The Advisor began operations in April of 2014. The Advisor is a limited liability company principally owned by David Marion, Kristina Alley and David Kantor.

SFA provides the following advisory services:

SFA primarily provides investment management and financial planning services for high net worth individuals and families, institutions, charitable organizations and trusts. In order to provide prudent financial planning and investment management services, we believe it is important to understand a client’s complete financial profile. We work with clients carefully outlining their goals as they relate to their assets/liabilities, cash flow, cost of living, risk tolerance and long term planning. In managing investment portfolios for our clients, portfolios consist of multi-asset class investments, comprised of active and passive investment vehicles selected and approved through our firm’s research process. SFA provides advice with respect to limited types of investments as described in greater detail below. Page 3 of 12 – Form ADV Part 2A Our Mission SFA’s mission is to help clients achieve their financial goals through creating a long term financial plan that incorporates the successful management of their investment portfolios. We believe that we offer clients a combination of depth of experience, an open, transparent approach and a culture focused on the best interests of our clients. Our interests should always be aligned with, and subordinated to, those of our clients. SFA is a fiduciary to each of our client relationships. To maintain a close alignment of interests between ourselves and our clients, we personally invest in the same portfolios that we recommend for our clients. Finally, we strive to maintain a high level of service for our clients. Clients should expect a positive client service experience including frequent and clear communications.

Financial Planning

Our clients receive financial planning advice as an important component of establishing their investment objectives for the long term management of their investment portfolios. The process starts with a detailed conversation with the client about their objectives, time horizon and tolerance for risk. We then request information from each client in order to prepare a summary balance sheet. We also request information about their family situation, income sources, current and expected cost of living, risk management planning, retirement plans, estate planning, their other advisors such as attorneys and tax advisors, etc. Once the information is assembled, we will prepare an overview and outline recommendations to assist the client with better aligning their finances and other planning with their personal goals and financial situation. Apart from the investment portfolios that SFA directly oversees, the client is responsible for implementation of any other financial planning recommendations. We help our clients keep track of the recommendations and review implementation, as necessary. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from SFA. A client’s financial plan is reviewed and adjusted on an on- going basis, as needed.

Financial planning services are available to clients as part of all investment management engagements. We also may be engaged for financial planning services on a stand-alone basis.

Investment Philosophy Our approach is focused on managing risk which we believe is essential to achieving investment objectives regardless of a client’s particular tolerance for risk. We believe that active management of portfolio allocation is critical to risk mitigation and investment success. Tactical portfolio changes are only made upon high conviction information. Portfolio changes are made if the change is viewed to be asymmetrically favorable for our clients. We do not adhere to benchmark allocations and believe that strict adherence to benchmarks yield mediocre results. Finally, an important aspect of a successful investment process is the containment of costs. Hidden fees, excessive transaction costs Page 4 of 12 – Form ADV Part 2A and adverse tax consequences hinder investment performance and must be minimized to the extent possible. Client Experience All client portfolios are governed by an investment policy statement which outlines, among other things, risk tolerance, asset allocation parameters, time horizon, distribution needs and other restrictions. Restrictions in client portfolios are subject to consideration by SFA to determine whether our firm can add value to a client’s investment portfolio within the restrictions imposed by the client.

Each client is advised that it is the client’s obligation to notify SFA of any change in financial circumstances or investment objectives. SFA will then review with the client whether a change in their investment portfolios is, in SFA’s opinion, recommended. SFA shall not independently verify any information received from the client or from the client’s other professionals and is authorized to rely on such information.

SFA does not provide tax or legal advice. Clients requiring assistance on issues outside of financial and investment advisory topics should consult a tax advisor, legal counsel or other professionals for expert opinions. Upon client request, SFA may recommend the services of other professionals such as attorneys, accountants, insurance agents, etc. The client is under no obligation to engage the services of any SFA-recommended professional. SFA has no affiliation, financial or otherwise, with any such professionals.

Our primary source of compensation is a fee based on a percentage of assets managed. For financial planning only engagements, we charge an hourly rate. We accept no product based fees nor any other form of compensation from outside sources. SFA does not participate in any wrap fee programs.

As of December 31, 2018, SFA had $113,190,000 of assets under management. $110,213,000 is managed on a discretionary basis and $2,977,000 is managed on a non- discretionary basis.

