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Part 2A of Form ADV: Firm Brochure
Item 1: Cover Page
AlphaMark Advisors, LLC
810 Wright’s Summit Parkway, Suite 100
Ft. Wright, KY 41011
Telephone: 859-957-1803
Email: ahaggerty@alphamarkadvisors.com
Web Address: www.ALPHAMARKADVISORS.COM
03/05/2025
This brochure provides information about the qualifications and business practices of
AlphaMark Advisors, LLC. AlphaMark Advisors, LLC and will be referred to as
“AlphaMark” throughout this brochure.
In accordance with the Investment Advisers Act of 1940, AlphaMark is registered with the U.S.
Securities and Exchange Commission as an investment adviser; however, being registered does
not imply that AlphaMark or our personnel have a certain level of skill or training.
The information in this brochure has not been approved or verified by the United States
Securities and Exchange Commission (and will be referred to as the “SEC” throughout this
brochure) or by any state securities authority.
Additional information about AlphaMark also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by typing in our name “AlphaMark” or our
identifying number, known as a CRD number. Our firm's CRD number is 109366. If you have
any questions about the contents of this brochure, please contact us at 859-957-1803 or
ahaggerty@alphamarkadvisors.com.
Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
Item 2 Material Changes
For the period ending effective 12/31/2024, there have been no material changes to the Part 2A of Form
ADV: Firm Brochure since the last annual update (which was filed in March 2024).
The SEC adopted "Amendments to Form ADV" in July 2010 changing the ADV to a Firm Brochure
narrative format. After our initial filing of this Brochure ending 3/31/2011, Item 2 “Material Changes” will
be used to provide our clients with a summary of new and/or updated information. We will inform you of
the revision(s) based on the nature of the updated information.
We will ensure that you receive a summary of any material changes to this and subsequent Brochures
within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other
interim disclosures about material changes as necessary.
Our ADV Part 2A Firm Brochure is also available on our website: https://alphamarkadvisors.com/.
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Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
Item 3 Table of Contents
Page
Fees and Compensation
Performance-Based Fees and Side-By-Side Management
Types of Clients
Investment Discretion
Item 1 Cover Page
Item 2 Material Changes
Table of Contents
Item 3
Item 4 Advisory Business
Item 5
Item 6
Item 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16
Item 17 Voting Client Securities
Item 18 Financial Information
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Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
Item 4 Advisory Business
AlphaMark Advisors, LLC, is a SEC-registered investment adviser with its principal place of business
located in Ft. Wright, Kentucky. AlphaMark began business in 1999.
We provide investment advisory services to individually managed accounts.
Principal Ownership. The firm's principal member (i.e., those individuals and/or entities controlling
25% or more of this company) is Michael L Simon, President of AlphaMark Advisors, LLC. AlphaMark
personnel with minority ownership are Kelly E. Owens and Andew C. Becker. See Item 10 Other
Financial Industry Activities and Affiliations and Item 14 Client Referrals and Other Compensation.
Types of Advisory Services. AlphaMark provides portfolio management services and investment
advisory services related to Individual Accounts (Individuals, Institutions, Pension Plans, Profit Sharing
Plans, 401k Plans, Trusts, Foundations, Corporations or other businesses not listed), Certified Divorce
Financial Analysis, Financial and Social Security Planning:
• Individual Account Portfolio Management. Our firm provides discretionary investment
management services based on the individual needs of the client. Generally, AlphaMark allocates
investment management assets of its individually managed accounts among debt and equity
securities, various mutual fund/ETF types and families.
Through personal discussions with the client, goals, objectives, and a client’s personal investment
policy is established based on the client's particular circumstances. In addition, we encourage
clients to let us know of any changes that will occur over time that would affect their investment
views. During our data-gathering process, we determine the client’s individual objectives, time
horizons, risk tolerance, and liquidity needs. All clients are encouraged to meet with their advisor at
least quarterly and we are available to meet as needed to review financial planning issues,
investment objectives and account performance.
For ERISA and IRA accounts: If the Account is part of a pension or other employee benefit plan (a
“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) or an Individual Retirement Account (an “IRA”) governed by the Internal Revenue
Code, we acknowledge that we are a “fiduciary” within the meaning of Section 3(21) of ERISA (but
only with respect to the provision of services described in our Advisory Agreement). We represent
that we are registered as an investment adviser and duly qualified to manage Plan assets under
applicable regulations.
It is important for a client moving funds from an employer sponsored 401K plan to an IRA
(Individual Retirement Account) to weigh their options and chose the solution that is best for them.
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AlphaMark Advisors LLC
Typically, a 401K plan participant has four options after leaving an employer plan.
1. Leave the money in the former employer’s plan
2. Cash out savings and close the account
3. Roll over the 401K savings in a new employer’s or
4. Rollover 401K savings into an IRA.
A client moving assets from a 401K plan and establishing an IRA with our firm receives a 401K
Rollover to IRA Disclosure discussing the pros and cons with each option. It is also important for
the client to research all fees involved with each scenario when making their decision.
Account supervision is guided by the client's stated objectives (i.e., capital appreciation, growth,
income, or growth and income), as well as tax considerations and current risk tolerance. Clients can
impose reasonable restrictions mutually agreed upon in advance with their advisor when investing
in certain securities, types of securities, or industry sectors.
Once the client's portfolio has been established, we monitor the portfolio on a continuous basis, and
as necessary, rebalance the portfolio, based on the client's individual needs in conjunction with
developments in the capital market. See Item 13: Review of Accounts for more details on the
review process.
Our investment recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company and will generally include advice regarding exchange-listed
securities, securities traded over-the-counter, foreign issuers, corporate debt, commercial paper,
certificates of deposit, municipal securities, mutual fund and ETF shares, U.S. government
securities, and options contracts on securities.
Because some types of investments involve certain additional degrees of risk, they will only
be recommended when consistent with the client's stated investment objectives, tolerance for risk,
liquidity and suitability.
Neither AlphaMark nor the client can assign the investment advisory agreement without the prior
written consent of the other party. Transactions that do not result in a change of actual control or
management of AlphaMark will not be considered an assignment.
