Overview
Assets Under Management: $240 million
Headquarters: CHADDS FORD, PA
High-Net-Worth Clients: 1
Average Client Assets: $240 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (PF ADVISORS ADV 2A)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $2,500,000 | 1.00% |
$2,500,001 | $10,000,000 | 0.75% |
$10,000,001 | and above | Negotiable |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $10,000 | 1.00% |
$5 million | $43,750 | 0.88% |
$10 million | $81,250 | 0.81% |
$50 million | Negotiable | Negotiable |
$100 million | Negotiable | Negotiable |
Clients
Number of High-Net-Worth Clients: 1
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 100.00
Average High-Net-Worth Client Assets: $240 million
Total Client Accounts: 8
Discretionary Accounts: 8
Regulatory Filings
CRD Number: 277156
Last Filing Date: 2024-03-22 00:00:00
Form ADV Documents
Primary Brochure: PF ADVISORS ADV 2A (2025-03-12)
View Document Text
Item 1: Cover Page
PART 2A OF FORM ADV: FIRM BROCHURE
Investment Advisory Firm CRD #277156
March 2025
PF Advisors, LLC
225 Wilmington-West Chester Pike, Suite 200
Chadds Ford, PA 19317
Phone: (610) 470-4028
Email: PFraley@MyPFAdvisor.com
This brochure provides information about the business practices and qualifications of about PF Advisors, LLC. Any
inquiries regarding the contents of this brochure should contact Mr. Philip G. Fraley III, President & CCO of PF Advisors at
(610) 470-4028 or by email at: PFraley@MyPFAdvisor.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 PF Advisors, LLC and/or Phil Fraley is also available on the SEC’s website at
www.adviserinfo.sec.gov
Registration does not imply a certain level of skill or training.
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Item 2: Material Changes
This is PF Advisors FYE2024 annual filing and PF Advisors has no material changes to disclose at this
time.
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Item 3: Table of Contents
Table of Contents
Item 1: Cover Page .................................................................................................................................................................. 1
Item 2: Material Changes ........................................................................................................................................................ 2
Item 3: Table of Contents ....................................................................................................................................................... 3
Item 4: Advisory Business ....................................................................................................................................................... 4
Item 5: Fees and Compensation ............................................................................................................................................. 6
Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................................... 7
Item 7: Types of Clients ........................................................................................................................................................... 7
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss .................................................................................... 7
Item 9: Disciplinary Information ............................................................................................................................................. 8
Item 10: Other Financial Industry Activities and/or Affiliations ............................................................................................. 9
Item 11: Code of Ethics, Client Transactions and Personal Trading ....................................................................................... 9
Item 12: Brokerage Practices ................................................................................................................................................ 10
Item 13: Review of Accounts ................................................................................................................................................ 11
Item 14: Client Referrals and Other Compensation .............................................................................................................. 11
Item 15: Custody ................................................................................................................................................................... 11
Item 16: Investment Discretion ............................................................................................................................................ 12
Item 17: Voting Client Securities ........................................................................................................................................... 13
Item 18: Financial Information.............................................................................................................................................. 13
Item 19: Requirements for SEC-Registered Advisers ............................................................................................................ 13
Item 20: Additional Information ........................................................................................................................................... 14
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Item 4: Advisory Business
PF Advisors, LLC offers investment advisory services to individuals, high net worth individuals, families, trusts,
estates, businesses and charities. PF Advisors is a limited liability company registered in the state of Delaware
and headquartered in the State of Pennsylvania, and registered as an investment adviser with the SEC. Mr.
Philip G. Fraley III is the sole principle owner of PF Advisors, LLC, President, and Chief Compliance Officer. This
is PF Advisors annual filing for FYE2024 and as of 12/31/2024 PF Advisors had a total of $238,353,979.12 in
non-discretionary assets under management (“AUM”).
Investment Advisory Services
industry sectors on assets managed on a discretionary basis. Our
PF Advisors provides investment advisory services that relate to investment analysis, allocation of assets
among various asset classes, portfolio diversification, managing portfolio risk, and other general economic and
financial topics. PF Advisors offers financial advice and guidance to our clients and reviews existing and
potential investments from a strategic and tactical asset allocation approach. Investments are chosen and
structured based on the individual client needs. During our discovery process, we listen actively to the client's
known and unknown objectives, time horizons, risk tolerance, and liquidity needs. We also review and discuss
the client's prior investment history, as well as family composition and investing background. We then assist
clients with the management of their investments on a discretionary and/or non-discretionary basis. Account
supervision and structure is guided by a client’s needs and objectives, as well as their specific tax situations
and potential implications. Clients may impose reasonable restrictions on investing in certain securities, types
of securities, or
investment
recommendations and decisions are not limited to any specific security or industry and may include
investment advice regarding the following types on investment vehicles:
Mutual Funds
Exchange Traded Funds (ETFs)
Domestic Equities
Foreign Equities
Corporate Bonds
Commercial paper
Certificates of Deposit
Municipal bonds
U.S. Treasuries
Tax free fixed income
REITs
3rd Party Money Managers
Commodities
Alternative Investments
Hedge Funds
Because some types of investments involve certain additional degrees of risk, they will only be implemented
or recommended when consistent with a client's stated investment objectives, risk tolerance, liquidity needs,
and suitability.
