Brice Financial Service

Firm Brochure

Firm Brochure

Item 1 – Cover Page

Brice Financial Services, Inc.
2000 Biscayne Blvd, Suite 210
Miami, FL 33137
Phone (305)967-8390
Fax (305)749-6410

June 30, 2016

Brice Financial Services, Inc. (hereinafter “BFS”) is an investment adviser registered with the state of Florida Office of Financial Regulation.  An “Investment Adviser” means any person who, for compensation, engages in the business of advising others, either directly or through publications or writings, as to the value of securities or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as part of a regular business, issues or promulgates analyses or reports concerning securities.  Registration with the SEC or any state securities authority doesn’t imply a certain level of skill or training.

This brochure provides information about the qualifications and business practices of BFS.  If you have any questions about the contents of this brochure, please contact us at (305)967-8390 and/or info@bricefinancial.com.  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 BFS is also available on the SEC’s website at www.adviserinfo.sec.gov .

Item 2 – Material Changes

Material Changes are defined as alterations in philosophy, style, process, strategy or criteria that no longer reflect the terms that the parties originally intended to serve as the basis of their obligation.  These changes are defined internally by BFS management by what would significantly affect a relationship or client.

There are no material changes at this time.

Item 4 – Advisory Business

BFS is an insurance and comprehensive investment advisory firm based in Miami, Florida.  We are a Corporation formed under the laws of the State of Florida. 

Alex Nelson is the Principal Adviser and Chief Compliance Officer of the company. 

Advisory services provided by BFS include investment management services, insurance advisory services, self-directed Individual 401(k) plan and IRA procurement.  These services may be offered to individuals, corporations, pension and profit sharing plans, trusts, estates, charitable organizations, and other business entities on an all-inclusive or individual basis. 

Information is obtained through personal interviews with the Client, including information regarding the Client’s goals, objectives, attitudes toward risk, and insurance planning experience. In the event that information contained in documents (such as account statements) are obtained or provided by the Client to the financial adviser, that information will be reviewed and, to the extent it is pertinent, be taken into account when providing advisory services to the Client. When the Client receives the results of the interviews and analysis provided by the adviser, the Client can then decide to either proceed with the BFS adviser’s recommendations or employ another firm of their choosing.

Prior to entering into a contract for services, BFS and the Client will determine the scope of the services to be provided. BFS mainly uses equity securities, exchange traded funds, mutual funds, corporate securities, municipal securities, U.S. government securities, and insurance products in its Investment Management Services.  After constructing a Client’s investment portfolio, we then open the 401(k) Pension Plan Trust account and/or IRA brokerage account(s), where we monitor the Client portfolio’s performance on an ongoing basis, rebalancing the portfolio whenever necessary, as changes occur in market conditions, Clients’ financial circumstances, or both.

Upon authority given by the Client and in accordance with the Client’s best interests, we gather the necessary information in order to open and fund a self-directed Individual 401(k) with In-plan Roth Rollover amendments; bind new insurance coverage(s) for the next requested effective date; facilitate cancellation of the Client’s previous insurance policy(s); annually supervise, amend, or renew in force insurance coverage; and  annually document and render to the Client upon request, the Client’s in-force health, life, and business insurance coverage and premiums that is currently being maintained by BFS.

Investment Management Services

BFS’s Investment Management Services provide investment advisory and brokerage services that are designed to help clients organize their financial situation and invest their assets based on personal criteria, financial goals, and an investment questionnaire. Such services include the following:

Professional Responsibilities include:

  1. Analysis of the Client’s financial condition;
  2. Recommendations to achieve the Client’s financial objectives;
  3. Assist in opening the 401(k) Pension Plan Trust account and/or IRA brokerage account(s) with Interactive Brokers
  4. Purchase securities investments for Client’s brokerage Account(s), subject to the objectives, limitations, and restrictions set by  the Client;
  5. Implementation of investment strategies concurrent with the Client’s financial objectives;
  6. On-going consulting of securities and non-securities investments;
  7. Periodic review of the performance of the Client’s investments, and periodic reallocation of the Client’s investments based upon changing Client financial objectives;
  8. To render to Client, at least annually, a statement of the investments in their brokerage Account(s);

A BFS financial adviser will interview the Client in order to obtain information regarding the Client’s investment experience, investment objectives and risk profile. The financial adviser uses investment research and portfolio allocation software to evaluate alternative portfolio designs and assist the client in selecting the investment strategies consistent with the Client’s financial objectives. The final portfolio allocation recommended to the Client will be tailored to meet specific client circumstances. In connection with developing a prospective portfolio, the Client’s existing investments are evaluated to determine whether the allocation and type of such assets meet the objectives set forth in the Client’s financial objectives. If the Client so chooses, the financial adviser works with the Client to develop a transition plan in order to reallocate assets. BFS may contract with other firms to provide certain administrative services to BFS in connection with Investment Management Service accounts. Such services may include trade processing, collection of management fees, record maintenance and report preparation.

BFS provides Investment Management securities brokerage services on a discretionary and nondiscretionary basis. 

On a nondiscretionary basis, BFS will obtain Client approval prior to execution of any trade.

On a discretionary basis, BFS is granted full discretion and authority to manage the Client’s account.  Accordingly, BFS is authorized to perform various functions, at the Client’s expense, without further approval from the Client.  Such functions include the determination of securities to be purchased and/or sold, the amount of securities to be purchased and/or sold, the broker-dealer to be used, and the commission rates to be paid.  Once the portfolio is constructed, BFS provides continuous supervision and re-optimization of the portfolio as changes in market conditions and client circumstances may require. 

This type of authorization is done using either the Advisory Services Agreement the Client originally signs with our firm, a limited power of attorney agreement, or trading authorization forms.  Clients are free to limit this authority if they wish to, for example, set a limit on the type of securities that can be purchased for their accounts. Written guidelines or restrictions would be required from the Client so that they may be kept on file for compliance.

Our investment advice is tailored to meet our Client’s needs and investment objectives.  There may be times that BFS will recommend a separate account manager to a Client, and such relationships will be carried out under an individual agreement between the Client and a separate account manager.  Fees for separate account managers are separate and above those fees charged by BFS.  In all cases, BFS is the sole project manager that will coordinate the work of the appropriate parties in a manner consistent with the Client’s objectives and will monitor the performance on at least a monthly basis. BFS will deliver its disclosure brochure, Form ADV Part 2, contemporaneously with the Client executing the agreement for services.  As such, the Client may terminate the Advisory Services Agreement within five business days of the date of acceptance without penalty.  Thereafter, either party, upon 30 days written notice to the other may terminate the Advisory Services Agreement.  Any unpaid annual fees beyond the five business day rescission period are due and payable.  