• Financial Analysis and Planning: Certified Divorce Financial Analysis: AlphaMark has a
Certified Divorce Financial Analyst (CDFA) available to provide financial guidance during the
divorce process. AlphaMark is paid a negotiated rate for divorce-related services such as education
on financial matters related to divorce, working with an attorney or mediator to create a budget,
forecasting long-term financial effects of a settlement/judgement, how to appropriately invest for
the client and family, etc.
Financial/ Social Security Planning: AlphaMark provides financial planning services as requested.
Financial planning is an evaluation of a client’s current and future financial state by using currently
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AlphaMark Advisors LLC
known variables to predict future cash flows, asset values and withdrawal planning. Clients entire
financial and life situation is examined and taken into account as it directly impacts the financial
planning process. Social Security Planning is a separate type of financial plan that is also offered.
Clients who purchase Financial/ Social Security planning services separately pay AlphaMark a fee
and receive a written report which provides the client with a detailed financial plan designed to
assist the client in achieving his or her financial goals and objectives. Implementation and review
are an on-going process.
• Consulting Services Fees: On an as needed basis, AlphaMark will provide investment advisory
services on a consulting basis.
Amount of Managed Assets: As of 12/31/2024, we were actively managing $405,760,183 of clients'
assets, $405,760,183 on a discretionary basis (100%).
Item 5
Fees and Compensation
Individual Account Portfolio Management Fees: Our annual fees to implement investment
recommendations for portfolio management services and investment advisory services for Individual
Accounts (Institutions, Pension Plans, Profit Sharing Plans, 401k Plans, Trusts, Foundations, Corporations or
other businesses not listed) are based upon a percentage of assets under management.
The management fee and schedule are negotiated between each client subject to certain limitations and
approval by AlphaMark. Fees are higher or lower or have a modified billing schedule based on the scope
and or complexity of responsibilities based on a number of factors; including, but not limited to, the
complexity of the client, assets to be placed under management, anticipated future additional assets, related
accounts, portfolio style, account composition, reports, and family relationship.
Generally, the annualized standard fee for Portfolio Management Services is charged as a percentage of
assets under management:
• 1% on the first $1 million of assets,
• 0.8% from $1-2 million of assets,
• 0.7% on assets from $2-3 million, and
• 0.5% on assets over $3 million.
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AlphaMark Advisors LLC
The client’s annual investment management fee will be calculated and paid quarterly, in arrears based on
the market value of the account on the last business day of the quarter. Client accounts under the same
household are grouped together to maximize the fee schedule discount. In addition, AlphaMark charges
each investment account a $25 quarterly account service fee.
From time to time, new investment advisor representatives are employed by AlphaMark. If these advisors
bring clients with them and transition them to become AlphaMark clients, in some cases, these clients have
fee schedules higher, or lower, versus AlphaMark’s general fee schedule. Their fee schedule will be based
on their previous experience (higher or lower) with their advisor and AlphaMark will maintain their
existing fee schedule. The client acknowledges any variation of fee charges that is different than the
standard fee schedule on the Investment Advisory Contract. The maximum negotiated fee schedule ceiling
is 1.25% plus AlphaMark charges each investment account an additional $25 quarterly account service fee.
For some client accounts, AlphaMark’s investment advisory agreement and the custodial agreements from
Charles Schwab & Co., Inc. (Schwab) or registered broker-dealers, members of SIPC, authorize Schwab to
debit the clients account for the amount of AlphaMark's investment management fee and to directly remit
that management fee to AlphaMark in accordance with SEC procedures. The investment advisory
agreement between AlphaMark and the client will continue in effect until terminated by either party by
written notice. AlphaMark's investment management fee shall be pro-rated through the date of termination,
and any remaining balance (if any) shall be promptly refunded to the client.
In addition to our investment management fee, the client will also pay transaction fees and expenses
charged by the custodian. See item 12 Brokerage Practices.
Financial/ Certified Divorce Financial Analysis/Social Security Consultation. AlphaMark's
Financial Planning/ Certified Divorce Financial analysis/Social Security Consultation fee is based on the
breadth of the services being provided and the complexity of each client’s circumstances. All fees are
agreed upon prior to entering into a contract with any client.
Consulting Services Fees: If requested, AlphaMark has the expertise to provide investment advisory
services on a consulting basis. The consulting services fee is determined by the nature of the services being
provided and the complexity of each client’s circumstances. All consulting fees are agreed upon prior to
entering into a contract with any client. An estimate for the total hours is determined at the start of the
advisory relationship and will be billed and due at the end of each quarter.
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AlphaMark Advisors LLC
General Information:
• Limited Negotiability of Advisory Fees. Although AlphaMark has established the general
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-
client basis. Client facts, circumstances and needs are factors considered in determining the fee.
These factors include the complexity of the client, assets to be placed under management,
anticipated future additional assets, related accounts, portfolio style, account composition, reports,
and family relationship among other factors. The specific annual fee is identified in the contract
between AlphaMark and the client. AlphaMark groups certain related client accounts for the
purposes of determining the appropriate fee.
• Termination of the Advisory Relationship. In the event a client terminates our investment
advisory agreement, the client is responsible for the investment advisory fee up until the day the
client terminates our agreement. AlphaMark’s ending fee will be calculated from the end of the
previous quarter to the last day on which the investment advisory agreement is in effect, pro-rated
by the number of days elapsed in the current period as a percentage of the total number of days in
such period. If we cannot bill the account directly, the client is responsible for any final bill owed.
• Additional Fees and Expenses. Although we generally charge the management fee in arrears, at
our sole discretion, we could bill in advance on certain criteria (pre-existing financial planning
client, sub-advisory relationship, anticipated future earning capacity, anticipated future additional
assets, dollar amount of assets to be managed, related accounts, a requirement of the client
relationship, etc.). In addition to our advisory fees, clients are also responsible for the fees and
expenses charged by custodians and imposed by broker dealers, including, but not limited to, any
transaction charges imposed by a broker dealer with which an independent investment manager
creates transactions for the client’s account(s) or termination fees. Please refer to the “Brokerage
Practices” section (Item 12) and “Client Referrals and Other Compensation” section (Item 14) of
this Form ADV for additional information.