Financial Reviews, Analysis & Planning:
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PF Advisors reviews and analyzes a client’s current financial situation and in most situations, focuses on areas
of concern and interest that may impact their short and long term goals. In some instances a conflict of
interest may exist and PF Advisors will make clients aware of these potential conflicts of interest.
A. a conflict exists between the interests of the investment adviser and the interests of the client,
B. the client is under no obligation to act upon the investment adviser's recommendation, and
C. if the client elects to act on any of the recommendations, the client is under no obligation to effect the
transaction through the investment adviser.
PF Advisors will, in most situations, focus on areas of immediate concern and interest that may impact clients
short and long term goals. These areas may include:
Estate Planning:
PF Advisors will review a client’s current exposure to estate taxes and clients current estate plan, which may
include whether clients have a will, powers of attorney, trusts and other related documents. PF Advisors will
discuss ways for clients to minimize and/or avoid potential estate taxes by implementing appropriate estate
planning strategies. We are available to work with a clients’ current attorney and/or may assist clients in
finding a qualified estate planning attorney.
Financial Goals:
PF Advisors helps clients identify personal financial goals and assists them in developing a plan to reach these
goals and dreams. PF Advisors will assist in determining what resources a client needs and what investments
are appropriate to reach these financial goals.
Investment Planning:
PF Advisors reviews client current investment asset allocation strategy and target asset allocation along with a
clients’ risk tolerance and time horizon in an effort to evaluate the appropriateness of each and every
investment. We also assist clients in reviewing employee stock options and purchase plans as well as other
areas of investment related concern.
Retirement Planning:
PF Advisors believes that it is always a good time to invest for/in the future and PF Advisors assists clients with
their retirement planning journey by guiding them to and through their retirement. PF Advisors helps clients
understand this process, where they are currently positioned, provide ideas to make the most of their savings
and investments, and shows them what they can do to stay on track for the retirement they envision.
Risk Management:
PF Advisors uses risk management to identify, analyze and accept or mitigate uncertainty within investments.
Essentially, risk management occurs any time an investor analyzes and/or attempts to quantify the potential
for losses of an investment and then takes the appropriate action (or inaction) given his investment
objectives and risk tolerance.
Tax Planning:
PF Advisors conducts an analysis of a client’s financial situation or plan from a tax perspective. The purpose
of tax planning is to ensure tax efficiency, with the elements of the financial plan working together in the most
tax-efficient way possible.
Investment Advisor to Private funds:
PF Advisors may act as an investment manager to private funds / pooled investment vehicles. These services
are negotiated and agreed upon prior to PF Advisors acting as an investment manager to the fund(s).
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Item 5: Fees and Compensation
PF Advisors is a “Fee-Only” investment advisory firm and receives compensation based on the type of advisory
services performed. PF Advisors reserves the right to negotiate fees and compensation with its clients.
Negotiated fees between PF Advisors and the client will supersede PF Advisors’ existing fee structure. The PF
Advisors investment advisory contract can be terminated by the client within five (5) business days of the
signing of the investment advisory contract and the client will not be responsible for advisory fees incurred
during that time. Please review the fee and compensation information below.
Lower fees for comparable services may be available from other sources.
Investment Management Fee Structure
Unless negotiated otherwise, PF Advisors advisory fees are charged in arrears and are based on the market
value of the assets under management and calculated as follows:
Account Value
Annual Advisory Fee
First $2,500,000.00
1.00%
Next $7,500,000.00
0.75%
Over $10,000,000.00
Negotiated
Negotiated Fees
PF Advisors may negotiate advisory fees with clients that have in excess of $10,000,000.00 in assets under
management with PF Advisors. These fees are negotiated between PF Advisors and the client and agreed upon
in writing by both parties. Negotiated fees may involve the client paying advisory fees to PF Advisors in
advance and/or in arrears.
