be aware that these 12(b)-1 fees come from fund assets, and thus, indirectly from client's assets. TD Ameritrade makes available to SWS other products and services that benefit SWS but may not benefit its clients' accounts. Some of these other products and services assist SWS in managing and administering clients' accounts. These include software and other technology that provide access to client account data, such as trade confirmation and account statements; facilitate trade execution, provide research, pricing information and other marked data; facilitate payment of SWS's fees from its clients' accounts; and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of SWS's accounts, including accounts not maintained at TDA. TDA may make available to SWS other services intended to help SWS manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance and marketing. TDA may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to SWS. SWS's associated persons may select and monitor Sub- Advisors or TPMMs to manage client assets. Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to clients either at their address of record or via at least quarterly. Performance Reports Clients are urged to review the account statements received directly from their custodians

17 Investment Discretion Discretionary Authority for Trading SWS accepts discretionary authority to manage securities accounts on behalf of clients. SWS has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. However, SWS consults with the client prior to any major changes to obtain concurrence if a blanket trading authorization has not been given. Discretionary trading authority facilitates placing trades in your accounts on your behalf so that we may promptly implement the investment policy that you have approved in writing or verbally. Voting Client Securities Proxy Votes SWS does not vote proxies on securities. Clients are expected to vote their own proxies. When assistance on voting proxies is requested, SWS will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. Financial Information Financial Condition SWS does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because SWS does not serve as a custodian for client funds or securities. Requirement for State-Registered Advisors Executive Officers and Management Persons Please refer to Principal Owners in the Advisory Business section. Other Business Activities Please refer to Other Financial Industry Activities and Affiliations section and also the personal bios in the Firm Brochure Supplement Part 2B of Form ADV. Business Continuity Plan General SWS has a Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, services or key people

18 Disasters The Business Continuity Plan covers natural disasters such as snow storms, hurricanes, tornados, and flooding. The Plan covers man-made disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1 communications line outage, Internet outage, railway accident and aircraft accident. Electronic files are backed up daily and archived offsite. Alternate Offices Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is our intention to contact all clients within five days of a disaster that dictates moving our office to an alternate location. Information Security Program Information Security SWS maintains an information security program to reduce the risk that your personal and confidential information may be breached. Privacy Notice SWS is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. The categories of nonpublic information that we collect from you may include information about your personal finances, information about your health to the extent that it is needed for the wealth management process, information about transactions between you and third parties, and information from consumer reporting agencies, e.g., credit reports. We use this information to help you meet your personal financial goals. With your permission, we disclose limited information to attorneys, accountants, and mortgage lenders with whom you have established a relationship. You may opt out from our sharing information with these nonaffiliated third parties by notifying us at any time by telephone, mail, fax, , or in person. With your permission, we share a limited amount of information about you with your brokerage firm in order to execute securities transactions on your behalf. We maintain a secure office to ensure that your information is not placed at unreasonable risk. We employ a firewall barrier, secure data encryption techniques and authentication procedures in our computer environment. We do not provide your personal information to mailing list vendors or solicitors. We require strict confidentiality in our agreements with unaffiliated third parties that require access to your personal information, including financial service companies, consultants, and auditors. Federal and state securities regulators may review our Company records and your personal records as permitted by law. Personally identifiable information about you will be maintained while you are a client, and for the required period thereafter that records are required to be maintained by federal and state securities laws. After that time, information may be destroyed. We will notify you in advance if our privacy policy is expected to change. We are required by law to deliver this Privacy Notice to you annually, in writing

19 Firm Brochure Supplement (Part 2B of Form ADV) Saffer Insurance & Investment Services, Ltd. dba Saffer Wealth Strategies N. 19 th Place Phoenix, AZ Phone: Fax: This brochure supplement provides information about Ronald G. Saffer and Sharon E. Cistone that supplements the Saffer Wealth Strategies brochure. You should have received a copy of that brochure. Please contact Ronald G. Saffer, President, if you did not receive Saffer Wealth Strategies brochure or if you have any questions about the contents of this supplement. Additional information about Ronald G. Saffer and Sharon E. Cistone is available on the SEC s website at May 12, 2015 Saffer Wealth Strategies

20 Brochure Supplement (Part 2B of Form ADV) Ronald G. Saffer, CLU Date of Birth: 1941 Educational Background: University of Arizona, Accounting & Finance, Iowa State University, Westside High School, Omaha, NE, 1959 Business Experience: President, Saffer Wealth Strategies, 1998 Current Registered Representative, Geneos Wealth Management, Inc., /31/2014 Registered Investment Advisor, 1998 Current Registered Representative, Securities America, Inc., President & Treasurer, Saffer Insurance & Investment Services, Ltd., 1994 Current President, Insurance Agent, Ron Saffer & Associates, Ltd., Name Change, same company required by State of California Registered Representative, Pentad Securities, Registered Representative, Fox & Company Investments, Ronald G. Saffer holds Series 1, 24, 63, and 66 licenses and is licensed in the states of AZ and TX Disciplinary Information: None Other Business Activities: Member of Board of Directors for the Boys and Girls Clubs of Metropolitan Phoenix since 1984 and is currently a Life Director. Emeritus Trustee of the Metropolitan Phoenix Boys and Girls Club Foundation. Founder, past Chairman and past Board Member of Junior Golf Association of Arizona. Lifetime Honorary Member of the Hon Kachina Council (part of the St. Luke s Health Initiative. Past Trustee of the Valley Presbyterian Church Foundation. Additional Compensation: None Supervision: Ronald G. Saffer is the President and Owner/Principal of Saffer Wealth Strategies Ronald G. Saffer s contact information: Phone: (602) Cell: (602) Arbitration Claims: None ron@safferws.com Self-Regulatory Organization or Administrative Proceeding: None Bankruptcy Petition: None Saffer Wealth Strategies May 12, 2015

21 Sharon E. Cistone Date of Birth: 1945 Educational Background: Graduate, RB Chamberlain High School, 1963 Business Experience: Registered Office Administrator, Saffer Wealth Strategies, 2006 Current Administrative Assistant to Nan Cohen, CFP, Cedar Brook Financial, Administrative Assistant to Nan Cohen, CFP, Lincoln Financial, Secretary to Vice President of Private Banking, Metropolitan Bank, Executive Secretary, LTV Steel Company, Executive Secretary, Lamotite Products, Secretary to Zone Manager, Cleveland, Chrysler Corporation, Secretary to President, Marshall Mortgage, Sharon E. Cistone holds a Series 6 license Disciplinary Information: None Other Business Activities: None Additional Compensation: None Supervision: Sharon E. Cistone is supervised by Ronald G. Saffer, President. He reviews Sharon E. Cistone s work through frequent office interactions as well as remote interactions. He also reviews Sharon E. Cistone s activities through our client relationship management system. Sharon E. Cistone s contact information: Phone (602) Ronald G. Saffer s contact information: Phone: Arbitration Claims: None sharon@safferws.com ron@safferws.com Self-Regulatory Organization or Administrative Proceeding: None Bankruptcy Petition: None Saffer Wealth Strategies May 12, 2015