Advisory Fees in General. Clients should note that similar advisory services are available from other
investment advisers for similar, higher or lower fees. Part of the compensation of the financial advisors of
AlphaMark is based on the amount of assets the advisor provides investment advisory services to which
creates an inherent conflict of interest for the Advisor to increase assets under his or her management.
Item 6
Performance-Based Fees and Side-By-Side Management
AlphaMark does not charge performance-based fees.
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AlphaMark Advisors LLC
Item 7 Types of Clients
AlphaMark provides advisory services to:
• Institutions
• Individuals – Taxable and Tax Exempt (Including High Net Worth Individuals)
• Pension Plans
• Profit Sharing Plans
• 401K plans
• Trusts
• Foundations
• Corporations or other businesses not listed above
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis. Dependent on the asset allocation of the client, AlphaMark utilizes the following
methods of analysis:
A) Fixed Income. Our analysis of appropriate fixed income instruments for our clients takes into
account the client’s cash flow needs as well as the client’s tolerance for risk. We view fixed income
investments as a necessary part of any portfolio designed to create sustainable income generation. The
majority of the fixed income securities that we purchase for our clients are high quality investment
grade bonds. In some circumstances, corporate and/or municipal bonds can be added to a portfolio in
order to increase the yield of the portfolio. Our analysis includes: a review of current inflation
expectations in order to determine the appropriateness of the duration of a bond portfolio; a review of
current and expected economic conditions in order to determine the appropriateness of the credit quality
of a bond portfolio; and a review of the value of having a laddered portfolio of fixed securities versus
the value of a structured portfolio with short term and longer term fixed income securities based upon
the steepness of the interest rate yield curve. Based upon the size of the portfolio and the client’s need
for liquidity, we could allocate all, some, or none of the Fixed Income asset class using mutual funds
and ETFs.
B) Equity. Our equity investment philosophy is grounded by an appreciation of risk. We believe that it
is possible to identify growing companies by trends in past and forecasted revenues and earnings.
However, it is important to select only those companies that have a sustainable business model through
various economic conditions. A sustainable business model is one that is focused on organic growth
supplemented by acquisitions and capital investment. A strong business model creates shareholder
wealth, as measured by the return on equity that a company produces. A company that produces a
reliable stream of cash from operating activities can succeed in economically challenging times. We
seek to invest in companies with a proven history of consistent growth, sustainable earnings momentum
and the ability to produce a reliable stream of cash flow during all economic cycles. We use a “bottom-
up” internal stock screening process designed to identify companies that produce reliable cash flows
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AlphaMark Advisors LLC
and are priced at a level that allows for growth opportunity. These companies are then subjected to
further fundamental analysis, including return on equity, sufficiency of cash flow to cover capital
spending, operating margin relative to price/sales, financial statement review, focusing on true net
equity value, and enterprise value review. An assessment of trends in the markets and the economy will
provide some influence on the economic sector weightings. We base the investment in individual
equities, or mutual funds or ETFs on the size of the portfolio and the client’s comfort with risk
exposure.
C) Other Investments – Alternative Investments, Real Estate and Commodity Mutual
Funds and ETFs. Alternative investments, real estate, commodities, mutual funds and ETFs can be
added to the portfolio if an investor’s risk profile allows. Alternative, real estate and commodity assets
often react to market conditions differently than traditional investments and can be used to further
diversify a portfolio and/or adapt to changing market conditions such as fluctuating interest rates or
depressed equity market.
Investment Strategies. The ownership of quality stocks, bonds, mutual funds and ETFs is the
foundation of our strategy. To reduce volatility in a client’s portfolio, we diversify by market
capitalization (large and small), and geography (domestic and international). Based on liquidity needs
and tolerance for risk, fixed income securities can also be part of the client’s portfolio. When
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations, we offer the following investment objectives:
• Aggressive Objective. Provide for preservation of capital with an emphasis on long-term growth
without undue exposure to risk and managed to achieve the most favorable after-tax return. Highest
risk tolerance. Higher return potential with the greatest variability of return (volatility). 90%-100%
equities; the remaining 0% to 10% in fixed income, alternative investments or cash equivalents.
Appropriate investments include: Common & Preferred Stocks & ADR’s, Alternative Investments,
Real Estate, Commodities, Options, Stock Mutual Funds, Individual Bonds, Bond Mutual Funds,
Foreign Mutual Funds and ETFs.
• Growth Objective. Provide for preservation of capital with an emphasis on long-term growth
without undue exposure to risk and managed to achieve the most favorable after-tax return. Highest
risk tolerance. Higher return potential with the greatest variability of return (volatility). 70%-90%
equities; 10% to 30% in fixed income, alternative investments or cash equivalents. Appropriate
investments include: Common & Preferred Stocks & ADR’s, Alternative Investments, Real Estate,
Commodities, Options, Stock Mutual Funds, Individual Bonds, Bond Mutual Funds, Foreign
Mutual Funds and ETFs.
• Balanced Objective. Provide for preservation of capital with an equal emphasis on income
generation and long-term growth. To provide results without undue exposure to risk and manage to
achieve the most favorable after-tax return. Above Average Risk Tolerance and relatively high
return potential. Relatively great variability of return. (volatility) 55%-75% equities; 25% to 45% in
fixed income, alternative investments or cash equivalents. Appropriate investments include:
Common & Preferred Stocks & ADR’s, Alternative Investments, Real Estate, Commodities,
Options, Stock Mutual Funds, Individual Bonds, Bond Mutual Funds, Foreign Mutual Funds and
ETFs.
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AlphaMark Advisors LLC
• Income Objective. Provide for preservation of capital with an emphasis on income generation as a
primary objective and long-term growth as a secondary objective. To provide results without undue
exposure to risk and manage to achieve the most favorable after-tax return. Average risk tolerance
and relatively lower return potential. Relatively low variability of return. (volatility) 40%-60%
equities; 40% to 60% in fixed income, alternative investments or cash equivalents. Appropriate
investments include: Common & Preferred Stocks & ADR’s, Alternative Investments, Real Estate,
Commodities, Options, Stock Mutual Funds, Individual Bonds, Bond Mutual Funds, Foreign
Mutual Funds and ETFs.