Fee Billing
PF Advisors’ investment advisory fees are billed quarterly, in arrears based on the average daily balance of the
accounts managed by PF Advisors. PF Advisors will send an invoice to clients based on the aggregated amount
of all accounts managed by PF Advisors. Clients have the option of paying the fee directly to PF Advisors. If
payment is not received by the end of the month in which the invoice is sent, PF Advisors has the consent and
authority to deduct the fee due directly from the client’s account.
Other Fees and Expenses
PF Advisors does not charge additional fees other than the Investment Advisory Fees charged.
PF Advisors does not receive or share any additional fees or expenses incurred by advisory clients.
PF Advisors may charge negotiated fees that may differ from the above fee structure.
PF Advisors clients will incur brokerage and other transaction costs by the custodian. PF Advisors does not
receive or share in these fees; see Item 12 for additional information.
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Item 6: Performance-Based Fees and Side-By-Side Management
PF Advisors does not charge performance-based fees or participate in side-by-side management. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees while at
the same time managing accounts that are not charged performance-based fees. Performance-based fees are
fees that are based on a share of capital gains or capital appreciation of a client's account. Our fees are
calculated as described above, and are not charged on the basis of a share of capital gains upon, or capital
appreciation of, the funds in client advisory accounts.
PF Advisors receives no additional compensation other than the agreed upon management fees negotiated
and PF Advisors does not share in any performance based fees.
Item 7: Types of Clients
PF Advisors clients can include: individuals, high net worth individuals, business entities, trusts, estates,
charitable organizations, and qualified plans. PF Advisors does not require an annual minimum fee or asset
level for investment advisory or investment planning services.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
When appropriate, PF Advisors will use the following methods of analysis when providing investment advice
to clients:
Technical Analysis -Technical Analysis involves studying past price patterns and trends in the financial markets
to predict the direction of both the overall market and specific stocks. The risk of market timing based on
technical analysis is that charts will not accurately predict future price movements. Current prices of securities
often reflect all information known about the security and day to day changes in market prices of securities
will follow random patterns and in these cases, not be predictable with any reliable degree of accuracy.
Fundamental Analysis - 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 is incorrect and the analysis will not
provide an accurate estimate of earnings, which in turn, will 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.
Cyclical Analysis - Cyclical analysis is a type of technical analysis that involves evaluating recurring price
patterns and trends based upon business cycles. The lengths of economic cycles are 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.
Quantitative Analysis - Quantitative analysis deals with measurable factors as distinguished from qualitative
considerations such as the character of management or the state of employee morale, such as the value of
assets, the cost of capital, historical projections of sales, and so on.
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Qualitative Analysis - Qualitative analysis is a securities analysis that uses subjective judgment based on
unquantifiable information, such as management expertise, industry cycles, strength of research and
development, and labor relations. Qualitative analysis contrasts with quantitative analysis, which focuses on
numbers that can be found on reports such as balance sheets. The two techniques, however, will often be
used together in order to examine a company's operations and evaluate its potential as an investment
opportunity.
Investment Strategies
PF Advisors believes that asset allocation across diverse investment is the key to long term success in reaching
client objectives. Our discretionary portfolio management strategies are customized to the client’s specific
wants, needs, investment objectives and risk tolerance. Each discretionary portfolio is constructed using a
strategic asset allocation methodology, with prevailing long-term trends in mind. Short-term trends and
strategies will not be employed unless necessary in accordance with Client mandates. PF Advisors structures
portfolios using a proprietary methodology. PF Advisors believes that Clients will benefit from having a
portfolio of holdings invested in a variety of assets classes. To the extent that these asset classes are non-
correlated, the portfolio will experience investment returns with mitigated risk. PF Advisors will not pursue
strategies that are highly speculative and risky in nature.
Risk of Loss
Investing in securities involves risks, including the loss of principal. Securities will and do fluctuate in value.
Clients should understand and be prepared for these fluctuations in value as well as for the potential of loss.
PF Advisors assists clients in determining an appropriate asset allocation strategy based primarily on their risk
tolerance and time horizon. Even with these methods in place, there is no guarantee that a client will meet or
exceed their investment goals. PF Advisors will continually review a client's investment goals, financial
situation, time horizon, tolerance for risk and other factors at least annually to determine if the current asset
allocation is still an appropriate asset allocation for the client. A client’s participation and understanding of the
process, including full and accurate disclosure of any and all requested information, is an essential piece to the
client understanding the risks involved. PF Advisors relies heavily on the information provided by the client in
determining the appropriate investments for said client. Therefore, the responsibility lies on the client to relay
accurate and up to date information to the PF Advisors Advisor. This information should include any changes
in the client’s financial condition, goals or other factors that may affect this analysis. The risks associated with
a particular strategy are provided to each client in advance of investing the client’s assets.