Miscellaneous

SFA may recommend that a client roll over employer sponsored retirement plan assets to an Individual Retirement Account (IRA) managed by SFA. As a result, SFA may earn an asset-based fee. In contrast, a recommendation that a client or prospective client leave their plan assets with their former employer or roll the assets to a plan sponsored by a new employer would likely result in little or no compensation for SFA. Thus, SFA has an economic incentive to encourage an investor to roll plan assets into an IRA that it will oversee. No client is under any obligation to roll over plan assets to an IRA managed by SFA or to open an IRA with SFA. SFA’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding its prospective engagement and the potential conflict of interest presented by such engagement. Page 5 of 12 – Form ADV Part 2A please register to get more info

SFA, in providing its investment advisory services to clients, selects investments for the client and performs the other functions specified by the client in the investment management agreement. Clients pay an investment management fee to SFA for the services provided under the investment management agreement, calculated and paid monthly in arrears based on the average fair market value of the assets in their accounts during the month. The fee percentage, expressed as an annual rate, is displayed in the table below. Fair market value shall be determined in good faith by SFA, and may include accrued income. In valuing investments in limited partnerships and other collective investment vehicles, SFA may use the most recent valuation (including estimated valuations) obtained from the manager or administrator/recordkeeper of the investment vehicle. Investment management fees are deducted from the client account(s). Subject to SFA approval, clients may request to be billed for investment management fees.

In addition to SFA’s investment management fee, underlying investments such as collective investment vehicles (mutual funds and exchange traded funds), hedge funds and separately managed accounts carry fees and expenses that are charged by the manager of the underlying investment and other service providers. In addition, accounts are subject to other fees and costs, such as custodial fees, broker-dealer commissions, and transaction charges.

Fee Schedules

Below are SFA’s standard fee schedules. In specific situations, fees may also be negotiated.
Discretionary

Fee
On the first $1 million

1.00% On the next $4 million

0.75% On the next $5 million

0.55% On amounts over $10 million

0.35%
Non - Discretionary
Fee
On the first $1 million 1.25% On the next $4 million 1.00% Page 6 of 12 – Form ADV Part 2A On the next $5 million 0.75% On amounts over $10 million 0.50% SFA assess a minimum annual fee of $7,500 per relationship, irrespective of asset size. Subject to management approval, the minimum fee may be waived.

Fees for financial planning only services are charged on an hourly basis and determined by the scope of the engagement.

Neither SFA nor any of its supervised persons accepts compensation for the sale of securities or other investment products, including asset based sales charges or service fees from the sale of mutual funds. please register to get more info

SFA does not charge any performance based fees. please register to get more info

SFA provides investment management and financial planning services to individuals, high-net-worth individuals, families, trusts, institutions, charitable organizations and to a limited extent, employer sponsored retirement plans.

SFA generally requires a minimum of $1,000,000 of assets under management for each client relationship. Subject to management approval, the minimum assets under management requirement may be waived.

For financial planning only engagements, SFA generally requires a minimum client net worth of $3,000,000. Subject to management approval, the minimum net worth requirement may be waived.

please register to get more info

Investment Process SFA is a manager of global multi-asset class investment portfolios with a long term, absolute return orientation. We believe that well diversified portfolios achieve superior investment results over time. Client portfolios are diversified across asset classes, investment style and geographic regions. As described earlier, we do not match our portfolios to a benchmark, in fact, our client portfolios may deviate considerably from our neutral strategic position. These changes result from reducing risk and capturing opportunities due to asset class mis-pricing. Page 7 of 12 – Form ADV Part 2A While we analyze each investment on a stand-alone basis, we view risk at the portfolio level and assess each investment’s risk in that context as we construct client portfolios. Client portfolios are constructed using both passively and actively managed investment vehicles. Mutual funds and exchange traded funds (“ETFs”) are primarily used in the construction of client portfolios. We may also use limited partnerships (“hedge funds”) and separately managed accounts depending on a client’s investment objectives and overall portfolio size. SFA does not provide advice for the purchase of individual securities in client portfolios.