Long-Term Purchases, Risk Controls and Sell Discipline.
• Long-term Purchases. We purchase securities with the idea of holding them in the client's
account until market conditions indicate a change. Typically, we employ this strategy when we
believe the securities to be currently undervalued, and/or we want exposure to a particular asset
class over time, regardless of the current projection for this class.
• Risk Controls and Sell Discipline. Our process places a strong emphasis on risk controls and
sell discipline using the following circumstances: 1) A material change in company structure or
management; 2) A material change in the industry or economic factors effecting that industry; 3) A
position has grown to an unacceptable weight; 4) Earnings momentum has decreased from previous
estimates; or 5) The security’s stock price has become overvalued by 20% or more based on our
proprietary cash flow models.
Securities investments are not guaranteed and you can lose money on your investments if the
securities purchased decrease in price. We ask that you work with us to help us understand your
tolerance for risk. A risk in a long-term purchase strategy is that by holding the security for a length
of time we do not take advantage of short-term gains that could be profitable to a client. Moreover,
if our predictions are incorrect, a security can decline sharply in value before we make the decision
to sell.
• Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities,
and other publicly available sources of information about these securities, are providing accurate
and unbiased data. While we are alert to indications that data utilized in our analysis is incorrect,
there is always a risk that our analysis could be compromised by inaccurate or misleading
information.
Stock Market Risk. The return on and value of an investment will fluctuate in response to stock market
movements. Stocks and other equity securities are subject to market risks, such as a rapid increase or
decrease in a stock’s value or liquidity, and fluctuations in price due to earning, economic conditions, world
events and other factors beyond our control. A company’s share price can decline if a company does not
perform as expected, if it is not well managed, if there is a decreased demand for its products or services, or
during periods of economic uncertainty or stock market turbulence, among other circumstances.
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ETF Risk. An Exchange trade fund (“ETF”) is a professionally managed marketable security that invests
in a basket of assets such as stocks, short-term money market instruments, other ETFs, and other securities
or any combination of securities, following the fund stated objectives. ETFs experience price changes
throughout the day as they are bought and sold. During extreme market volatility, ETF prices can lag the
actual underlying asset value. This lag usually resolves itself in a short period of time (usually the
following day), however, there is no guarantee this will always occur.
Fixed Income Risk. Fixed income securities also are subject to market risk affecting the fluctuation of
price and value. Fixed income assets have additional potential risks such as inflationary risk, interest rate
risk, credit risk, income risk, currency risk, default/repayment/maturity risk, and quality risk.
Other Important Risk Considerations. Large Capitalization and Small Capitalization equity securities
which, like all equity securities, carry the potential for unpredictable drops in value and periods of
lackluster performance. Large capitalization companies could at times be unable to respond as quickly as
smaller companies to new competition challenges and also not be able to attain the high
growth rate of successful smaller companies. Small capitalization companies or funds could involve
greater risks than large capitalization companies or funds because these companies could lack the
management experience, financial resources, product diversification and competitive strengths of larger
companies. Small capitalization investments can be subject to greater price fluctuations and be less liquid
compared to larger capitalization investments. Foreign securities investments involve risks that could be
different from those of U.S. securities. Foreign securities might not be subject to uniform audit and
financial reporting and disclosure standards. Foreign investments also can be subject to adverse changes in
investment or exchange control regulations, expropriation or confiscatory taxation, political or social
instability, and nationalization of companies or industries. Although we make every effort to preserve and
grow capital, our strategy may not achieve its investment objective due to the risks noted above and clients
should understand investing in financial markets involves a risk of loss of principal that each client should
be prepared to bear.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a client's or prospective
client's evaluation of our advisory business or the integrity of our management. Our firm and our
management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
Other Affiliation(s). Some of the management personnel of AlphaMark can also be member(s) of limited
liability companies (LLCs) and/or general partner(s) to limited partnerships (LPs). For further details see
AlphaMark personnel’s Part 2B of Form ADV Brochure Supplements Item 4: Other Business.
Relationships with Other Advisors & Relationships with Related Persons. Outside of the
relationship referenced herein, neither the Adviser nor any of its management persons have any other
material relationships or conflicts of interest with any financial industry participants other than those
discussed above. Under the Adviser’s compliance policies and procedures, Advisor Representatives are
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AlphaMark Advisors LLC
required to obtain pre-approval of any outside business activities from the Adviser’s chief compliance
officer so that the Adviser can monitor any potential conflicts of interest between the representative and
any clients.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics. Our firm has adopted a Code of Ethics which sets forth high ethical standards of business
conduct that we require of our employees, including compliance with applicable federal securities laws.
AlphaMark and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have
an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general
principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of employee personal quarterly
securities transactions reports as well as initial and annual securities holdings reports that must be
submitted by the firm’s access persons. Among other things, our Code of Ethics requires the pre-clearance
of any employee’s acquisition of securities within set parameters and any new business ownership
relationships. Our Code also provides for oversight, enforcement and recordkeeping provisions.
AlphaMark's Code of Ethics further includes the firm's policy prohibiting the use of material non-public
information. While we do not believe that we have any particular access to non-public information, all
employees are reminded that such information will not be used in a personal or professional capacity. In
accordance with Section 204A of the Investment Advisers Act of 1940, AlphaMark also maintains and
enforces written policies reasonably designed to prevent the misuse of material non-public information by
our firm or any person associated with AlphaMark. We collect nonpublic personal information about our
clients from the following sources: Information we receive directly from our clients on applications or
other forms and information about client’s transactions or from any of AlphaMark’s affiliates or
broker-dealers utilized. AlphaMark does not disclose any nonpublic information about its customers or
former customers to anyone, except as permitted by law. AlphaMark discloses limited information
collected, if necessary, as described above to companies that perform marketing services on its behalf or to
other financial institutions with which it has joint marketing agreements. We restrict access to nonpublic
personal information about its clients to those employees who need to know that information to provide
products or services to their clients and we maintain physical, electronic and procedural safeguards that
comply with federal standards to guard the client’s nonpublic personal information.