With the clients approval PF Advisors will use margin as a tool in managing the allocation during the
rebalancing of client accounts if needed. PF Advisors, with a client’s approval and the appropriate options
agreement on file will employ options strategies to hedge or gain additional exposure to a particular asset
class or sector. Following are some of the risks associated with these transactions
Market Risks
All securities, particularly individual equity and debt securities are subject to market volatility, economic
factors and certain other market risks. The success of a particular investment depends to a great extent upon
correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that
PF Advisors will be able to predict those price movements accurately.
Item 9: Disciplinary Information
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PF Advisors has not been the subject of any disciplinary action(s) and does not have any legal of disciplinary
information to disclose. This includes any criminal actions, civil actions, administrative proceedings,
and/orself-regulatory Organization (SRO) Proceedings. Any disciplinary information regarding PF Advisors
Investment Advisor Representatives would be disclosed here as well as additional information being disclosed
on the PF Advisors IAR’s ADV Part 2B.
Item 10: Other Financial Industry Activities and/or Affiliations
Neither PF Advisors, nor its representatives, are registered or have an application pending to register, as a
broker-dealer or a registered representative of a broker-dealer.
Neither PF Advisors, nor its representatives, are registered or have an application pending to register, as a
futures commission merchant, commodity pool operator, a commodity trading advisor, or a representative of
the foregoing.
PF Advisors has no other relationship or arrangement with a related person that is material to its advisory
business.
Item 11: Code of Ethics, Client Transactions and Personal Trading
Code of Ethics
PF Advisors and its employees are committed to a Code of Ethics that is available for review and will be
provided to clients and prospective clients upon request. PF Advisors Financial Planning & Investment
Management strives to comply with all applicable laws and regulations governing its practices. Therefore, PF
Advisors has set forth guidelines for professional standards of conduct for its associated persons, the goal of
which is to protect our 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. Associated persons are also required to report any violations of the Firm's Code of Ethics.
Additionally, PF Advisors maintains and enforces written policies reasonably designed to prevent the misuse
or dissemination of material, non-public information about clients or their account holdings by PF Advisors or
any associated person.
Participation or Interest in Client Transactions
Neither PF Advisors nor any of our associated persons has any material financial interest in client transactions
beyond the provision of investment advisory services as disclosed in this Brochure.
Personal Trading
PF Advisors recognizes and believes that (i) high ethical standards are essential for its success and to maintain
the confidence of its clients; (ii) its long-term business interests are best served by adherence to the principle
that the interests of clients come first; and (iii) it has a fiduciary duty to its clients to act in their best interests.
All PF Advisors personnel must put the interests of PF Advisors' clients before their own personal interests and
must act honestly and fairly in all respects in dealings with clients. All PF Advisors' personnel must also comply
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with all federal securities laws. PF Advisors has adopted a Code of Ethics governing personal trading by its
personnel. Among other requirements, the Code of Ethics requires personnel who have access to client
portfolio information or securities recommendations to pre-clear their personal securities transactions with PF
Advisors' Chief Compliance Officer. Certain classes of securities (e.g., mutual funds and ETFs) are exempt from
the pre-clearance requirements of the Code based on PF Solution's determination that these types of
transactions have no practical effect its clients. If you are a current client or perspective client, a copy of the
Code of Ethics will be provided upon request.
PF Advisors or affiliated/related persons shall refrain from recommending that clients buy or sell securities in
which PF Advisors or a related person has a material financial interest.
PF Advisors or affiliated/related persons shall not invest in the same securities (or related securities, e.g.,
warrants, options or futures) that are currently being recommended to clients.
PF Advisors or
affiliated/related persons may invest in said securities after all existing clients have been informed of the
investment opportunity.
PF Advisors or affiliated/related persons may not recommend securities to clients, buy or sell securities for
client accounts, at or about the same time that PF Advisors or a related person buys or sells the same
securities.
Item 12: Brokerage Practices
Selecting Brokerage Firms
PF Advisors maintains the ability to work with multiple custodians and also maintains the right to recommend
clients work with the a qualified custodian that they feel most comfortable with based on the specific clients
needs. PF Advisors does not receive fees or commissions from these arrangements. PF Advisors will
recommend a custodian based on historically proven integrity and financial responsibility of said custodian.
Best Execution
We believe in using custodians that provide the best services at competitive rates. The reasonableness of
commission rates is based on several factors, including the broker's ability to provide professional services,
execution, the broker's reputation, experience and financial stability of the broker or dealer, and the quality of
service rendered by the broker or dealer in transactions. 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. Each of the above
mentioned custodians has a history of best execution performance that is well documented in various
publications and testing results.