If a Client wishes to terminate this service, they can do so by writing a letter BFS at least 30 days before the designated termination date.  There will be a charge for any services performed by BFS in the year in which termination notification was given.

BFS recommends that clients check their invoices against the statement(s) that they receive from the qualified custodian.  If there is a discrepancy, please call BFS’s main office number, located on page one of this brochure.

Insurance Advisory Services

In general, the Insurance Advisory Services will address any or all of the following areas of concern and will take the below approximate time to complete:

Personal:   Health, dental, and gap insurance; liability & business umbrella, financial & estate information (15 minutes).

Death & Disability:  Term or permanent life insurance, disability, and cash needs at death, income needs of surviving dependents, estate  planning and long-term care analysis (15 minutes).

Retirement:  Analysis of conservative whole, universal, and indexed universal life and annuity strategies to provide the Client with maximum principal protection from market gyrations (30 minutes).

We review the Client’s proposed and existing insurance policies to ensure proper insurance coverage. A separate advisory premium schedule applies to clients who wish to only engage BFS as their insurance adviser, and have no desire for retirement plan procurement or investment management services. Client renewals with no plan changes are exempt from the annual Insurance Advisory Services Fee, provided that they are only Insurance Advisory clients that are simply renewing their current insurance plan, and no new services are rendered by BFS.

Professional Responsibilities include:

  1. To annually document and render to the Client upon request, the Client’s current in-force health, life, and business insurance coverage and premiums that is being maintained by BFS;
  2. To gather the necessary information to obtain insurance quotes from all the top carriers in the state;
  3. Research the provider networks of each registered insurer for confirmation of whether Client’s required primary care physicians and specialists contracts have been finalized (the tax id is active on the insurers’ networks for the year);
  4. To electronically deliver the schedule of benefits of every insurance plan requested by the Client;
  5. To educate and optimize the Client’s ability to make an informed decision in selecting the proper insurance coverage;
  6. Upon authority given by the Client, bind new insurance for the next requested effective date, facilitate cancellation of the Client’s previous insurance policy(s), annually supervise, amend, or renew in force insurance coverage in accordance with the Client’s wishes;
  7. If health insurance is purchased though the Health Insurance Marketplace, annually render to the Client their current year Form 1095-A for IRS compliance;

The Client may terminate the Insurance Advisory Agreement within five days of the date of execution without penalty to the Client. After the five-day period, either party may terminate the agreement by providing written notice to the other party. In the event the Client terminates the agreement after five days of execution, the Client will be charged the full annual fee for services rendered by BFS.

Individual 401(k)/IRA Procurement Services

BFS assists small business clients in obtaining IRS-approved documents for prototype self-directed 401(k) with In-plan Roth Rollover amendments, obtain Trust EIN(s) from the IRS, and set up the plans with the Client (or the person of the Client’s choosing) as the Trustee. We also provide assistance for opening a trust checking account for the Individual 401(k) plan and gather all the necessary documentation for the Client’s current custodian to transfer funds to Client’s new account(s).

The Client may terminate the Advisory Services Agreement within five days of the date of execution without penalty for a full refund. To exercise rescission rights, Client must notify in writing Brice Financial Services, Inc. prior to midnight of the fifth day. In the event Client wishes to cancel services after that time, a $500.00 administrative fee as well as any actual costs will be deducted from any refunds (up to $750). Once BFS provides the Client with the completed documents, no refund requests will be accepted.

Item 5 – Fees and Compensation

Investment Management Services

BFS charges the annual fee for investment management services for an entire household based on the age of the Head of Household. The annual advisory fee can be paid monthly, semi-annually, or annually based on the Client’s preference.  Investment Management Services always include Insurance Advisory Services; however the Client is under no obligation, and may elect to employ another insurance broker if they wish to.  

BFS requires a minimum of $5,000.00 to open and maintain an individually managed brokerage account. This account minimum may not be waived at the discretion of BFS.

BFS will either invoice the Client directly for payment of the annual Advisory Fee or the fee will be deducted from a designated account through a pre-authorized check draft or credit card authorization. Fees are due no later than upon completion of services rendered. The Client must sign the Advisory Services Agreement permitting the fees to be paid directly from the authorized account(s) provided to BFS. BFS will not have access to client funds for payment of fees without Client consent in writing. The Client may also mail BFS a check for the billing cycle of their choice.

The custodian, Interactive Brokers LLC., will send, at least quarterly, a statement to the Client indicating all amounts dispersed from the account. The Client must review each statement for accuracy. BFS will also receive a copy of Client account statements from the custodian.

Insurance Advisory Services

Prior to engaging BFS, the Client will generally be required to enter into a written agreement with us. The agreement will set forth the terms and conditions of the engagement and describe the scope of the services to be provided and the fee that is due from the Client. Generally, BFS requires the annual fee payable upon entering the written agreement, and the Client’s expectation of full completion of the agreed upon services within a timely manner an acknowledged priority for BFS.

BFS charges the annual fee for insurance advisory services for an entire household based on the age of the Head of Household. The annual advisory fee can be paid monthly, semi-annually, or annually based on the Client’s preference. 

BFS will either invoice the Client directly for payment of the annual Advisory Fee or the fee will be deducted from a designated account through a pre-authorized check draft or credit card authorization. Fees are due no later than upon completion of services rendered. The Client must sign the Advisory Services Agreement permitting the fees to be paid directly from the authorized account(s) provided to BFS. BFS will not have access to client funds for payment of fees without Client consent in writing. The Client may also mail BFS a check for the billing cycle of their choice.

401(k) Review Service – Upon entering into a 401(k) review service with BFS, the Client shall be drafted a concise,  customized synopsis of their 401(k) plan, complete with suggested fund allocations based on the participant’s stated goals, age, and risk assessment.  Although not considered a comprehensive financial planning tool, the focus will be on

the most appropriate securities allocation to help the retirement portfolio meet the Client’s long term objectives. 