Manager Evaluation and Due Diligence

SFA conducts proprietary research on every fund or separately managed account used in client portfolios. This due diligence is performed prior to recommending the investment for use any client portfolio. The process begins with qualitative screening which includes an assessment of performance and consistency criteria such as past relative and absolute investment returns, style drift, drawdowns and volatility. The screens include a preliminary assessment of the management team, its strategy, investment philosophy and process. We also consider the repeatability of the investment approach, risk management and the operational controls utilized by the investment manager. Prior to inclusion in the SFA approved list, investment managers are generally interviewed either in person or via conference call. Active managers with significant investment discretion are almost always interviewed in-person. Investment vehicles such as hedge funds and other alternative managers require additional due diligence, including a review of their counterparties including custodian, prime broker(s), auditor, and administrator. Once a manager is added to our approved list, we institute a regular monitoring process which includes telephone calls, site visits, review of positioning, and continued performance analysis.

Client Portfolio Construction

SFA invests each client portfolio consistent with the objectives and risk tolerance of the overall client relationship. Each client portfolio is governed by an investment policy statement which defines risk parameters and is agreed upon with the client at the beginning of the relationship. The investment policy statement is adjusted throughout the client relationship as objectives and restrictions change. Institutional clients of SFA may have proprietary investment policy statements which SFA will utilize to govern the relationship. We will also advise institutional clients on revisions to their proprietary investment policy statements. Once we have determined the appropriate risk profile of the client we will then apply an appropriate asset allocation. The asset allocation will reflect the investment process and manager due diligence described above. SFA maintains a limited number of risk based portfolios that are used as guidelines for client portfolios. These portfolios are broadly titled Aggressive Growth, Growth, Moderate, Balanced, Conservative and Capital Preservation. This terminology is subject to change based on market conditions and generally understood investment terminology. Client portfolios are carefully monitored and adjusted as we alter our view based on changing market conditions. Page 8 of 12 – Form ADV Part 2A Investment Strategy and Research Process SFA does not actively trade in individual equities or fixed income securities. Rather, the Advisor typically allocates clients’ assets among mutual funds, exchange traded funds, unregistered investment funds (“hedge funds”) and separately managed accounts that are managed by unaffiliated third-party money managers. The Advisor may offer advice about specific investment managers who specialize in various disciplines, including, but not limited to domestic and international equities, fixed income (including high yield, international and investment grade), alternative strategies such as global macro and real estate, and cash management. The Advisor may also recommend investments in hedge funds which invest in venture capital, private equity, and other types of unregistered funds.

Risks

Investing in securities involves risk of loss which clients should be prepared to bear. The following is an overview of the risks related to the Advisor’s investment strategy and is not intended to be complete. All investing involves a risk of loss and the investment strategy offered by the Advisor could lose money over short or long periods. The following are certain risks applicable to advisors that may select third-party investment managers to manage a portion of its clients’ underlying assets:

Hedge funds and other unregistered private investments may not be suitable for all investors, may present significant risks and may be sold or redeemed at more or less that the original amount invested. Private investments are offered only by offering memoranda, which more fully describe the possible risks. Suitability requirements must be met for investments in unregistered investments such as hedge funds.

Underlying hedge funds will not be registered as investment companies under the Investment Company Act of 1940 (the “1940 Act”) and, therefore, the clients will not be entitled to the various protections afforded by the 1940 Act with respect to its investments in hedge funds. For example, there may be a lack of transparency since hedge funds may choose to not disclose the contents of their portfolios and may use proprietary investment strategies that are not fully disclosed to its investors. Hedge funds may have illiquid holdings, not allow withdrawals and may distribute securities instead of cash. Securities distributed in-kind may be difficult to value. The valuation of a client’s investments in hedge funds is ordinarily determined based upon valuations calculated by the third-party advisor. Although the Advisor reviews the valuation procedures used by the portfolio funds, the Advisor may not be able to confirm or review the accuracy of such valuations. Page 9 of 12 – Form ADV Part 2A please register to get more info

SFA and its employees have not been involved in any disciplinary events in the past 10 years that would be material to a client’s evaluation of the Advisor or its personnel. please register to get more info

The Advisor is a limited liability company, principally owned by David Kantor, Kristina Alley and David Marion. SFA does not have any affiliated entities. Neither SFA nor any of its representatives receives compensation directly or indirectly from the recommendation or selection of other investment advisors on behalf of its clients. please register to get more info

Trading – Item 11
SFA may recommend that clients make investments in collective investment funds such as mutual funds or exchange traded funds in which employees of the Advisor assets’ are also invested. To avoid any potential conflicts of interest involving personal trades, the Advisor has adopted a Code of Ethics (the “Code”), which includes a formal code of ethics and insider trading policies and procedures.