A complete copy of our Code of Ethics is available to our advisory clients and prospective clients. You can
request a copy by email sent to ahaggerty@alphamarkadvisors.com, or by calling us at 859-957-1803. Our
Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our
employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii)
implementing such decisions while, at the same time, allowing employees to invest for their own accounts.
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Personal Trading. Our firm and/or individuals associated with our firm can buy or sell for their personal
account’s securities identical to or different from those recommended to our clients. In addition, any related
person(s) who have an interest or position in a certain security(ies) are permitted to recommended the same
securities to a client. We have a written expressed Personal Securities policy that all AlphaMark access
persons adhere to regarding purchasing or selling securities in their personal accounts. The reviewing
officer will not approve a transaction if a material conflict of interest exists.
We can manage individual brokerage accounts for our employees, associated persons, directors, board
members and owners for a fee. These accounts will be managed on a discretionary basis. AlphaMark’s
pre-clearance policies specific to transactions, apply only to those transactions that the associated people
direct themselves. If an employee or associated person of our firm conducts transactions in their account
not managed by AlphaMark, those transactions are subject to our Code. Those accounts and transactions
are subject to the regulations under Section 204A of the Investment Advisers Act of 1940 and are the
responsibility of the employee or associated person to report to AlphaMark’s compliance officer. A
quarterly request for transactions will be made to all employees and associated persons. If there were no
transactions, that must be reported as well.
Prohibited Transactions. Our firm prohibits its employees from becoming involved in “agency cross”
or “principal transaction”. An agency cross transaction occurs when an advisor executes a trade with an
advisory client on one side of the transaction and a non-advisory client on the other. Principal Transactions:
Our firm also prohibits its employees from becoming involved in principal transactions. A principal
transaction is when an adviser purchases any security from or sells any security to a client.
Item 12 Brokerage Practices
Our Fiduciary Duty. As an adviser and a fiduciary to the firm’s clients, AlphaMark’s clients’ interests
are placed first and foremost. AlphaMark’s trading practices and procedures prohibit unfair trading
practices. AlphaMark seeks to disclose and avoid any conflicts of interests or resolve such conflicts in the
client’s favor. Section 206 of the Advisers Act of 1940 makes it unlawful for any advisor, by use of the
mail or by any means or instrumentality of interstate commerce, directly or indirectly to:
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AlphaMark Advisors LLC
• employ any device, scheme, or artifice to defraud any client or prospective client;
• engage in any transaction, practice or course of business that operates as a fraud or deceit upon any
client or prospective client;
• engage in any act, practice or course of business that is fraudulent, deceptive or manipulative;
• act as a principal for its own account, or act as broker for another person, knowingly sell or buy any
security from an advisory client without first disclosing in writing its capacity in the transaction and
obtaining the client's consent to the transaction.
Trading. AlphaMark has a fiduciary duty to obtain the best execution of trades for client accounts. To
fulfill this duty, AlphaMark generally must "execute securities transactions for clients in such a manner that
the client's total cost or proceeds in each transaction is the most favorable under the circumstances". The
SEC views best execution as the best qualitative execution, not necessarily the best possible commission
cost. To that extent, if we have more than one custodian holding assets when trading a block trade (multiple
accounts trading the same stock when the strategy sells or buys the position across the firm), trades within
each custodian are added (blocked) together, and custodians are alphabetized then rotated from a fixed list
to ensure one custodian does not receive preferential treatment over another. Example: #1 custodian is
chosen for the first block trade, and then in order each subsequent custodian’s clients are traded. Next
block trade will begin with #2 custodian. This block trading policy will prevent preferential treatment to
clients of one custodian.”
Allocation/Aggregation. We have a fiduciary duty to allocate trades in such a way that AlphaMark’s
own (or affiliated) account(s) do not receive more favorable treatment. We will not give special
consideration or preferential treatment to any account. If we have an opportunity to participate in a limited
issue security, we will exercise our fiduciary responsibility to ensure that client accounts receive the same
attention as our own or affiliated accounts and no account is given favorable treatment.
Selecting Brokers/Custodians. We seek to recommend a custodian/broker who will hold our clients’
assets and execute transactions on terms that are, overall, most advantageous when compared to other
available providers. We consider a wide range of factors, including, but not limited to, combination of
transaction execution services and asset custody services (generally without a separate fee for custody),
capability to execute, clear, and settle trades (buy and sell securities for your account), capability to
facilitate transfers and payments to and from accounts (deposits, wire transfers, check requests, etc.), breath
of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.,
availability of investment research tools that assist us in making investment decisions, quality of services,
competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and
willingness to negotiate the prices, reputation, financial strength, security and stability, prior service to us
and our other clients, services delivered or paid for by Schwab, availability of other products and services
that benefit us, as discussed below (See “Products and Services Available to Us”). We will make every
effort to accommodate a client who wishes to direct trading. Although by directing brokerage transactions,
we would have no involvement over the execution of client transactions, and the transaction costs could be
more expensive to the client.
Custodian and Brokers that We Recommend. We do not maintain custody of assets we manage.
Although technically we can be deemed to have a level of custody of assets if given the authority to
15
Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
withdraw assets from your account (see Item 15 - Custody below). Assets must be maintained in an
account at a “qualified custodian”, generally a broker-dealer or bank. We generally recommend that our
clients use Charles Schwab & Co., Inc. (Schwab), registered broker-dealers, members of SIPC, as the
qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab
will hold your assets in a brokerage account and buy and sell securities as we instruct. While we
recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your
account with Schwab by entering into an account agreement directly with them which we can facilitate for
you. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for
your account if needed as described below (see “Your Brokerage and Custody Costs”).
Brokerage and Custody Costs. For our clients’ accounts that Schwab maintains, brokers generally do not
charge you separately for custody services but brokers are compensated by charging you commissions or
other fees on trades that they execute or that settle into your account. In order to minimize your trading
costs, we have Schwab execute most of your trades to be consistent with our duty to seek “best execution”.
