J.E. Sandifer Financial Consultants, Inc., dba Sandifer & Associates (“Sandifer & Associates” or
“we”) was founded in 1997 and is owned by James E. Sandifer, President and Chief Compliance
Officer. Sandifer & Associates became a registered investment advisory firm in 2013.
Sandifer & Associates provides investment advisory services to individuals, high net worth
individuals, trusts, retirement accounts and estates. Services include asset management and
financial planning.
As of December 31, 2019, Sandifer & Associates managed $158,243,699 in assets on a
discretionary basis and $5,578,503 on a non-discretionary basis.
Asset Management Services
We provide continuous investment advice and asset management services based on the
individual needs of our clients. Through personal discussions in which goals and objectives based
on your particular circumstances are established, we create and manage a portfolio based on
those objectives. We will ensure that your investments are suitable for you and consistent with
your investment needs, goals, objectives and risk tolerance. Account supervision is guided by
your stated objectives (i.e., capital preservation, income with moderate growth, growth and
income, growth, and aggressive growth, etc.).
We will manage your investment portfolio on a discretionary or a non-discretionary basis. As a
discretionary investment adviser, we will have the authority to supervise and direct the portfolio
without prior consultation with you. Under a non-discretionary arrangement, you must be
contacted prior to the execution of any trade in the account(s) under management. This can result
in a delay in executing recommended trades, which could adversely affect the performance of
your portfolio. 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, you retain the
responsibility for the final decision on all actions taken with respect to the portfolio.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the
management of your investment portfolios, such as prohibiting the inclusion of certain types of
investments in an investment portfolio or prohibiting the sale of certain investments held in the
account at the commencement of the relationship. You should note, however, that if you impose
restrictions it may adversely affect the composition and performance of your investment portfolio.
You should also note that your investment portfolio is treated individually by giving consideration
to each purchase or sale for your account. For these and other reasons, performance of
investment portfolios within the same investment objectives, goals and/or risk tolerance may differ
and you should not expect that the composition or performance of your investment portfolio would
necessarily be consistent with our similar clients.
You are advised to promptly notify us if there are ever any changes in your financial situation or
investment objectives or if you wish to impose any reasonable restrictions upon our management
services.
Separate Account Managers
When appropriate and in accordance with your investment plan, we may recommend the use of
one or more Separate Account Managers, each a “Manager.” Having access to various Managers
offers a wide variety of manager styles, and offers you the opportunity to utilize more than one
6 Sandifer & Associates
Manager if necessary to meet your needs and investment objectives. We will select or
recommend the Manager(s) we deem most appropriate for you. Factors that we consider in
recommending/selecting Managers generally include your stated investment objective(s),
management style, performance, risk level, reputation, financial strength, reporting, pricing, and
research.
The Manager(s) will generally be granted discretionary trading authority to provide investment
supervisory services for the portfolio. Under certain circumstances, we retain the authority to
terminate the Manager’s relationship or to add new Managers without your specific consent. In
other cases, you will ultimately select one or more Managers recommended by us. Fees paid to
such Manager(s) are separate from and in addition to our fee.
In any case, with respect to assets managed by a Manager, our role will be to monitor your overall
financial situation, to monitor the investment approach and performance of the Manager(s), and
to assist you in understanding the investments of the portfolio.
Third Party Wrap Programs
From time to time, we may utilize the separate account managers available in a Third Party Wrap
Program. A Wrap Program is one that charges one fee (the “wrap fee”) for both the Manager’s
fee and the transaction expenses incurred by the account. Our fee is charged separately from
and in addition to the wrap fee.
Financial Planning
We offer financial planning services, which may include a review of all aspects of your current
financial situation, including the following components: cash management, risk management,
insurance, education funding, goal setting, retirement planning, estate and charitable gift
planning, tax planning, and capital needs planning. You should understand that when we are
engaged to address only certain components, your overall financial and investment issues may
not be taken into consideration.
We meet with you to review risk tolerance, financial goals and objectives, and investment time
horizon. Additional meetings may include a review of additional financial information, such as
sources of income, assets, insurance, liabilities, wills, trusts, business agreements, tax returns,
investments, and personal and family obligations.