The Code also requires employees to report personal securities transactions on at least a quarterly basis and provide the Advisor with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. Transactions in initial public offerings and private placements, including interests in private investment funds, require pre-clearance.

Employees and the owners of SFA have accounts that are managed by the Advisor. Those accounts are managed according to investment policy statements and the relevant risk based portfolios described in Item 8. SFA does not believe that these relationships result in a conflict of interest. On the contrary, we believe that this practice results in a closer alignment of interests between SFA and its clients. However, in order to prevent the risk of conflicts that arise in connection with personal trading, these accounts are managed on a discretionary basis and not overseen nor traded by the account owners. When tactical changes are being implemented across client accounts, SFA employee and owner accounts are traded towards the end of a tactical change or as part of an aggregated trade such as a block trade. Because SFA allows for customized client portfolio management, there are often reasons to delay the trading in certain client accounts to address specific client needs. In these cases, there is no reason to delay the trading for SFA employee accounts. Clients and prospective clients may obtain a copy of the Code by contacting Kristina Alley (SFA’s Chief Compliance Officer (“CCO”)) via phone at (505) 501-6200. Page 10 of 12 – Form ADV Part 2A please register to get more info

The Advisor offers both discretionary and non-discretionary client agreements. In the case of the non-discretionary client agreements, SFA does not have the exclusive authority to determine the securities purchased or sold and the amount of securities to be purchased or sold for the client account. Under both types of the Advisor’s agreements, the client has the authority to choose the custodian for their account. SFA is custodian neutral but generally recommends that clients custody their assets with Fidelity Institutional (“Fidelity”). Clients of the Advisor that use Fidelity as a custodian, primarily also utilize brokerage services provided by National Financial Services, Fidelity’s broker- dealer. The third-party investment managers recommended by SFA select the brokers through which they trade.

SFA has negotiated favorable commission rates and terms with Fidelity. The Advisor’s clients that use Fidelity as custodian will also primarily use Fidelity to execute transactions in individual securities such as mutual funds, ETFs and individual securities. The Advisor will attempt to aggregate client transactions as much as possible. Certain investments may not be appropriate for all SFA clients and, as such, shall only be offered to those clients that have investment guidelines and other qualifications that make the investment permissible.

SFA does not actively trade in individual equity or fixed income securities. Clients of SFA may have legacy individual securities or other positions in their accounts. SFA generally expects to make decisions regarding the sale of such legacy positions based on the individual client objective and other applicable considerations. SFA shall execute these transactions through Fidelity or another broker-dealer, as appropriate. Although the commissions and/or transaction fees paid by SFA’s clients shall comply with SFA’s duty to obtain best execution, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where SFA determines, in good faith, that the commission/transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the execution capability, commission rates, and responsiveness. The same considerations are applicable in the event that a Client directs brokerage. The Client should know that directed brokerage may incur greater costs. Accordingly, although SFA will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client account transactions. The brokerage commissions or transaction fees charged by the designated broker dealer/custodian are exclusive of, and in addition to, SFA’s investment advisory fee. SFA does not receive research or any type of soft dollar benefit in connection with any type of client transaction. The Advisor does not recommend nor select broker-dealers inconsideration of whether it receives referrals from a broker-dealer or third party. Page 11 of 12 – Form ADV Part 2A please register to get more info

All client relationships are reviewed, at least, annually. Reviews of client relationships include review of each account held within a client relationship. Relationship reviews are performed by the team responsible for each client relationship. Each client relationship will also be reviewed whenever the Advisor is informed by the client of any changes in the client’s circumstances or when the Advisor believes market conditions or other factors warrant such review. David Kantor, Kristina Alley and/or David Marion are primarily responsible for the review of each client relationship.