The cost for the 401(k) Review service is currently $250.00 for a single 401(k) or IRA account with a menu of up to 30 investment choices. If there are more than 30 investment choices, the total price will be negotiated and agreed upon before any work begins. BFS requires the advisory fee payable upon entering the written agreement.

Separate and Distinct Fees and Expenses

Advice offered by BFS might involve investment in many types of mutual funds, exchange traded funds, and alternate funds. The fees charged are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds, or any portion of the funds of an advisory Client (15 U.S.C. §80b-5(a)(1)). Clients are hereby advised that all fees paid to BFS for investment advisory services are separate and distinct from the fees and expenses charged by mutual

funds or exchange traded funds to their shareholders. These fees and expenses are described in each fund's prospectus.

These fees generally include a management fee, other fund expenses, and a possible distribution fee.  If the fund also imposes sales charges, a Client may pay an initial or deferred sales charge.  Further, there may be transaction charges involved with purchasing or selling of securities in the portfolio.  These charges include custodial fees, broker fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.

BFS does not share in any portion of the brokerage fees/transaction charges imposed by the custodian holding the Client’s funds or securities. The Client should review all fees charged by mutual funds, BFS, and others to fully understand the total amount of fees to be paid by the Client. 

Item 12 further describes the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions).

General Information on Advisory Services and Fees

BFS does not represent, warranty, or imply that the services or methods of analysis used by BFS can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines.

A Client could invest in securities directly, without the services of BFS. In that case, the Client would not receive the services provided by BFS which are designed, among other things, to assist the Client in determining which securities or funds are most appropriate to each Client’s financial condition and objectives. Accordingly, the Client should review both the fees charged by the funds and the fees charged by BFS to fully understand the total amount of fees to be paid by the Client and to thereby evaluate the advisory services being provided.

Assets Under Management

As of 06/30/2016, BFS manages $42,560 in Client assets, all on a discretionary basis.

Item 6 – Performance-Based Fees and Sided-By-Side Management

BFS does not charge performance-based fees, as we believe this will avoid conflicts of interest that could result from favoring accounts where management fees have the potential to be substantially higher.

Item 7 – Types of Clients

BFS offers investment advisory and portfolio management services to individuals, corporations, pension and profit sharing plan participants, guardianships, trusts and estates, charitable organizations and foundations. 

BFS requires a minimum account size of $5,000.00 to open and maintain a brokerage account. However, BFS recognizes that there are other factors that can be taken into account to open an account for less than $5,000.00. At BFS’s sole discretion, we may waive this requirement. This requirement can be met by combining two or more accounts owned by the Client or the Client’s related family members. Where BFS waives this account minimum, the annual advisory fee will be due in full, and the Client must deposit a minimum of $5,000.00 into their brokerage account no later than December 31st of the year they signed their Advisory Services Agreement.

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss

In conducting the analysis of securities, BFS uses a number of tools, including commercially available software technology, securities rating services, general market and financial information and due diligence reviews. The principle sources of information include commercially available investment services, financial newspapers, various reports of fund performances, prospectuses, and various financial and business magazines, periodicals and issuer-prepared information, including filings with the Securities and Exchange Commission and financial statements.

BFS may also use outside consultants in certain circumstances to provide expertise in particular areas of information or analysis.

BFS’s primary method of investment analysis is fundamental value, but we also review technical, chart-based analysis and cyclical macroeconomic considerations as part of the investment decision.

Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance.

Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices.  However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them.

Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit position. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may underperform other trading methods when fundamental factors dominate price moves within a given market.

Chart-based analysis involves the use of patterns in performance charts. We may use charting techniques to search for patterns which might identify favorable conditions for buying and/or selling a security.

Cyclical analysis involves evaluating recurring price patterns and tends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends.

Investment Strategies

In regards to BFS’s Large Cap Value Equity Program, BFS is a value/yield manager. The professionals at BFS perform fundamental analysis on individual companies that meet the BFS’s dividend yield criteria. Emphasis is placed on underlying values, free cash flows and the identification of a catalyst that will fuel the eventual realization of those values. Examples of catalysts are merger or management uncertainty, bad press, and increasing business opportunity.

BFS’s universe of securities includes stocks with above average yields because they provide a measure of downside protection and are less volatile than stocks with little or no dividend. Yield also provides an objective characteristic to identify undervalued equities. Currently, the firm will not purchase a stock unless it is yielding 1.6% or higher, and if the yield falls below 0.06% the security is targeted for sale. The firm’s buy and sell disciplines are observed, however, there could be certain instances where the basic sell discipline is suspended by the Chief Investment Officer. This could be appropriate when there is an extreme overall market decline. Every effort will be made to communicate the suspension of the sell discipline to clients, should it occur.

BFS’s discipline strategy is designed to produce above-average, long-term results while taking less than market risk. While most of our excess returns are attributable to bottom-up stock selection, companies do not operate independent of the macro-economic environment. Being a successful in active management equity securities is the result of the application of a disciplined process, one that is centered on exploiting inefficiencies uncovered through extensive research (an investment philosophy known as strong fundamental analysis).  All large cap value client portfolios are individually managed and monitored for consistency throughout portfolios.

Each portfolio is invested in 10 to 30 stocks, approximately equally-weighted. BFS maintains fully invested portfolios and does not rely on market timing. As such, cash is a residual of the investment process. Typically, BFS’s portfolios have an average cash reserve of 2-5% and no more than 10%.

Note:  Because BFS does not follow the GIPS sector classifications for all of the securities held in the large cap value portfolios there could be instances, due to our internal classification of a holding, whereby a sector weighting is more than 20% as stated above. If such an instance does occur, a full explanation of the sector classification difference will be presented. More information on BFS’s buy and sell discipline is available upon request. The key differentiating factors of BFS’s Large Cap Value Equity strategy are low portfolio turnover and high dividend yield relative to Russell 1000 Value Index. By design, the firm’s large cap value investment style is a disciplined strategy which is risk-averse in nature and provides above average, long-term returns with lower market risk. As a manager of domestic equities, BFS is able to offer a superior investment process that uniquely uses dividends as a key selection component. BFS’s advantage and defining characteristic rests in our multi-dimensional approach to stock and ETF selection. Many value managers completely eschew macroeconomic implications and focus entirely on stock selection. In contrast, we are a true bottom-up investment manager, using top-down macroeconomic and sector analysis only to set the stage for our fundamental

analysis. Our active approach to risk control enables us to construct portfolios with risk characteristics that compare favorably to our benchmarks while increasing the likelihood of superior risk-adjusted returns.