The financial plan may include both long and short-term considerations, depending upon your
financial situation. Upon completion, a plan is presented to you. At this meeting, you are provided
with recommendations compatible with your stated goals and objectives. An implementation
schedule is reviewed with you to determine what steps will be pursued, and with whom the steps
may be accomplished. You are under no obligation to utilize additional services of ours and our
representatives and are under no obligation to implement the advice or plan. You may choose
all, none or certain specific components of advice and recommendations and may implement the
recommendations through the service providers of your choice.
Fiduciary Disclosure
With respect to any account for which we meet the definition of a fiduciary under Department of
Labor rules, we acknowledge that both Sandifer & Associates and its Related Persons are acting
as fiduciaries. Additional disclosure may be found elsewhere in this Brochure or in the written
agreement between you and Sandifer & Associates.
7 Sandifer & Associates
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In certain circumstances, fees, account minimums and payment terms are negotiable depending
on your unique situation – such as the size of the aggregate related party portfolio size, family
holdings, low cost basis securities, or certain passively advised investments and pre-existing
relationships with you. You may pay more or less than others depending on the amount of assets,
type of portfolio, or the time involved, the degree of responsibility assumed, complexity of the
engagement, special skills needed to solve problems, the application of experience and
knowledge of your situation.
Compensation – Asset Management Services
Pursuant to the annual fee schedule set forth below, the percentage fee corresponding with the
value of all of your related accounts that we manage is applied to your entire portfolio.
Assets Under Management Annual Fee
$0 to $250,000 1.50%
$250,001 to $500,000 1.25%
$500,001 to $1,000,000 1.10%
$1,000,001 to $2,500,000 1.00%
$2,500,001 to 5,000,000 0.85%
$5,000,001 to $10,000,000 0.65%
$10,000,001 to $15,000,000 0.50%
$15,000,000 plus 0.35%
You will be billed quarterly in advance at the beginning of each calendar quarter based upon the
value of your portfolio on the last business day of the previous quarter. Such fees shall become
due and payable the following business day. Fees will be debited from the account in accordance
with your authorization in the Asset Management Agreement. The custodian will send an account
statement to you, at least quarterly, indicating all amounts disbursed from the account including
the amount of management fees paid directly to us.
If an Asset Management Agreement is terminated before the end of the billing quarter, you are
entitled to a prorated refund of any pre-paid advisory fee based on the number of days remaining
in the quarter after the termination date.
Separate Account Manager Fees
In instances where the services of a Separate Account Manager are utilized, the Separate
Account Manager fees will be charged in addition to our fee, and will be detailed in the
Management Agreement signed by you.
Wrap Program Fees
Our fees are charged separately from and in addition to Wrap Program fees.
Compensation – Financial Planning
Financial Planning will be charged on an hourly basis of $200 - $500 per hour, depending on the
complexity of the plan. All financial planning fees are due and payable upon completion of your
financial plan. You will receive an invoice for the financial planning fee.
8 Sandifer & Associates
If a Financial Planning Agreement is terminated before the end of the billing period, you may be
charged a prorated fee based upon the time spent on the engagement prior to the termination.
If you have retained us for asset management services, financial planning services are included
in your quarterly advisory fee for managed portfolios of $500,000 or more.
Other Fees
You may incur certain charges imposed by the custodians and other third parties such as
brokerage commissions, transaction fees, custodial fees, charges imposed directly by a mutual
fund or exchange traded fund in the account, which shall be disclosed in the fund’s prospectus
(e.g., fund management fees and other fund expenses), deferred sales charges, transfer taxes,
wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. We do not receive any portion of the foregoing charges. Such costs, fees
and commissions are exclusive of and in addition to our advisory fee.
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We do not have any performance-based fee arrangements. “Side-by-Side Management” refers
to a situation in which the same firm manages accounts that are billed based on a percentage of
assets under management and at the same time manages other accounts for which fees are
assessed on a performance fee basis. Because we have no performance-based fee accounts,
we have no side-by-side management.
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As described in Item 4, our clients include individuals, high net worth individuals, trusts, retirement
plans and estates.
We require a minimum relationship account value of $350,000 for clients, although this may be
negotiable under certain circumstances. We do not generally impose a minimum annual fee for
any account.
