Conflicts of Interest Disclosure
Identifying, managing, and mitigating inherent industry conflicts.
As a fiduciary registered with the SEC, Sierra Crest Advisors, LLC is bound by law to act in your utmost good faith and place your interests above our own. However, the nature of the financial services industry dictates that certain conflicts of interest will inherently arise.
Our fee-only compensation model heavily reduces the most common industry conflicts—we do not accept commissions, 12b-1 fees, or third-party kickbacks. Nonetheless, we are committed to absolute transparency regarding the remaining material conflicts associated with our operational structure, as fully detailed in our Form ADV Part 2A.
1. Custodial "Soft Dollar" Benefits & Platform Recommendations
The Conflict: We routinely recommend that clients establish brokerage accounts with specific, independent qualified custodians (e.g., Charles Schwab & Co., Inc.). These custodians provide Sierra Crest Advisors with institutional trading platforms, access to proprietary research, compliance software, and discounted practice management services. These "soft dollar" benefits have independent value to our firm, creating an inherent incentive for us to recommend these custodians based on the benefits we receive, rather than solely on your interest in receiving the most favorable execution.
How We Mitigate This Risk
We do not require clients to use a specific custodian. When we do recommend a custodian, we conduct periodic reviews to ensure their fees, trade execution quality, and technological security remain highly competitive and in the best interest of our clients. We do not use soft dollars to pay for general overhead expenses.
2. Retirement Account Rollover Recommendations
The Conflict: If you leave an employer, we may recommend that you roll over your 401(k) or other ERISA-governed retirement plan assets into an Individual Retirement Account (IRA) managed by Sierra Crest Advisors. Because we charge an asset-based fee on managed accounts, this recommendation directly increases our Assets Under Management (AUM) and our resulting compensation, representing a financial conflict of interest.
How We Mitigate This Risk
We adhere to the Department of Labor’s strict fiduciary guidelines regarding rollover advice. Before recommending a rollover, our advisors conduct a documented, side-by-side analysis comparing your current plan's fees, investment options, and services against the proposed IRA. A rollover is only recommended if it is demonstrably in your best financial interest.
3. Employee Personal Trading
The Conflict: Employees and principals of Sierra Crest Advisors are permitted to buy or sell the same securities for their personal accounts that we recommend to clients. This creates a potential conflict where an employee could hypothetically trade ahead of client orders to secure a better price (known as "front-running"), or allocate favorable trades to their own accounts instead of client accounts.
How We Mitigate This Risk
We enforce a strict, written Code of Ethics. Our policy mandates that client orders must always be executed before or alongside employee block trades. All employees must pre-clear specific types of trades and submit quarterly personal transaction reports to our Chief Compliance Officer to ensure no client is disadvantaged by employee trading activity.
4. Financial Planning Implementation
The Conflict: When we provide financial planning services, we may recommend that you implement the investment portions of the plan through Sierra Crest Advisors’ discretionary management service. Recommending our own firm generates additional fee revenue for us.
How We Mitigate This Risk
You are under absolutely no obligation to implement any financial plan through Sierra Crest Advisors. You maintain the absolute right to take our planning blueprint and execute the recommendations through the broker, adviser, or custodian of your choosing.