If your account is held in custody at Schwab, but we trade with a different “prime broker” or “trade away”,
Schwab will charge you a flat dollar amount fee for each trade that we have executed by a different broker-
dealer while Schwab act as your custodian, but where the securities bought or the funds from the securities
sold are deposited (settled) into your Schwab account. These fees would be in addition to the commissions
or other compensation you pay the executing broker dealer, which is why we choose to execute the
majority, if not all of your trades through the custodian. (see “Selecting Brokers/Custodian”).
Products and Services Available to Us. Schwab Advisor Services (formerly called Schwab Institutional)
is Schwab’s business unit serving independent investment advisory firms like us. They provide us and our
clients with access to its institutional brokerage-trading, custody, reporting, and related services – many of
which are not typically available to Schwab retail customers. Schwab also makes available support
services. Schwab’s support services generally are available on an unsolicited basis (we don’t have to
request them) and at no charge to us. The investment products available through Schwab include some to
which we might not otherwise have access or that would require a significantly higher minimum initial
investment by our clients and would generally benefit your account. There can be other products and
services that benefit us that would not directly benefit your account since they help us to manage and
administer our clients’ accounts. These include such things as investment research, both Schwab’s own and
that of third parties. We can use this research to service all or a substantial number of our clients’ accounts,
including accounts held by other custodians. In addition to research, Schwab also make available software
and other technology that provide access to client account data (such as duplicate confirmation and account
statements), facilitate trade execution and allocate aggregated trade order for multiple account, provide
security pricing and other market data, facilitate payment of our fees from our clients’ accounts, and assist
with back-office functions/recordkeeping, and client reporting. Schwab also offers other services intended
to help us manage and further develop our business enterprise such as educational conferences and events,
consulting on technology/compliance/legal/business needs and access to employee benefits providers,
human capital consultants and insurance providers. While Schwab can provide some of these services
itself, in other cases, it will arrange for third-party vendors to provide the services to us. Schwab can also
discount or waive its fees for some of these services or pay all or part of a third party’s fees. Schwab could
also provide us with other benefits such as occasional business entertainment of our personnel or
sponsorship of a client event. If you did not maintain your account with Schwab, we would be required to
16
Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
pay for these services from our own resources and these services would not be available to us. The fact that
we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab and is a
conflict of interest. However, our recommendation of Schwab as custodian and broker is in the best
interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s
services and not Schwab’s services that benefit only us. We may also receive sponsorship for a client event
from other vendors that provide our firm and clients with services. If we did not use their services, we would not
receive any sponsorship for client events and would be responsible for all costs. Requesting client event
sponsorship from an outside vendor has no bearing whether we utilize that vendor.
Soft Dollars. We are not participating in Soft dollar programs at this time. Soft dollars are generated from
trading commissions. Investment managers typically use soft dollars to pay for investment research as long
as the expenses paid fall within the “safe harbor” provided by the Section 28(e) of the Securities Exchange
Act of 1934.
Item 13 Review of Accounts
Individually Managed Account Portfolio Management. AlphaMark reviews its clients’ accounts on
an ongoing basis. All clients are encouraged to discuss with their advisor his/her/their investment
objectives, needs and goals and to keep the advisor informed of any changes regarding same. All clients are
encouraged to meet, at least quarterly, with their advisor, to fully review financial planning issues,
investment objectives and account performance. Periodically the Chief Compliance Officer reviews client
accounts for the asset class weightings compared to the portfolio allocations listed in the Client Investment
Policy Statement. The weightings are to be within range or the advisor is to have the client approve such
discrepancies. Advisors are responsible for all levels of client service including but not limited to;
establishing accounts, discussing Investment Policy Statements with clients, implementing those policies,
investing and re-balancing accounts to client’s policy and AlphaMark's approved investments. Account
reviews are done at a minimum on a quarterly basis by the individual advisor, or more frequently if market
changes require re-balancing of individual or sector weights. Clients receive monthly statements and
confirmations of transactions from their custodian and the client is provided access to a separate electronic
reporting portal to access our client reporting.
Other Portfolio Management. Clients where we act as the Sub-Advisor are provided client statements
from their Advisor. Where we act as the manager of a model program, information and reporting is
provided by the sponsoring brokerage firm.
Item 14 Client Referrals and Other Compensation
AlphaMark has established a relationship with a non-affiliated CPA firm. AlphaMark may refer clients to
these firms for tax preparation services. Dependent on a client’s needs and complexity of their tax
preparation, AlphaMark may cover some or all the cost of the tax preparer’s fee.
We receive an economic benefit from our relationship with Schwab. This takes the form of the support
products and services, how they benefit us, and the related conflicts of interest are described above (see
Item 12 – Brokerage Practices.) Our ability to use Schwab’s products and services is not based on us giving
particular investment advice, such as buying particular securities for our clients.
17
Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
Schwab Advisor Network Referral fees. AlphaMark participated in a Schwab client referral program
called the Schwab Advisor Network (“the Service”) until 2006. The Service was designed to help investors
find an independent advisor. As outlined in Item 12 Broker Practices, Schwab is a broker-dealer
independent of and not affiliated with AlphaMark. We paid Schwab fees to receive client referrals through
the Service. Although we have not been a part of the program since 2006, for those accounts we received as
a part of the Service, the process could encourage a conflict of interest, since we are required to compensate
Schwab a set fee for any assets we continue to manage that leave Schwab’s custody. Please contact
AlphaMark if you would like more detailed information on this referral program.
Item 15 Custody
We previously disclosed in the “Fees and Compensation” (Item 5) section of this Brochure that our firm
typically directly debits advisory fees from client accounts giving our firm custody technically of your
assets but only related to fee billing.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from
that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement
showing all transactions within the account during the reporting period.
Schwab maintains actual custody of your assets. You will receive account statements directly from Schwab
at least quarterly. The Schwab statements will be sent to the email or postal mailing address you provided
to Schwab.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to
carefully review their custodial statements to verify the accuracy of the calculation, among other things.
Clients should contact us directly if they believe that there has been an error in their periodic statements
they receive directly from their custodians.
Our firm does not have actual or constructive custody of client accounts. See Item 12 Brokerage Practices
for additional information regarding brokerage and custody.
Item 16
Investment Discretion
Clients can hire us to provide discretionary asset management services, in which case we place trades in a
client's account without contacting the client prior to each trade to obtain the client's permission.