Management by Alex Nelson of certain client’s equity portfolios is nearly identical to that of BFS’s Large Cap Value Program in the scope of research protocol, analysis of prospective securities, investment philosophy, investment strategy, and risk profile for potential losses.

Equity Research and Philosophy:

  1. Mixed-Long (Luke) portfolios, he fully relies on fundamental, bottom’s-up research, though on a rare occasion, he will employ a top-down approach for thematic purposes. Portfolios hold a moderately over-weighted position-size of his “best ideas” (those owned in certain concentrated portfolios), and the remainder of the portfolio is filled-out with favorite positions owned in BFS’s  Large Cap Value Program, often according to sector weight preferences. Such portfolios typically hold between 15-20 issues.
  2. Concentrated-Long (Fire) portfolios only hold “best idea” stock selections, and these portfolios typically hold between 25-35 issues. Despite the slightly higher concentrations, the equity risk parameters of these portfolios have not proven to be significantly greater that of the Large Cap Value Program, as most holdings in these portfolios are Large-Cap and Mid-Cap issues – with only a dash of Small-Caps. For certain managed separate equity accounts, most are smaller and have differing risk tolerances, BFS employs blended fixed income and equities (balanced), or pure equity. The balancing in these accounts represents yield embellishment generally in the mix of equities and bonds, and also provides differing degrees of risk amelioration by not having the higher risks of a pure equity portfolio. In the equity selection of both styles of account diligent research is applied to all equity names and a blend is usually according to the risk tolerances

and income needs of the client. The equity portfolios adhere to sector balancing considerations and equity style considerations such as growth, growth at a reasonable price (GARP), and value. Preference is toward large capitalization market leaders, dividend payers, strong balance sheets and strong and secure managements.

Alex’s equity management leans to a style blend and to long term holdings.  Many, but not all positions are Large Cap Value Program top fifty stocks and most, but not all, are large capitalizations.

BFS’s Fixed Income investment protocol and philosophy:

For Fixed Income, BFS uses many of the same researching tools as are used in Equity Research such as credit rating, balance sheet study, industry top-down and database type research, and fundamental bottoms-up statistical research. But in fixed income research, duration, credit ratings, liquidity, yield based pricing, and full knowledge of the huge over the counter market places and the trading techniques are very important to understand as well as disciplines which are by the nature of the vehicles and process every bit as important as they are different to the equity researcher. Bonds are not readily saleable, except for commercial paper and US Treasuries.

The important judgment made about investing in bonds is the old adage about not only getting the receipt of your interest but of your principal as well. To this end, BFS policy arrived at as well by knowing customer risk tolerances requires mainly in investing to get a short 4-6 year duration using laddered type arrangement of like amounts of principal annually maturing from 1 to 7 years. US Treasuries, corporate bonds and notes, and municipal tax exempt debt are most frequently the fixed vehicles of choice and those rated as investment grade BAA-BBB or better.

Of late, short corporate debt has been used in blended portfolios with other laddered types of debt or with equities. Not only have yields been higher, but the visibility by research into the companies and balance sheets has made it possible to determine the risk of leverage to the company; something that is very difficult to determine in the taxable and non-taxable sovereign and municipal debt. So to reiterate, BFS requires careful research, rating scrutiny, leverage ratio scrutiny and short duration laddering to protect its portfolios against undue risk in fixed investing. Most important is the discipline of your BFS portfolio manager in applying these practices.

In Alex’s Fixed-Income portfolios, he relies on fundamental, bottom’s-up research of the balance-sheets, debt-structures and ratings of issuers along with research feedback from GimmeCredit, S&P, and Moody’s reports. Such portfolios typically hold between 5-20 issues, depending on their gross size of the account. These accounts are managed in a more “conservative” laddered, buy-and-hold, BBB- or higher rated manner.

Methods of Analysis

BFS utilizes charting in an attempt to forecast future market moves by studying historical data on charts. BFS also employs fundamental analysis in an attempt to determine a security’s value by focusing on underlying factors that affect a company's actual business and its future prospects. The term refers to the analysis of the economic well-being of a financial entity as opposed to only its price movements. Technical Analysis is another technique used by BFS that relies on the assumption that current market data (such as charts of price, volume, and open interest) can help predict future market trends, at least in the short term. It assumes that market psychology influences trading and can predict when stocks will rise or fall.  This technique, as explained earlier, is not employed as much as strong fundamental analysis. BFS will also use cyclical analysis to study different business cycles, specifically analyzing the way security prices follow certain patterns and trends.

Certain investing strategies may not be suitable for many members of the public. Clients need to carefully consider whether the strategies employed will be appropriate in light of their experience, objectives, financial resources and other relevant circumstances.

Investment Risks

General Investment Risk: All investments come with the risk of losing money. Investing involves substantial risks, including complete possible loss of principal plus other losses and may not be suitable for many members of the public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk and you should familiarize yourself with the risks involved in the particular market instruments you intend to invest in.

Market Risk: Market Risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of investment regardless of the operational success of the issuer’s operations or its financial condition.

Loss of Value: There can be no guaranteed assurance that a specific investment will achieve its investment objectives and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and government, economic or monetary policies.

Style Risk: Any of our strategies may invest in both “value” and “growth” investments. With respect to securities and investments we consider undervalued, the market may not agree with our determination that the security is undervalued, and its price may not increase to what we believe to be its full value. It may even decrease in value. With respect to “growth” investments, the underlying earnings or operational growth we anticipate may not occur, or the market price of the security may not increase as we expect it to.

Defensive Risk: To the extent that the strategy attempts to hedge its portfolio stocks or takes defensive measures such as holding a significant portion of its assets in cash or cash equivalents, the objective may not be achieved.

Small and Medium Cap Company Risk: Securities of companies with small and medium market capitalizations (under $2 billion) are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio.

Developing Market Countries: The strategies used in developing market countries are subject to all of the risks of foreign investing generally, and may have additional heightened risks due to a lack of established legal, political, business, and social frameworks to support securities markets, including delays in settling portfolio securities transactions,; currency and capital controls; greater sensitivity to interest rate changes; pervasiveness of corruption and crime; currency exchange rate volatility; as well as inflation, deflation, and currency devaluation.

Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange control regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value, the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are determined by supply and demand in the currency exchange markets, the international balance of payments, governmental intervention, speculation and other economic and political conditions. If the currency in which a security is denominated appreciates against the US Dollar, the value of the security will increase. Conversely, a decline in the exchange rate of the currency would adversely affect the value of the security.

Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer term debt securities are usually more sensitive to interest rate changes.

Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may

also offset the security's liquidity, making it more difficult to sell. Funds investing in lower quality debt securities are more susceptible to these problems and their value may be more volatile.

Concentration Risk: To the extent that the strategy focuses on particular asset classes, counties, regions, industries, sectors, or types of investment from time to time, the strategy may be subject to greater risks of adverse developments in such areas of focus than a strategy that invests in a more broadly diversified variety of investments.

Prepayment or Call Risk: The issuer of a debt security may prepay or call the debt in whole or in part prior to the security’s maturity date. We may be unable to reinvest the proceeds in a security of equivalent quality or paying a similar yield or coupon.

Legal or Legislative Risk: Legislative changes or court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances.

Inflation:  Inflation may erode the buying power of a client’s investment portfolio, even if the dollar value of the investments remains the same.

Risks associated with Securities

Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks.

Municipal/Government Bonds are susceptible to events in the municipality that issued the bond or the security posted for the bond. These events may include economic or political policy changes, changes in law, tax base erosion, state constitutional limits on tax increases, budget deficits, or other financial difficulties, and changes in the credit rating assigned to municipal issues.

Corporate bonds may lose all value in the event of the issuer’s bankruptcy or restructuring.

Common Stocks have often outperformed other types of investments at certain times, however, individual stock prices may go up and down more dramatically. A slower-growth or recessionary economic environment could have an adverse effect on the price of all stocks.

Foreign Securities including American Depository Receipts (ADRs) may involve more risk than investing in U.S. securities. These risks include currency exchange rates and policies, country or government specific issues, less favorable trading practices or regulation, and greater price volatility.

Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are highly dependent on short-term interest rate changes and may be adversely affected by downturns in the U.S. and foreign economies or changes in baking regulations.

Exchange Traded Funds prices may vary significantly from the new asset value due to market conditions. Certain exchange traded funds may not track underlying benchmarks as expected.

Mutual Funds are meant to be long-term investments and may be subject to fees, charges, or other restrictions if redeemed within certain time periods as outlined in the prospectus. Proceeds from mutual fund sales may be credited with a delay. Mutual funds are bought and sold based on a net asset value calculated at the end of each day based on end of day prices. As markets may move significantly lower over the course of the day, purchase or sale prices may differ significantly from intra-day prices. Mutual Funds may value illiquid portfolio holdings based on a modeled price.

Item 9 – Disciplinary Information

BFS has not been subject to any disciplinary events.

Item 10 – Other Financial Industry Activities and Affiliations

Alex Nelson is also a fully licensed Health, Accident, Life and Variable Annuity insurance broker who provides insurance brokerage services for his clients in the state of Florida.

Alex Nelson is the principal and sole owner of Brice Financial Services, Inc., devoting a portion of his time, and deriving a majority of his income from his capacities as lead broker consultant and binder of insurance contracts.  Clients who hire BFS for securities investment management services may also engage Brice Financial Services Inc. as their broker for health, life, disability and long-term care insurance products.

Annualized and trail commissions received by BFS from various insurance companies are a percentage of the compensation for services rendered for insurance products recommended to and purchased by clients.  The client is responsible to BFS for their annual insurance advisory fee for services rendered by their respective BFS adviser.

Clients are instructed that the fees paid to BFS for investment management services are separate and distinct from compensation paid to BFS for insurance –only advisory services. BFS advisory clients are informed that they are under no obligation to use BFS, and may use at any time, the insurance brokerage firm of their choice.

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

BFS has adopted a Code of Ethics, to address investment advisory conduct. It focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest.  BFS desires to comply with all applicable laws and regulations governing its practice. The management of BFS has determined to set forth guidelines for professional standards, under which all associated persons of BFS are to conduct themselves. BFS has set high standards, the intention of which is to protect client interests at all times and to demonstrate its commitment to its fiduciary duties of honesty, good faith and fair dealing with clients.

All associated persons are expected to adhere strictly to these guidelines, as well as the procedures for approval and reporting established in the Code of Ethics primarily related to personal securities transactions, and violations of the Code. In addition, BFS maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by BFS or any person associated with BFS.

Individuals associated with BFS may buy or sell – for their personal account(s) - investment products identical to those recommended to clients. It is the expressed policy of BFS that employees shall not have priority in any purchase or sale over clients’ accounts. (1)(2) Employees must request and receive permission to participate in a trade for a personal account prior to execution of the trade. Client accounts have priority and should be executed prior to any personal account activity. These personal account trades are then monitored and reviewed every day, then compared to month end statements at the end of each month.

BFS does not have any business or financial interests in any securities bought or sold for our client accounts.

Personal Trading Practices

At times BFS and/or its advisers may take positions in the same securities as clients, which may pose a conflict of interest with clients. BFS will generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades. We will not violate our fiduciary responsibilities to our clients.  Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (i.e. a thinly traded stock), disclosure will be made to the Client(s) at the time of trading.

Incidental trading not deemed to be a conflict (i.e. a purchase or sale which is minimal in relation to the total outstanding value, and as such would have negligible effect on the market price), would not be disclosed at the time of trading.

A copy of BFS’s Code of Ethics is available upon request to the Chief Compliance Officer at BFS’s principal office address.

Footnotes:

(1)  This investment policy has been established recognizing that some securities being considered for purchase and/or sale on behalf of BFS’s clients trade in sufficiently broad markets to permit transactions by clients to be completed without an appreciable impact on the markets of the securities. Under certain circumstances, exceptions may be made to the policies stated above. Records of these trades, including the reasons for the exceptions, will be maintained with BFS’s records in the manner set forth above.

(2)  The foregoing does not apply to certain types of securities, such as obligations of the U.S. Government, and shares in open-end mutual funds. Open-end mutual funds are purchased or redeemed at a fixed net asset value price per share specific to the date of purchase or redemption. As such, transactions in mutual funds by Advisory Representatives are not likely to have an impact on the prices of the fund shares in which clients invest.