Clients receive a report of their relationship on a quarterly basis or more frequently as agreed, showing performance for the period and performance since inception of the advisory relationship. These reports will be in addition to any periodic statements received from the relevant custodians, brokerage firms, investment administrators, third- party investment managers or funds. please register to get more info

SFA does not have any agreements for the referral of clients. No other forms of compensation are provided to SFA or its employees for providing investment advice to Clients of the Advisor. please register to get more info

SFA has custody of client accounts because it maintains authority to directly debit fees from its clients’ accounts. The clients’ respective custodians send statements directly to the clients on, at least, a quarterly basis. Clients should carefully review these statements, in particular listed activity such as monthly fee debits. They should compare these statements to any account information provided by SFA. Clients should notify the Advisor if they are not receiving custodial statements, at least quarterly, from the relevant custodian, brokerage firms, investment administrators and/or third party investment managers. To ensure that notice of fee debits are being sent to our clients, SFA receives quarterly attestations from its primary custodian that statements have been sent to clients. Previously, SFA was deemed to have custody of certain client accounts due to having a standing authorization to process distributions from a client account to a third party. This is called a Standing Letter of Authorization (SLOA). Effective June 2018, SFA has removed all third party SLOA’s from client accounts. Additionally, the money movement authorization status at Fidelity was changed for all accounts to require signed client authorization for any distribution to a third party. SFA is not affiliated with any custodians. Page 12 of 12 – Form ADV Part 2A please register to get more info

The Advisor may maintain discretionary authority over client accounts as described by the relevant investment management agreement. For discretionary authority, the Advisor is appointed as investment Advisor with respect to all assets held from time to time in the applicable account(s), with full discretionary power and authority, without prior consultation with the client, to invest and reinvest the assets in the account(s). The Advisor shall invest in accordance with any objectives, limitations and restrictions specified in the IPS and as agreed to with the client. An investment’s compliance with the IPS shall be determined at the time of the investment’s purchase, based upon the price and the characteristics of the investment known to the Advisor on the date of purchase. please register to get more info

The Advisor will not exercise proxy voting authority over client securities. The obligation to vote client proxies shall at all times rest with the client. Clients should receive all proxies and other solicitations directly from their respective custodians or transfer agents, as applicable. If SFA inadvertently receives proxy information for a security held in a client’s account, then the Advisor will immediately forward such information on to the appropriate client, but will not take any further action with respect to the voting of such proxy. Upon the termination of its Agreement with a client, the Advisor shall make a good faith and reasonable attempt to forward proxy information inadvertently received by Advisor on behalf of the client to the forwarding address provided by the client. please register to get more info

SFA has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. Page 1 of 6 - Form ADV Part 2B - Brochure Supplement
Item 1 Cover Page
A. David E. Marion Santa Fe Advisors, LLC

Form ADV Part 2B - Brochure Supplement Dated March 2019

Contact: Kristina E. Alley, Chief Compliance Officer PO Box 1471 Santa Fe, NM 87504 B.

This Brochure Supplement provides information about David Marion that
supplements the Santa Fe Advisors, LLC Brochure. You should have
received a copy of that Brochure. Please contact Kristina E. Alley, Chief
Compliance Officer, if you did not receive Santa Fe Advisors, LLC’s Brochure
or if you have any questions about the contents of this supplement.

Item 2 Education Background and Business Experience
David E. Marion was born in 1964. He graduated from Texas A&M University in 1986 with a Bachelors of Science degree in Finance. He graduated from Pepperdine University in 1987 with a Masters of Business Administration degree with a concentration in Finance. Mr. Marion is also a Chartered Financial Analyst Charterholder. The Chartered Financial Analyst (CFA) Program is a professional credential offered by the CFA Institute (formerly AIMR) to investment and financial professionals. To become a Charterholder a candidate must satisfy the following requirements. 1. Enter the CFA Program 2. Study for and pass the three levels of exams 3. Become a regular member of the CFA Institute 4. Maintain Charterholder status. For more information please also see www.cfainstitute.org. Mr. Marion founded Santa Fe Advisors in 2014 together with Kristina Alley and David Kantor. Previously, he served as Senior Managing Director and Chief Investment Officer of First Santa Fe Advisors, LLC for three years. Prior to moving to Santa Fe, New Mexico, he spent 18 years at JP Morgan in both Chicago and New York. While at JP Morgan, he worked in both the Investment Bank, where he specialized in covering large institutional investors for alternative credit assets, and in Private Wealth Management, where he managed client relationships and advised on asset allocation and balance sheet solutions. Prior to joining JP Morgan in 1993, Mr. Marion was employed at Daiwa Securities America and Security Pacific Bank. Page 2 of 6 - Form ADV Part 2B - Brochure Supplement
Item 3 Disciplinary Information
Mr. Marion has not been involved in any disciplinary events that would be material to a client’s evaluation of Mr. Marion or of Santa Fe Advisors, LLC.
Item 4 Other Business Activities
A. Mr. Marion is a member of the Performance Santa Fe board. B. Mr. Marion is not actively engaged in any non-investment-related business or occupation for compensation.