Our discretionary authority includes the ability to do the following without contacting the client; determine
the security to buy or sell; and/or determine the amount of the security to buy or sell and where to trade for
best execution.
Clients give us discretionary authority when they sign a discretionary agreement with our firm, and can
limit this authority by giving us written instructions. At any time, clients can change/amend such
limitations by once again providing us with written instructions.
18
Part 2A of Form ADV: Firm Brochure
AlphaMark Advisors LLC
Item 17 Voting Client Securities and Filing Class Action Claims
Proxy Voting for Advisory Accounts. We do not direct how the proxies beneficially owned by the client
are voted. We instruct the client’s custodian to send all proxy and shareholder communication directly to
the client. If the Investment Account is for a pension or other employee benefit plan governed by ERISA,
the client directs us not to vote proxies for securities held in the account since the right to vote the proxies
is expressly reserved to the plan’s trustees.
Class Action Monitoring and Securities Claim Filing. Advisory clients at times can be entitled to
participate in a security class action litigation and could be notified of a pending or actual class action
filing. In an ongoing effort to serve our clients, we engaged a 3rd party class action litigation specialist
Chicago Clearing Corporation (CCC) to monitor and file these claims on behalf of our clients. We believe
using CCC will maximize the potential recovery of these claims. CCC does retain a set negotiated
percentage of the award payment as a contingency fee. To file the class action paperwork, we are required
to provide private information to CCC using a secure process. Clients can choose not to participate in this
service. A Client can file the class action paperwork without using a service. Please let your advisor know
that you are opting out and we will not include your account in this service. Neither AlphaMark nor CCC
will monitor any class action that a client could be entitled to receive from a settlement who has opted out
of the service provided by CCC.
Item 18 Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than
six months in advance of services rendered. Therefore, we are not required to include a financial statement.
AlphaMark has not been the subject of a bankruptcy petition at any time during the past ten years.
19
Brochure Supplement
Part 2B of Form ADV
Item 1: Cover Page
Michael L. Simon
(CRD# 4365604)
AlphaMark Advisors, LLC
810 Wright’s Summit Pkwy, Suite 100
Ft. Wright, KY 41011
Telephone: 859-957-1803
Date of Supplement:
03/05/2025
This brochure supplement provides information about Michael L. Simon that
supplements the AlphaMark Advisors, LLC brochure. You should have received a copy
of that brochure. Please contact Anne Haggerty (CCO) at (859) 957-1803 if you did not
receive the AlphaMark Advisors, LLC brochure or if you have any questions about the
contents of this supplement.
Additional information about Michael L. Simon is available on the SEC’s website at
www.adviserinfo.sec.gov.
1
Item 2: Educational Background and Business Experience
Michael L. Simon was born in 1967. Mike graduated from Northern Kentucky University in
1989 earning a B.S. in Accountancy. In 1992, he completed the requirements to receive the
Certified Public Accountant designation (inactive). In December of 1993, Mike graduated
from Xavier University with an MBA in Finance. Mike earned the Chartered Financial
Analyst (CFA) designation in 1996. The CFA designation is offered by the CFA Institute
(Formerly the Association for the Investment Management and Research - AIMR). To obtain
the CFA charter, candidates must 1) pass three sequential, six-hour examinations; 2) have at
least four years of qualified professional investment experience; 3) join the CFA institute as a
member: 4) commit to abide by, and annually reaffirm, adherence to the CFA Institute Code
of Ethics and Standards of Professional Conduct. In obtaining the CFA designation, the
candidate demonstrates their competence, integrity and extensive knowledge in accounting,
ethical and professional standards, economics, portfolio management and security analysis.
Mike founded AlphaMark Advisors, LLC in 1999 (formerly known as Wealth Advisors of
Cincinnati) which is a SEC Registered Investment Advisory firm. Mike is the President, CEO
and majority shareholder of AlphaMark Advisors, LLC. Mike Simon acts as the Portfolio
Manager, on behalf of AlphaMark Advisors.
Item 3: Disciplinary Information
There are no legal or disciplinary events for Michael L. Simon.
Item 4: Other Business Activities
Michael L. Simon does have outside business activities which are not in the financial industry
or related to AlphaMark Advisors, LLC in any way.
Mike has a 25% ownership in Combined Care Mgmt LLC DBA Figure Weight Loss (a weight
loss clinic), a 25% ownership of CCM Barnwood (a multi-floor office building) and 50%
ownership in SL Auto Group (a Limousine Service), and a 100% ownership of Dispenser Man
(beverage dispensing product).
2
Item 5: Additional Compensation
Michael L. Simon receives no economic benefit from anyone who is not a client for providing
advisory services.
Item 6: Supervision
AlphaMark reviews its clients’ accounts on an ongoing basis. All clients are encouraged to
discuss with their advisor his/her/their investment objectives, needs and goals and to keep
the advisor informed of any changes regarding same. All clients are encouraged to meet, at
least quarterly, with their advisor, to comprehensively review financial planning issues,
investment objectives and account performance. Periodically the Advisor and the Chief
Compliance Officer reviews assigned client accounts for the sector and individual holdings
weightings compared to the portfolio allocations listed in the Client Investment Policy
Statement. The weightings are to be within range or the advisor is to have the client approve
such discrepancies. Advisors are responsible for all levels of client service including but not
limited to; establishing accounts, discussing Investment Policy Statements with clients,
implementing those policies, investing and re-balancing accounts to client Policy and
AlphaMark's approved investments. Account reviews are done at a minimum on a quarterly
basis, or more frequently if market changes require re-balancing of individual or sector
weights. Clients receive monthly statements and confirmations of transactions from their
custodian and the client is provided access to an electronic portal to access our client
reporting.
3
Brochure Supplement
Part 2B of Form ADV
Item 1: Cover Page
Kelly E. Owens
(CRD# 5793107)
AlphaMark Advisors, LLC
810 Wright’s Summit Pkwy, Suite 100
Ft. Wright, KY 41011
Telephone: 859-957-1803
Date of Supplement:
03/05/2025
This brochure supplement provides information about Kelly E. Owens that supplements
the AlphaMark Advisors, LLC brochure. You should have received a copy of that
brochure. Please contact Anne Haggerty (CCO) at (859) 957-1803 if you did not receive
the AlphaMark Advisors, LLC brochure or if you have any questions about the contents
of this supplement.