Item 12 – Brokerage Practices

BFS does not maintain custody of client assets. Client assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. BFS uses and recommends Interactive Brokers LLC., a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. Interactive Brokers was chosen based on their relatively low transaction fees, quality of operations, and access to a wide range of securities, ETFs, and markets.

BFS is independently owned and operated and not affiliated with Interactive Brokers LLC. Interactive Brokers LLC. will hold client assets in a brokerage account and buy and sell securities when BFS instructs them to. While BFS recommends clients use Interactive Brokers LLC.as custodian/broker, the Client will ultimately decide whether to do so, and open their account with Interactive Brokers LLC. by entering into an account agreement directly with them. BFS may assist clients in the preliminaries of opening their own accounts, however the responsibility of the actual opening and initial funding of the account lies with the Client.

Even though client accounts may be maintained at Interactive Brokers LLC., BFS can still use other brokers to execute trades for Client accounts as described below.

BFS seeks to recommend a custodian who will hold a Client’s assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. BFS will consider a wide range of factors, including:

  1. A combination of transaction execution services along with asset custody services (generally without a separate fee for custody)
  2. Capability to execute, clear and settle trades (buy and sell securities for Client accounts)
  3. Capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment)        
  4. Breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.)
  5. Availability of investment research and tools that assist us in making investment decisions
  6. Quality of services
  7. Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc) and willingness to negotiate them
  8. Reputation, financial strength, and stability of the provider
  9. Availability of other products and services that benefit the Client.

For BFS Clients’ accounts that Interactive Brokers LLC. maintains, Interactive Brokers LLC. does charge separate custody services for IRAs (none for Trust Accounts) and  is also compensated by charging Clients’ commissions or other fees on trades that it executes or that settle into a Client’s Interactive Brokers account. If it is chosen to trade using a prime broker or trade away, Interactive Brokers charges the Client a flat dollar amount as a “prime broker” or “trade away” fee for each trade that BFS has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into the Client’s Interactive Brokers account. These fees are in addition to the commissions or other compensation clients pay the executing broker-dealer. Because of this, in order to minimize trading costs, BFS has Interactive Brokers execute most trades for client accounts. BFS has determined that having Interactive Brokers execute most trades is consistent with our duty to seek “best execution” of client trades.

Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. BFS maintains relationships with a limited number of other broker-dealers. While a client is free to select the broker or other service provider of his or her choosing, BFS typically recommends that a Client establish an account with a brokerage firm with which BFS has an existing relationship. As to such brokers, BFS might, in certain circumstances, be deemed to be receiving a benefit in the form or research, market information, and/or administrative services. While BFS believes the service providers recommended by or with which BFS has relationships (including the brokerage firms) provide benefits to the Client, each client is expressly advised to evaluate any recommended broker or other service provider to ensure that they are acceptable to them. Where a separate account manager is used, the separate account manager may select the broker-dealer to execute the transactions in the portfolio that it is managing, in which case the separate account manager will have the responsibility for negotiation of the amount of commissions charged.

BFS has adopted a policy on selecting brokers and dealers which requires that "best execution”, adherence to fiduciary duty and compliance with the law are paramount considerations in selecting a broker or dealer to effect transactions for client accounts. In determining whether a particular broker or dealer is likely to provide best execution in a particular transaction, BFS considers factors that it deems relevant to the broker’s or dealer’s execution capability, including, for example, commission rates, resolution of trade errors, settlement capabilities, trade execution, block trading capabilities, available research, products and services received, and the reputation and financial stability of the broker or dealer.

Best execution is not measured solely by reference to commission rates. Paying a broker a higher commission rate than another broker might charge is permissible if the difference in cost is reasonably justified by the quality of the brokerage services offered. Also, BFS may cause the account to pay a higher commission in recognition of the value of “research services” and additional brokerage products and services a broker-dealer has provided or may be willing to provide, as described more fully below.

Soft Dollar Arrangements

BFS does not receive benefits from broker-dealers that are referred to soft dollar agreements, in order to avoid any conflict of interests with our clients.   

Brokerage for Client Referrals

BFS does not receive client referrals from broker-dealers and custodians in which we have an institutional advisory arrangement.  BFS does not use client brokerage to compensate, or otherwise reward, any brokers for client referrals.

Clients Directing which Broker-Dealer or Custodian to Use

The Client may not direct brokerage to a specified broker-dealer other than the firm recommended by BFS. The reason for this is that it will be up to the Client to negotiate the commission rates, as BFS would not. The Client may not be able to negotiate the most competitive rate, and as a result, the Client may pay more than the rate available through the broker-dealer used by BFS.  In Client-directed brokerage arrangements, the Client may not be able to participate in aggregated (“blocked”) trades, which may help reduce the cost of execution. BFS recommends only broker-dealers with competitive commission rates, and by requiring clients to use our specific custodian, Interactive Brokers LLC., BFS acknowledges we may be unable to achieve the most favorable execution of client transactions and that this may cost clients’ money over using a lower cost custodian.

Trade Aggregation

For discretionary accounts, BFS will generally aggregate orders with respect to a security if such aggregation is consistent with achieving best execution for the various client accounts. When orders are aggregated, each participating account will receive the weighted average share price for all transactions in a particular security effected to fill such orders on a given business day. Transaction costs will be shared pro rata based upon each account’s participation in the transaction. Commissions for block transactions are based on the individual account relationship with the qualified custodian and will typically vary on an account by account basis, for example, commissions may be higher or lower predicated on the individual account meeting preset minimums established by the custodian.

While individual client advice is provided to each account, client trades may be executed as a block trade. BFS encourages its existing and new clients to use Interactive Brokers. Only accounts in the custody of Interactive Brokers would have the opportunity to participate in aggregated securities transactions. All trades using Interactive Brokers will be aggregated and done in the name BFS. The executing broker will be informed that the trades are for the account of BFS’s Clients and not for BFS itself. No advisory account within the block trade will be favored over any other advisory account, and thus, each account will participate in an aggregated order at the average share price and receive the same commission rate. The aggregation should, on average, reduce slightly the costs of execution, and BFS aggregates Client transactions for discretionary accounts, but it does not aggregate transactions for non-discretionary accounts.