Item 5 Additional Compensation

None
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in accordance with the Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with the requirements of supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act (“Act”). The Registrant’s Chief Compliance Officer, Kristina E. Alley, is primarily responsible for the implementation of the Registrant’s policies and procedures and overseeing the activities of the Registrant’s supervised persons. Should an employee, independent contractor, investment adviser representative, or solicitor of the Registrant have any questions regarding the applicability/relevance of the Act, the Rules there under, any section thereof, or any section of the policies and procedures, he/she should address those questions with the Chief Compliance Officer. Should a client have any questions regarding the Registrant’s supervision or compliance practices, please contact Ms. Alley at (505) 501-6200. Page 3 of 6 - Form ADV Part 2B - Brochure Supplement
Item 1 Cover Page
A. Kristina E. Alley

Santa Fe Advisors, LLC

Form ADV Part 2B - Brochure Supplement Dated March 2019

Contact: David E. Marion, Chief Executive Officer PO Box 1471 Santa Fe, NM 87504 B.

This Brochure Supplement provides information about Kristina E. Alley that
supplements the Santa Fe Advisors, LLC Brochure. You should have
received a copy of that Brochure. Please contact Kristina E. Alley, Chief
Compliance Officer, if you did not receive Santa Fe Advisors, LLC’s Brochure
or if you have any questions about the contents of this supplement.

Item 2 Education Background and Business Experience

Kristina E. Alley was born in 1973. She graduated from Bryn Mawr College in 1996 with a Bachelor of Arts degree in Spanish. She graduated from Fordham University in 2008 with a Masters of Business Administration degree with a concentration in Management. Ms. Alley is a CERTIFIED FINANCIAL PLANNER™ professional.

In order to become a CERTIFIED FINANCIAL PLANNER™ professional, a candidate must meet four certification requirements. First, they must complete a college level program of study in personal financial planning and a capstone course registered with the CFP Board. Second, they must successfully pass the CFP® Certification Examination. Third, they must satisfy the requirement of having three years of professional experience. Finally, they must adhere to the Standards of Professional Conduct. After becoming a CFP® professional, there are renewal standards that must be met in order to continue using the CFP® mark. For more information, please visit www.cfp.net. Ms. Alley founded Santa Fe Advisors in 2014 together with David Marion and David Kantor. Previously, she served as a Managing Director of First Santa Fe Advisors, LLC for six years. Before moving to Santa Fe, New Mexico, she was an investment and relationship manager with U.S. Trust Company of New York from 1998 to 2008. She managed portfolios for high net worth private clients including retirement, fiduciary and charitable entities. Previously, she worked as an institutional relationship manager for Page 4 of 6 - Form ADV Part 2B - Brochure Supplement U.S. Trust’s proprietary mutual fund company, Excelsior Funds, and as a customer service manager for Davis Selected Advisors, a mutual fund company.
Item 3 Disciplinary Information
Ms. Alley has not been involved in any disciplinary events that would be material to a client’s evaluation of Ms. Alley or of Santa Fe Advisors, LLC.
Item 4 Other Business Activities
A. Ms. Alley is a trustee of the Santa Fe Preparatory School and serves on its finance and endowment committees. B. Ms. Alley is not actively engaged in any non-investment-related business or occupation for compensation. Item 5 Additional Compensation