Additional information about Kelly E. Owens is available on the SEC’s website at
www.adviserinfo.sec.gov.
1
Item 2: Educational Background and Business Experience
Kelly E. Owens was born in 1965. Kelly earned a Bachelor of Arts from the University of
Kentucky in 1988. She earned an additional Bachelor of Science from Thomas More College
in 1995 and a Master of Education degree from Northern Kentucky University in 2004. Kelly
passed the Series 7 which is a General Securities Representative exam (inactive) and Series 63
a Uniform Securities Agent State Law exam (inactive) in 2010 while employed with a national
level financial institution.
Kelly joined AlphaMark Advisors in 2014 as an investment advisor and is a partner of the
firm. She passed the series 65, Uniform Investment Advisor Law exam, and earned the
designation of Certified Divorce Financial Analyst (CDFA) in 2014. The CDFA program is
administered by the Institute for Divorce Financial Analysts and demonstrates competency in
areas of financial planning such as tax consequences, dividing assets and real estate, uniquely
related to divorce. Kelly earned the Certified Financial Planner (CFP) designation in 2016.
The CFP program is administered by the Certified Financial Planner Board of Standards Inc.
Those with the CFP designation have demonstrated competency in all areas of finance related
to financial planning. Candidates complete studies on over 100 topics, including stocks,
bonds, taxes, insurance, retirement planning and estate planning. In 2020, Kelly became
licensed by the department of insurance to conduct business in the Commonwealth of
Kentucky and has demonstrated knowledge of insurance products, insurance laws and ethics.
Kelly completed certification as a national Social Security Advisor in March 2022. This
advanced Social Security training qualifies her to guide retirees through the options available,
best time to access the benefits, and the best way to claim Social Security benefits in order to
optimize Social Security income.
Item 3: Disciplinary Information
There are no legal or disciplinary events for Kelly E. Owens.
Item 4: Other Business Activities
Kelly E. Owens does not have any current outside business activities.
Item 5: Additional Compensation
Kelly E. Owens receives residual compensation from insurance companies.
2
Item 6: Supervision
AlphaMark reviews its clients’ accounts on an ongoing basis. All clients are encouraged to
discuss with their advisor his/her/their investment objectives, needs and goals and to keep
the advisor informed of any changes regarding same. All clients are encouraged to meet, at
least quarterly, with their advisor, to comprehensively review financial planning issues,
investment objectives and account performance. Periodically the Advisor and the Chief
Compliance Officer reviews assigned client accounts for the sector and individual holdings
weightings compared to the portfolio allocations listed in the Client Investment Policy
Statement. The weightings are to be within range or the advisor is to have the client approve
such discrepancies. Advisors are responsible for all levels of client service including but not
limited to; establishing accounts, discussing Investment Policy Statements with clients,
implementing those policies, investing and re-balancing accounts to client Policy and
AlphaMark's approved investments. Account reviews are done at a minimum on a quarterly
basis, or more frequently if market changes require re-balancing of individual or sector
weights. Clients receive monthly statements and confirmations of transactions from their
custodian and the client is provided access to an electronic portal to access our client
reporting.
3
Brochure Supplement
Part 2B of Form ADV
Item 1: Cover Page
Andrew C. Becker
(CRD# 4959123)
AlphaMark Advisors, LLC
810 Wright’s Summit Pkwy, Suite 100
Ft. Wright, KY 41011
Telephone: 859-957-1803
Date of Supplement:
03/05/2025
This brochure supplement provides information about Andrew (Drew) C. Becker that
supplements the AlphaMark Advisors LLC brochure. You should have received a copy
of that brochure. Please contact Anne Haggerty (CCO) at (859) 957-1803 if you did not
receive the AlphaMark Advisors, LLC brochure or if you have any questions about the
contents of this supplement.
Additional information about Drew is available on the SEC’s website at
www.adviserinfo.sec.gov.
1
Item 2: Educational Background and Business Experience
Andrew (Drew) C. Becker was born in 1975. Drew earned a Bachelor of Science Degree from
the Ohio University in 1998 majoring in Mathematics. Drew has been in the financial
industry since 1999. He passed the Series 7, which is a General Securities Representative
exam, and Series 66, a Uniform Combined State Law Exam in 2005 while employed with a
national level financial institution.
In 2016, Drew joined AlphaMark Advisors, which is a SEC Registered Investment Advisory
firm, as a Vice President and is a partner of the firm. Drew is an Investment Advisor on
separately managed accounts, and is a co-Portfolio Manager.
Item 3: Disciplinary Information
There are no legal or disciplinary events for Andrew C. Becker.
Item 4: Other Business Activities
Andrew C. Becker does not have any outside business activities.
Item 5: Additional Compensation
Andrew C. Becker does not receive any compensation outside of AlphaMark Advisors LLC.
2
Item 6: Supervision
AlphaMark reviews its clients’ accounts on an ongoing basis. All clients are encouraged to
discuss with their advisor his/her/their investment objectives, needs and goals and to keep
the advisor informed of any changes regarding same. All clients are encouraged to meet, at
least quarterly, with their advisor, to comprehensively review financial planning issues,
investment objectives and account performance. Periodically the Advisor and Chief
Compliance Officer reviews assigned client accounts for the sector and individual holdings
weightings compared to the portfolio allocations listed in the Client Investment Policy
Statement. The weightings are to be within range or the advisor is to have the client approve
such discrepancies. Advisors are responsible for all levels of client service including but not
limited to; establishing accounts, discussing Investment Policy Statements with clients,
implementing those policies, investing and re-balancing accounts to client Policy and
AlphaMark's approved investments. Account reviews are done at a minimum on a quarterly
basis, or more frequently if market changes require re-balancing of individual or sector
weights. Clients receive monthly statements and confirmations of transactions from their
custodian and the client is provided access to an electronic portal to access our client
reporting.
3