Confidentiality

Accordingly, Clients are hereby advised that non-discretionary accounts may receive different prices for the same securities transactions than discretionary accounts. Additionally, Clients who enter non-discretionary arrangements with BFS may not be able to buy and sell the same quantities of securities and may be charged higher commissions or fees than Clients who enter into discretionary arrangements. BFS will not aggregate a Client's order if in a particular instance BFS believes that aggregation would cause the Client's cost of execution to be increased. Interactive Brokers will be notified of the amount of each trade for each account. BFS and/or its Advisory Representatives may participate in block trades with Clients, and may also participate on a pro rata basis for partial fills, but only after the determination has been made that Clients will receive fair and equitable treatment.

Item 13 – Review of Accounts

Client accounts are monitored on a daily basis with a formal review conducted at least quarterly. Additional reviews may be provided at the client’s request, based on deposits and/or withdrawals in the account, material changes in the Client’s financial condition, or at the Portfolio Manager’s discretion. The individuals conducting reviews may vary from time to time, as personnel join or leave BFS.  Reviews are currently conducted by Alex Nelson, Principal and Chief Investment Officer.

During the regular review, the account’s performance is compared against like-managed accounts to identify any unacceptable performance deviation. Additionally, reasonable client imposed restrictions will be reviewed to confirm that they are being enforced. Events that trigger a special review would be unusual performance, addition or deletions of Client-imposed restrictions, excessive draw-down, volatility in performance, or buy and sell decisions from the Firm or per Client’s needs.

The custodian holding the Client’s funds and securities will send the Client a confirmation of every securities transaction and a brokerage statement at least quarterly, as BFS does not provide written reports to clients.

BFS offers all advisory clients a portfolio and insurance plan review on an annual basis.  The reviews are performed by the Client’s Financial Adviser. The Chief Compliance Officer shall monitor the investment portfolios and insurance policies for investment objectives and other supervisory review.

Item 14 – Client Referrals and other Compensation

Brice Financial Services, Inc. does not receive any economic benefit, directly or indirectly from any third party for advice rendered to our clients. As a fiduciary, BFS endeavors to act in the best interests of our clients.  

Referral Fees Paid

BFS may compensate individuals and/or entities for client referrals. All solicitor agreements are in compliance with the Investment Advisers Act of 1940 and applicable state regulations. In addition, all applicable federal and state laws will also be observed. Fees that BFS charges clients introduced by solicitors will not be greater than the fees of advisory clients who were not introduced by solicitors and who have similar portfolios under BFS’s management. BFS usually compensates the solicitor with a portion of the advisory fee received from the introduced client.

Clients procured by solicitors will be given full written disclosures describing the terms and fee arrangements between the adviser and the solicitor prior to or at the time of entering into the advisory agreement.  All solicitors are required to be licensed in the state of Florida as investment adviser representatives and provide solicitor brochures to potential clients in addition to the BFS brochure.

Item 15 – Custody

Under State of Florida regulations, BFS is deemed to have custody of Client assets if, for example, the Client authorizes BFS to instruct the custodian to deduct our advisory fees directly from the client’s account or if the Client grants BFS authority to move their money to another person’s account.

BFS does not have the ability to withdraw funds or securities from Client’s account. The custodian maintains actual custody of Client assets. Clients will receive account statements directly from their custodian at least quarterly. They will be sent to the email or postal mailing address provided by the Client. Clients should carefully review those statements promptly when received. The custodial statement is the official record of the Client’s account for tax purposes.

Item 16 – Investment Discretion

Generally, clients grant BFS complete discretion over the selection and amount of securities to be bought or sold, the broker or dealer to be used, and the commission rates to be paid for their account without obtaining their prior consent or approval. At the start of the advisory relationship, the Client will execute a Limited Power of Attorney which will grant BFS discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the Client.

Investment Management Services - All Clients contracting with BFS for these services utilize BFS’s model portfolio and generally do not set any conditions or guidelines on managing these accounts. In limited situations, BFS may manage Client accounts, within guidelines requested by the Client, such as restricting individual securities within an industry sector or limitations on additions to concentrated holdings, only to the extent that the ability to effectively and efficiently manage the Client’s portfolio is not hindered and the performance of the portfolio is not significantly affected. Prior to BFS entering into an engagement with a Client for investment management services, an investment representative of BFS will work with the Client to determine if their financial circumstances are suitable based on the investment strategy utilized under this platform.

BFS recommends that clients in need of brokerage and custodial services utilize Interactive Brokers LLC, a registered broker-dealer, member SIPC. Interactive Brokers provides BFS with access to its institutional trading and custody services, which are typically not available to Interactive Brokers retail investors. These services generally are available to independent investment advisors on an unsolicited basis. Such services are not otherwise contingent upon BFS committing to Interactive Brokers any specific amount of business (assets in custody or trading). Interactive Brokers’ services include brokerage, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or that would require a significantly higher minimum initial investment.

For BFS’s Client accounts maintained in its custody, Interactive Brokers does charge separately for custody of IRA funds (currently $30 per year), but does not for 401(k) Trust accounts. Interactive Brokers is also compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Interactive Brokers or that settle into Interactive Brokers accounts. BFS does not share in any portion of the commissions/transaction charges imposed by Interactive Brokers. The commissions and/or transaction fees charged by Interactive Brokers or any other designated broker-dealer are exclusive of and in addition to BFS’s advisory fees.

Item 17 – Voting Client Securities

BFS does not vote client proxies. It is the Client's responsibility to vote proxies. Clients will receive proxy materials directly from the custodian. Questions about proxies may be made via the contact information on the cover page.

Item 18 – Financial Information

Registered investment advisers are required to provide Clients with certain financial information or disclosures BFS’s financial condition. BFS has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients, and has not been the subject of a bankruptcy proceeding.  BFS does not take physical custody of Client funds or securities, does not serve as a trustee or signatory for Client accounts, and does not require the prepayment of over $500, six or more months in advance of services rendered. Therefore, BFS is not required to include a financial statement with this brochure.

Item 19 – Requirements for State-Registered Advisors

Principal Executive Officers and Management Persons

Alexander Brice Nelson

Formal Education after High School:

-  Bachelor of Arts in Political Science, - Florida International University, 2007.

Business Background for the Previous 10 Years:

-  Brice Financial Services, Inc., President/ Senior Financial Adviser /Chief Compliance Officer, 08/2011 to Present.

-  Apollo Education Group, Financial Adviser, 7/2010 – 8/2011

-  Universal Insurance Services, Financial Adviser, 11/2006 to 07/2010.