None.
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in accordance with the Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with the requirements of supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act (“Act”). The Registrant’s Chief Compliance Officer, Kristina E. Alley, is primarily responsible for the implementation of the Registrant’s policies and procedures and overseeing the activities of the Registrant’s supervised persons. Should an employee, independent contractor, investment adviser representative, or solicitor of the Registrant have any questions regarding the applicability/relevance of the Act, the Rules thereunder, any section thereof, or any section of the policies and procedures, he/she should address those questions with the Chief Compliance Officer. Should a client have any questions regarding the Registrant’s supervision or compliance practices, please contact Ms. Alley at (505) 501-6200. Oversight for Ms. Alley is performed by David E. Marion, Chief Executive Officer of Santa Fe Advisors. Mr. Marion can be reached by calling (505) 501-6200. Page 5 of 6 - Form ADV Part 2B - Brochure Supplement
Item 1 Cover Page
A. David B. Kantor Santa Fe Advisors, LLC

Form ADV Part 2B - Brochure Supplement Dated March 2019

Contact: Kristina E. Alley, Chief Compliance Officer PO Box 1471 Santa Fe, NM 87504 B.

This Brochure Supplement provides information about David Kantor that
supplements the Santa Fe Advisors, LLC Brochure. You should have
received a copy of that Brochure. Please contact Kristina E. Alley, Chief
Compliance Officer, if you did not receive Santa Fe Advisors, LLC’s Brochure
or if you have any questions about the contents of this supplement.

Item 2 Education Background and Business Experience
David Kantor was born in 1959. Mr. Kantor received a Bachelor of Arts degree from Harvard College in 1981 with a concentration in Economics, and a Masters of Business Administration degree in 1986 from the Wharton School of the University of Pennsylvania, with a dual major in Finance and Strategic Planning. Mr. Kantor founded Santa Fe Advisors in 2014 together with David Marion and Kristina Alley. Previously, he served as a Managing Director of First Santa Fe Advisors, LLC for four years. In 1997, Mr. Kantor joined Prudent Management Associates, a wealth management firm with approximately $800 million in assets under management as of December 2011, where he was a partner and ran the firm's Washington, DC office. Previously, Mr. Kantor spent 9 years as a founding partner and principal in Cambridge International Partners, Inc., a New York investment banking boutique specializing in merger and acquisition transactions in the investment management industry. Mr. Kantor has also been a consultant to institutional investment management firms and to the thrift industry, after beginning his career with the First National Bank of Boston.
Item 3 Disciplinary Information
Mr. Kantor has not been involved in any disciplinary events that would be material to a client’s evaluation of Mr. Kantor or of Santa Fe Advisors, LLC. Page 6 of 6 - Form ADV Part 2B - Brochure Supplement
Item 4 Other Business Activities
A. 1. Mr. Kantor is an indirect owner of Prudent Management Associates, an investment advisor registered with the SEC. Mr. Kantor is not a control person of Prudent Management Associates. However, he provides advice to certain clients of Prudent Management Associates. Mr. Kantor receives compensation related to his ownership interests in Prudent Management Associates and for the advice provided to current clients of Prudent Management Associates. There is no affiliation or business relationship between Prudent Management Associates and Santa Fe Advisors.

Santa Fe Advisors does not believe that Mr. Kantor’s activities related to Prudent Management Associates result in a conflict of interest for its clients.

2. Mr. Kantor serves as treasurer of the board for Creative Startups.

B. Mr. Kantor is not actively engaged in any non-investment-related business or occupation for compensation.

Item 5 Additional Compensation

Mr. Kantor receives compensation related to his ownership interest in Prudent Management Associates and for the advice provided to current clients of Prudent Management Associates. There is no affiliation between Prudent Management Associates and Santa Fe Advisors.
Item 6 Supervision
The Registrant provides investment advisory and supervisory services in accordance with the Registrant’s policies and procedures manual. The primary purpose of the Registrant’s Rule 206(4)-7 policies and procedures is to comply with the requirements of supervision requirements of Section 203(e)(6) of the Investment Advisor’s Act (“Act”). The Registrant’s Chief Compliance Officer, Kristina E. Alley, is primarily responsible for the implementation of the Registrant’s policies and procedures and overseeing the activities of the Registrant’s supervised persons. Should an employee, independent contractor, investment adviser representative, or solicitor of the Registrant have any questions regarding the applicability/relevance of the Act, the Rules there under, any section thereof, or any section of the policies and procedures, he/she should address those questions with the Chief Compliance Officer. Should a client have any questions regarding the Registrant’s supervision or compliance practices, please contact Ms. Alley at (505) 501-6200. please register to get more info