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Loss Your investment plan is based upon the objectives you provide during consultations. The
investment plan will be updated from time to time when you request, or when we determine it to
be necessary or advisable based on updates to your financial or other circumstances.
In accordance with your investment plan, we will primarily invest in exchange traded funds
(“ETFs”) and mutual funds, and to a lesser extent, individual stocks and bonds. Where
appropriate to your situation, we may also recommend investments in fee-only variable annuities.
Mutual funds and ETFs are generally evaluated and selected based on a variety of factors,
including, as applicable and without limitation, past performance, fee structure, portfolio manager,
fund sponsor, overall ratings for safety and returns, and other factors.
Fixed income investments may be used as a strategic investment, as an instrument to fulfill
liquidity or income needs in a portfolio, or to add a component of capital preservation. We will
9 Sandifer & Associates
generally evaluate and select individual bonds or bond funds based on a number of factors
including, without limitation, rating, yield and duration.
For individual stocks, we often utilize fundamental analysis which attempts to measure the
intrinsic value of a security by looking at economic and financial factors (including the overall
economy, industry conditions, and the financial condition and management of the company itself)
to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced
(indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market
movements. This presents a potential risk, as the price of a security can move up or down along
with the overall market regardless of the economic and financial factors considered in evaluating
the securities.
Note: All investments involve the risk of loss, including (among other things) loss of principal, a reduction in earnings (including interest, dividends and other distributions), and the loss of future earnings. Although we manage the assets in a manner consistent with risk tolerances, there can be no guarantee that our efforts will be successful. The investor should be prepared to bear the risk of loss. Our investment approach constantly
keeps the risk of loss in mind. Investors face the following investment risks:
• Management Risks: While we manage your investment portfolios, or recommend one or
more Managers, based on our experience, research and proprietary methods, the value
of your investment portfolio will change daily based on the performance of the underlying
securities in which it is invested. Accordingly, your investment portfolio is subject to the
risk that we or a Manager allocate your assets to individual securities and/or asset classes
that are adversely affected by unanticipated market movements, and the risk that our
specific investment choices could underperform their relevant indexes.
• Risks of Investments in Mutual Funds, ETFs and Other Investment Pools: Investments in
pooled investment funds are generally less risky than investing in individual securities
because of their diversified portfolios; however, these investments are still subject to risks
associated with the markets in which they invest. In addition, pooled investment funds’
success will be related to the skills of their particular managers and their performance in
managing their funds. Pooled investment funds are also subject to risks due to regulatory
restrictions applicable to registered investment companies under the Investment
Company Act of 1940.
• 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 next year will not buy as much
as a dollar today, because purchasing power is eroding at the rate of inflation.
• Foreign Securities Risks: While foreign investments are important to the diversification of
your investment portfolio, they carry risks that may be different from U.S. investments. For
example, foreign investments may not be subject to uniform audit, financial reporting or
disclosure standards, practices or requirements comparable to those found in the U.S.
10 Sandifer & Associates
Foreign investments are also subject to foreign withholding taxes and the risk of adverse
changes in investment or exchange control regulations. Finally, foreign investments may
involve currency risk, which is the risk that the value of the foreign security will decrease
due to changes in the relative value of the U.S. dollar and the security’s underlying foreign
currency.
• 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.
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Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of the firm or the integrity of our
management. We have no information to disclose applicable to this Item.
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We act as an authorized third party of our clients to assist in the administrative tasks of completing
the insurance paperwork for the policy’s agent. We do not receive any commissions or
compensation for these services. You are not obligated to use us for insurance product purchases
and may work with any insurance agent you choose.
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Transactions and Personal Trading Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon
request. Our Code has several goals. First, the Code is designed to assist us in complying with
applicable laws and regulations governing its investment advisory business. Under the Investment
Advisers Act of 1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties,
the Code requires persons associated with us (managers, officers and employees) to act with
11 Sandifer & Associates
honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits such
associated persons from trading or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for Sandifer & Associates’
associated persons. Under the Code’s Professional Standards, we expect our associated persons
to put the interests of our clients first, ahead of personal interests. In this regard, our associated
persons are not to take inappropriate advantage of their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time our associated persons may invest in the
same securities recommended to clients. Under our Code, we have adopted procedures
designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s
personal trading policies include procedures for limitations on personal securities transactions of
associated persons, reporting and review of such trading and pre-clearance of certain types of
personal trading activities. These policies are designed to discourage and prohibit personal
trading that would disadvantage clients. The Code also provides for disciplinary action as
appropriate for violations.