Outside Business Activities

Mr. Nelson does not have any relationship or arrangement that is material to BFS’s advisory business or to BFS’s clients. Relationships or arrangements with another financial industry participant are conducted solely on an unaffiliated, independent basis. Please refer to Item 10 above for more information about BFS’s financial industry affiliations.

Performance Based Fees

BFS and our Associated Persons do not accept performance based fees. Performance based fees are based on a share of capital gains on or capital appreciation of the Client’s assets. Performance based fees, and the conflicts associated with them, are described in Item 6 of this Brochure.

Material Disciplinary Information

Mr. Nelson has not been involved in any reportable disciplinary events.  No management person at Brice Financial Services Inc. has ever been involved in an arbitration claim of any kind, or been liable in a civil, self-regulatory organization, or administrative proceeding.

Other Relationships or Arrangements with Issuers of Securities

BFS and our related persons do not have any relationships or arrangements with any issuer of securities.

Item 20 – Miscellaneous

Class Action Lawsuits

From time to time, securities held in the accounts of Clients will be the subject of class action lawsuits. BFS has no obligation to determine if securities held by the Client are subject to a pending or resolved class action lawsuit. BFS also has no duty to evaluate a Client’s eligibility or to submit a claim to participate in the proceeds of a securities class action settlement or verdict. Furthermore, BFS has no obligation or responsibility to initiate litigation to recover damages on behalf of Clients who may have been injured as a result of actions, misconduct, or negligence by corporate management of issuers whose securities are held by clients.

Where BFS receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by a Client, it will forward all notices, proof of claim forms, and other materials, to the client. Electronic mail is acceptable where appropriate, and the client has authorized contact in this manner.

Confidentiality

BFS views protecting its customers’ private information as a top priority and, pursuant to the requirements of the Gramm-Leach-Bliley Act, the firm has instituted policies and procedures to ensure that customer information is kept private and secure.

BFS does not disclose any nonpublic personal information about its customers or former customers to any nonaffiliated third parties, except as permitted by law. In the course of servicing a client account, BFS may share some information with its service providers, such as transfer agents, custodians, broker-dealers, accountants, and lawyers.

BFS restricts internal access to nonpublic personal information about its clients to those employees who need to know that information in order to provide products or services to the client. BFS maintains physical and procedural safeguards that comply with state and federal standards to guard a Client’s nonpublic personal information and ensure its integrity and confidentiality. As emphasized above, it has always been and will always be BFS’s policy never to sell information about current or former customers or their accounts to anyone. It is also BFS’s policy not to share information unless required to process a transaction, at the request of the Client, or as required by law.

A copy of BFS privacy policy notice will be provided to each Client prior to, or contemporaneously with, the execution of the Advisory Agreement. Thereafter, BFS will deliver a copy of the current privacy policy notice to Clients on an annual basis. If a Client has any questions on this policy, please contact Alex Nelson, President/Chief Compliance Officer, at (305) 967-8390.

Item 1 – Cover Page

Alex Nelson

Brice Financial Services, Inc.
2000 North Bayshore Dr, Suite 210
Miami, FL 33137
Phone (305) 967-8390
Fax (305) 749-6410

Additional information about Alex Nelson is available on the SEC’s website at www.adviserinfo.sec.gov.

Item 2 – Educational Background and Business Experience

Alex Nelson

Formal Education after High School:

- Bachelor of Arts in Political Science, Florida International University, 2007.


Business Background and Experience:

- Brice Financial Insurance Services, Inc., CEO /Chief Investment Officer, 8/2011 to Present.

- Apollo Education Group, Financial Adviser, 8/2007 to 7/2011.

- Royal Caribbean Cruises, LTD., Marketing Consultant, 3/2002 to 5/2007.


Professional Designations, Licensing & Exams

- Series 65 Uniform Investment Adviser Florida State FINRA Registration.

- Class 2-15 Life & Health (Including Annuities & Variable Contracts) Agent License.


Continuing Education for active registration and licensure

Must complete at least 30 hours of continuing education hours bi-annually for FINRA active registration, as well as at least 24 hours bi-annually for Florida Department of Financial Services active insurance agency appointment.

CFP applicant.


Alex Nelson’s FINRA CRD number is 6474481 and his Florida State Agent License number is W051672.

Brice Financial Services, Inc.’s FINRA CRD number is 173358 and the Florida State Agent License number is L095345.

Item 3 – Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Alex Nelson and Brice Financial Services, Inc.  Alex Nelson has no history of legal or disciplinary events.

Item 4 – Other Business Activities

Mr. Nelson does not have any financial industry relationship or arrangement that is material to BFS’s advisory business or to BFS clients and does not receive additional compensation or economic benefits from third party sources in connection to his securities advisory activities at BFS.

Item 5 – Additional Compensation

Mr. Nelson does not receive additional compensation or economic benefits from third party sources in connection to his securities advisory activities at BFS.  He does receive compensation (in the form of nominal health and life insurance new business and renewal commissions) via his capacities as lead broker consultant and binder of insurance contracts for Brice Financial Services, Inc., a registered Florida insurance brokerage firm. Clients who hire BFS for securities advisory services may also use BFS as their insurance broker for health, life, disability and long-term care financial products, but are under no obligation to do so at any time.

Item 6 –Supervision

Alex Nelson is the Chief Investment Officer and Chief Compliance Officer of Brice Financial Services, Inc. In these roles, Mr. Nelson is responsible for the monitoring of client portfolios for investment objectives, insurance review, and other supervisory reviews.

BFS has implemented a Code of Ethics and an internal compliance program that guides each Associated Person in meeting their fiduciary obligations to clients of BFS. Mr. Nelson adheres himself to Brice Financial Services Inc.’s code of ethics and compliance manual as mandated.

BFS is subject to regulatory oversight by various agencies. These agencies require registration by Brice Financial Services, Inc. and its employees. As a registered entity, BFS is subject to examinations by regulators, which may announced or unannounced. BFS is required to periodically update the information provided to these agencies and to provide various reports regarding firm business and assets at least annually.

Item 7 – Requirements for State-Registered Advisers

Disciplinary Information

Alex Nelson has not been involved in any reportable disciplinary events.


Bankruptcy Petition

Alex Nelson has not been subject to a bankruptcy petition.

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