Participation or Interest in Client Transactions
Because client accounts are primarily invested in open-end mutual funds and ETFs, there is little
opportunity for a conflict of interest between personal trades by our associated persons and trades
in client accounts, even when such accounts invest in the same securities. However, in the event
of other identified potential trading conflicts of interest, our goal is to place client interests first.
As outlined above, we have adopted procedures to protect client interests when our associated
persons invest in the same securities as those selected for or recommended to clients. In the
event of any identified potential trading conflicts of interest, our goal is to place client interests
first.
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Best Execution and Benefits of Brokerage Selection
When given discretion to select the brokerage firm that will execute orders in client accounts, we
seek “best execution” for client trades, which is a combination of a number of factors, including,
without limitation, quality of execution, services provided and commission rates. Therefore, we
may use or recommend the use of brokers who do not charge the lowest available commission in
the recognition of research and securities transaction services, or quality of execution. Research
services received with transactions may include proprietary or third-party research (or any
combination), and may be used in servicing any or all of our clients. Therefore, research services
received may not be used for the account for which the particular transaction was effected.
We recommend that clients establish brokerage accounts with Raymond James Financial, Inc.
(“RJF”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to maintain
custody of clients’ assets. We will also effect trades for client accounts at RJF, or may in some
instances, consistent with our duty of best execution and specific agreement with each client,
elect to execute trades elsewhere. Although we may recommend that you establish accounts at
RJF, it is ultimately your decision to custody assets with RJF. We are independently owned and
operated and are not affiliated with RJF.
12 Sandifer & Associates
RJF provides us with access to its institutional trading, custody, reporting and related services,
which are typically not available to RJF retail investors. RJF also makes available various support
services. Some of those services help us manage or administer our clients’ accounts while others
help us manage and grow our business. These services generally are available to independent
investment advisors on an unsolicited basis, at no charge to them. These services are not soft
dollar arrangements, but are part of the institutional platform offered by RJF. RJF’s brokerage
services include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors
or would require a significantly higher minimum initial investment.
RJF generally does not charge you separately for custody services but is compensated by
account holders through commissions and other transaction-related or asset-based fees for
securities trades that are executed through RJF or that settle into RJF accounts. Some
transactions do not incur transaction-related fees. RFK also earns interest on the uninvested
cash in your account.
RJF also makes available to us other products and services that benefit us but may not directly
benefit our clients’ accounts. Many of these products and services may be used to service all or
some substantial number of our accounts, including accounts not maintained at RJF.
RJF’s products and services that assist us in managing and administering clients’ accounts
include software and other technology that (i) provide access to client account data (such as trade
confirmations and account statements); (ii) facilitate trade execution and allocate aggregated
trade orders for multiple client accounts; (iii) provide pricing and other market data; (iv) facilitate
payment of our fees from clients’ accounts; and (v) assist with back-office functions,
recordkeeping and client reporting.
RJF also offers other services intended to help us manage and further develop our business
enterprise. These services may include: (i) technology compliance, legal and business consulting;
(ii) publications and conferences on practice management and business succession; and (iii)
access to employee benefits providers, human capital consultants and insurance providers. RJF
may make available, arrange and/or pay third-party vendors for the types of services rendered to
us. RJF 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 us. RJF may also provide other
benefits such as educational events or occasional business entertainment of our personnel. In
evaluating whether to recommend that clients custody their assets at RJF, we may take into
account the availability of some of the foregoing products and services and other arrangements
as part of the total mix of factors we consider and not solely on the nature, cost or quality of
custody and brokerage services provided by RJF, which creates a conflict of interest. Please note
that as part of our fiduciary duties to clients, we endeavor to always put the interests of our clients
first.
Directed Brokerage
You may direct us to use a particular broker for custodial or transaction services on behalf of your
portfolio. In directed brokerage arrangements, you are responsible for negotiating the commission
rates and other fees to be paid to the broker. Accordingly, if you direct brokerage, you should
consider whether such designation may result in certain costs or disadvantages to you, either
because you may pay higher commissions or obtain less favorable execution, or the designation
limits the investment options available to you.
The arrangement that we have with RJF is designed to maximize efficiency and to be cost
effective. By directing brokerage arrangements, you acknowledge that these economies of scale
13 Sandifer & Associates
and levels of efficiency are generally compromised when alternative brokers are used. While
every effort is made to treat clients fairly over time, the fact that you choose to use the brokerage
and/or custodial services of these alternative service providers can in fact result in a certain
degree of delay in executing trades for your account(s) and otherwise adversely affect
management of your account(s).
By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and
agree that they have the authority to make the direction, that there are no provisions in any client
or plan document which are inconsistent with the direction, that the brokerage and other goods
and services provided by the broker or dealer through the brokerage transactions are provided
solely to and for the benefit of the client’s plan, plan participants and their beneficiaries, that the
amount paid for the brokerage and other services have been determined by the client and the
plan to be reasonable, that any expenses paid by the broker on behalf of the plan are expenses
that the plan would otherwise be obligated to pay, and that the specific broker or dealer is not a
party in interest of the client or the plan as defined under applicable ERISA regulations.
Aggregated Trade Policy
We typically direct trading in individual client accounts as and when trades are appropriate based
on the client’s investment plan, without regard to activity in other client accounts. However, from
time to time, we aggregate trades together for multiple client accounts, most often when these
accounts are being directed to sell the same securities. If such an aggregated trade is not
completely filled, we will allocate shares received (in an aggregated purchase) or sold (in an
aggregated sale) across participating accounts on a pro rata or other fair basis; provided,
however, that any participating accounts that are owned by Sandifer & Associates or its officers,
directors, or employees will be excluded first.
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Asset Management Reviews and Reporting
James E. Sandifer, President and Chief Compliance Officer, or Marc D. Salyers, Portfolio
Manager, have the responsibility for communicating with you, updating changes to your situation
and regularly reviewing your portfolio including the asset allocation and the specific assets
included in the account. Your review includes comparing the portfolio and current security
positions with your goals and objectives, reviewing changes to your investment circumstances,
evaluating the specific holdings, re-balancing the portfolio and communicating the current status
of the portfolio and any recommended actions to you. Reviews may also be conducted if there
are changes in market, political or economic conditions, tax laws, new investment information,
and changes in your own situation.
Account custodians are responsible for providing monthly or quarterly account statements which
reflect the positions (and current pricing) in each account as well as transactions in each account,
including fees paid from an account. Account custodians also provide prompt confirmation of all
trading activity, and year-end tax statements, such as 1099 forms. In addition, we provide at least
an annual report for each managed portfolio. This written report normally includes a summary of
portfolio holdings and performance results. Additional reports are available at your request.
Financial Planning – Reviews and Reporting
Financial Planning engagements will be reviewed as contracted at the inception of the
engagement.
14 Sandifer & Associates
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As noted above, we receive an economic benefit from RJF in the form of support products and
services RJF makes available to us and other independent investment advisors whose clients
maintain accounts at RJF. These products and services, how they benefit us, and the related
conflicts of interest are described in
Item 12 - Brokerage Practices. The availability of RJF’s
products and services to us is based solely on our participation in the programs and not in the
provision of any particular investment advice.
Compensation – Client Referrals – Solicitation Arrangements
We may enter into written arrangements to pay referral fees to other professionals (solicitors) who
refer prospective clients to us. There will be a written agreement between us and the solicitor,
which will clearly define the duties and responsibilities of the solicitor under this arrangement. In
addition, each solicitor is required to provide a written disclosure document, which explains to the
prospective client the terms and compensation structure under which the solicitor is working with
us. The solicitor is also required to furnish a copy of Sandifer & Associate’s Form ADV Part 2 to
the prospective client and obtain a written acknowledgement from the client that both the solicitor's
disclosure document and Sandifer & Associate’s Form ADV Part 2 have been received.
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RJF is the custodian of nearly all client accounts at Sandifer & Associates. From time to time
however, clients may select an alternate broker to hold accounts in custody. In any case, it is the
custodian’s responsibility to provide you with confirmations of trading activity, tax forms and at
least quarterly account statements. You are advised to review this information carefully, and to
notify us of any questions or concerns. You are also asked to promptly notify us if the custodian
fails to provide statements on each account held.
From time to time and in accordance with our agreement with you, we will provide additional
reports. The account balances reflected on these reports should be compared to the balances
shown on the brokerage statements to ensure accuracy. At times there may be small differences
due to the timing of dividend reporting, pending trades or other similar issues.
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As described above under
Item 4 - Advisory Business, we will accept clients on either a
discretionary or non-discretionary basis. For
discretionary accounts this means that after an
investment plan is developed for your investment portfolio, we will execute that plan without
specific consent from you for each transaction. For discretionary accounts, you will execute a
Limited Power of Attorney (“LPOA”) giving us the authority to carry out various activities in your
account(s), generally including the following: trade execution; the ability to request checks on
your behalf; and, the withdrawal of advisory fees directly from your account(s). We then direct
investment of your portfolio using our discretionary authority. You may limit the terms of the LPOA
to the extent consistent with your investment advisory agreement with us and the requirements
of your custodian. The discretionary relationship is further described in the agreement between
you and us.
15 Sandifer & Associates
For
non-discretionary accounts, you also generally execute an LPOA, which allows us to carry
out trade recommendations and approved actions in the portfolio. However, in accordance with
the investment advisory agreement between you and us, we do not implement trading
recommendations or other actions in the account unless and until you have approved the
recommendation or action. As with discretionary accounts, you may limit the terms of the LPOA,
subject to our agreement with you and the requirements of your custodian.
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We do not have any authority to and do not vote proxies on your behalf. You retain the
responsibility for receiving and voting proxies for securities maintained in your portfolios; you
receive these proxies directly from either Raymond James or transfer agents. You may contact
James E. Sandifer at 251-340-1984 with questions relating to proxy procedures and proposals;
however, we generally do not research particular proxy proposals.
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Investment advisers that are registered with the U.S. Securities and Exchange Commission must
provide a balance sheet in conjunction with this Form ADV if they solicit or require prepayment of
fees of more than $1,200 per client, more than six months in advance. We do not require such
payments and therefore are not required to provide a balance sheet to clients.
16 Sandifer & Associates
Form ADV Part 2B – James E. Sandifer Sandifer & Associates Form ADV Part 2B
Investment Adviser Brochure Supplement
Supervisor and Supervised Person: James E. Sandifer, CFP® CRD# 1031904 3615 Old Shell Road
Mobile, Alabama 36608
251.340.1984
www.jesandifer.com
March 10, 2020
This Brochure Supplement provides information about James E. Sandifer that supplements the
Sandifer & Associates’ Brochure. You should have received a copy of that Brochure. Please
contact James E. Sandifer, President and Chief Compliance Officer, if you did not receive
Sandifer & Associates’ Brochure or if you have any questions about the contents of this
supplement.
Additional information about Sandifer & Associates’ Supervised Persons is also available on the
SEC’s website at
www.adviserinfo.sec.gov. You can search this site using a unique identifying
number known as a CRD number. Sandifer & Associates CRD number is 166948.
17 Sandifer & Associates
Educational Background and Business Experience Sandifer & Associates requires a college degree and/or industry experience.
Supervised Person
James E. Sandifer Born 1952
Business Background
Sandifer & Associates 1997 – Present
President/Chief Compliance Officer
Raymond James Financial Services, Inc. 1982 – 2013
Financial Advisor/Registered Principal/Portfolio Manager
Education
B.S. Finance, University of Alabama
Professional Designations
James E. Sandifer is a Certified Financial Planner™ professional.*
* The CFP® certification is granted by Certified Financial Planner Board of Standards, Inc. (CFP
Board). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
such as the CPA, CFA and others may satisfy the education component, and allow a candidate
to sit for the CFP® Certification Examination. A comprehensive examination tests the candidate’s
ability to apply financial planning knowledge to client situations. Qualifying work experience is
also required for certification. Qualifying experience includes work in the area of the delivery of
the personal financial planning process to clients, the direct support or supervision of others in
the personal financial planning process, or teaching all, or any portion, of the personal financial
planning process. CFP® professionals must complete 30 hours of continuing education accepted
by the CFP Board every two years.
Disciplinary Information Neither Sandifer & Associates nor any Supervised Persons have been involved in any activities
resulting in a reportable disciplinary disclosure.
Other Business Activities James Sandifer acts as an authorized third party of clients to assist in the administrative tasks of
completing the insurance paperwork for the policy’s agent. Sandifer & Associates does not
receive any commissions or compensation for these services. Clients are not obligated to use
Sandifer & Associates for insurance product purchases and may work with any insurance agent
they choose.
18 Sandifer & Associates
Additional Compensation Other than as stated above, Mr. Sandifer is not engaged in any other investment-related business
or occupation, and does not earn compensation for the sale of any other products or services.
Supervision James Sandifer, President and Chief Compliance Officer is responsible for supervising Sandifer
& Associates’ advisory activities and managing Sandifer & Associates’ team of supervised
persons. James E. Sandifer supervises these persons by holding regular meetings, which may
include staff, investment, compliance and other ad hoc meetings. Among other things, Mr.
Sandifer reviews client reports and trading, as well as personal securities transactions and
holdings reports. Mr. Sandifer may be reached at 251.340.1984.
19 Sandifer & Associates
Form ADV Part 2B – Marc D. Salyers Sandifer & Associates Form ADV Part 2B
Investment Adviser Brochure Supplement
Marc D. Salyers, CFP® CRD# 6560150 3615 Old Shell Road
Mobile, Alabama 36608
251.340.1984
www.jesandifer.com
March 10, 2020
This Brochure Supplement provides information about the Marc D. Salyers that supplements the
Sandifer & Associates’ Brochure. You should have received a copy of that Brochure. Please
contact James E. Sandifer, President and Chief Compliance Officer, if you did not receive
Sandifer & Associates’ Brochure or if you have any questions about the contents of this
Supplement.
Additional information about Sandifer & Associates’ Supervised Persons is also available on the
SEC’s website at
www.adviserinfo.sec.gov. You can search this site using a unique identifying
number known as a CRD number. Sandifer & Associates CRD number is 166948.
20 Sandifer & Associates
Educational Background and Business Experience Sandifer & Associates requires a college degree and/or industry experience.
Supervised Person
Marc D. Salyers Born 1979
Business Background
Sandifer & Associates 2017 – Present
Portfolio Manager
Aptus Capital Advisors 2016 – 2017
Senior Vice President and Investment Adviser
Morgan Stanley & Associates 2015 – 2016
Financial Advisor Trainee
Samford University 2014 – 2015
Assistant Basketball Coach
Professional Basketball Player in Europe & Asia 2005 – 2014
Education
B.S. Business Administration, Samford University (2015)
Professional Designations
Mark D. Salyers is a Certified Financial Planner™ professional.*
____________________________________________________________________________
* The CFP® certification is granted by Certified Financial Planner Board of Standards, Inc. (CFP
Board). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
such as the CPA, CFA and others may satisfy the education component, and allow a candidate
to sit for the CFP® Certification Examination. A comprehensive examination tests the candidate’s
ability to apply financial planning knowledge to client situations. Qualifying work experience is
also required for certification. Qualifying experience includes work in the area of the delivery of
the personal financial planning process to clients, the direct support or supervision of others in
the personal financial planning process, or teaching all, or any portion, of the personal financial
planning process. CFP® professionals must complete 30 hours of continuing education accepted
by the CFP Board every two years.
Disciplinary Information Neither Sandifer & Associates nor any Supervised Persons have been involved in any activities
resulting in a reportable disciplinary disclosure.
21 Sandifer & Associates
Other Business Activities Marc has no other business activities to disclose.
Additional Compensation Marc is not engaged in any other investment-related business or occupation, and has no other
income or compensation to disclose.
Supervision James Sandifer, President and Chief Compliance Officer is responsible for supervising Sandifer
& Associates’ advisory activities and managing Sandifer & Associates’ team of supervised
persons. James E. Sandifer supervises these persons by holding regular meetings, which may
include staff, investment, compliance and other ad hoc meetings. Among other things, Mr.
Sandifer reviews client reports and trading, as well as personal securities transactions and
holdings reports. Mr. Sandifer may be reached at 251.340.1984.
please register to get more info
Open Brochure from SEC website