Order Aggregation
It is PF Advisors’ practice to aggregate transactions across multiple client accounts if and whenever possible, in
an effort to obtain the best execution for our clients.
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Directed Brokerage
In limited circumstances, and at our discretion, some clients may instruct PF Advisors to use one or more
particular brokers for the transactions in their accounts. If clients choose to direct our firm to use a particular
broker, clients should understand that this might prevent from effectively negotiating brokerage commissions
on clients behalf. This practice may also prevent PF Advisors from obtaining a favorable price and execution.
Thus, when directing brokerage business, clients should consider whether the commission expenses,
execution, clearance, and settlement capabilities that clients will obtain through a particular broker are
adequately favorable in comparison to those that we would otherwise obtain for clients.
Trade Errors
Trading errors can and do happen. If a trade error occurs when entering a trade on behalf of a client, PF
Advisors’ policy is to restore a client’s account to the position it should have been in had the trade error had
not occurred. Depending on the circumstances, corrective actions may include canceling/busting said trade,
adjusting the client account to reflect the appropriate asset allocation and/or the reimbursing of any fees to
the client account.
Item 13: Review of Accounts
Periodic Reviews
Financial Plans are reviewed at least annually and updated by PF Advisors on a periodical basis as deemed
necessary by PF Advisors and said client. Reviews are ongoing and are done quarterly, semiannually and/or
annually as predetermined by PF Advisors and the client. Portfolio and financial plan reviews are and in most
cases predetermined in advance with PF Advisors clients. Reviews can also be prompted by the client and/or
PF Advisors at any given time.
Review Triggers
Other conditions triggering a review are changes in the portfolio allocation, new information affecting the
specific client’s situation, and changes in a client's own situation.
Regular Reports
PF Advisors clients receive monthly and/or semi-annual portfolio performance statements from the custodian
holding client assets. In addition, clients also receive transaction confirmations from the account custodian
being used.
Item 14: Client Referrals and Other Compensation
As of this filing, PF Advisors does not directly or indirectly compensate any persons for client referrals or
performance based compensation.
Item 15: Custody
PF Advisors does not accept or maintain custody of any Client accounts. All Clients must place their assets with
a qualified custodian. Clients may choose a qualified custodian of their own preference. If a client has no
preference of a qualified custodian, PF Advisors may assist the client(s) in identifying a qualified custodian
based on the clients immediate and possible future needs. Qualified custodians may allow for direct debit of
advisory fees. Therefore, if a custodian allows for direct debiting and the client chooses to have advisory fees
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direct debited from their accounts, PF Advisors may directly debit clients account(s) for the payment of our
advisory fees. This ability to deduct advisory fees from clients account(s) falls under the category of trade
authorization over client funds or securities. PF Advisors does not have physical custody of any client funds
and/or securities. Client funds and securities will be held with a bank, broker-dealer, or other independent,
qualified custodian. Clients will receive account statements from the independent, qualified custodian(s)
holding client’s funds and securities at least quarterly. The account statements from client’s custodian(s) will
indicate the amount of our advisory fees deducted from clients account(s) each billing period. Clients should
carefully review account statements for accuracy. If clients have a question regarding account statements or if
clients did not receive a statement from the custodian, please contact PF Advisors at the contact information
provided on the front page of this brochure.
Safe Keeping and Safeguards in Custody
A. If PF Advisors has custody of client funds it is solely a consequence of assisting clients in making deposits
and/or withdrawals from client accounts as well as in assisting clients with the payment of advisory fees.
B. The investment adviser has written authorization from the client to deduct advisory fees from the account
held with the qualified custodian.
C. Each time a fee is directly deducted from a client account, PF Advisors concurrently:
i. Sends the qualified custodian an invoice or statement of the amount of the fee to be deducted from the
client’s account; and
ii. Sends the client an invoice or statement itemizing the fee. Itemization includes the formula used to
calculate the fee, the value of the assets under management on which the fee is based, and the time
period covered by the fee.
D. PF Advisors has implemented these transparent safeguards to help protect clients and client assets
Item 16: Investment Discretion
PF Advisors can provide both discretionary and non-discretionary investment management services to its
clients. Custody options will be discussed and approved by both parties prior to the opening of the initial
account. The client must approve of the custodian that will be used and the commission rates paid to the
custodian by the client. PF Advisors does not receive any portion of the transaction fees and/or commissions
paid by the client to the custodian on any given trade and/or transaction.
Discretionary Authority
PF Advisors manages certain client’s investments in a discretionary fashion. A signed investment management
agreement/contract between the client and PF Advisors establishes the discretionary authority for trading in a
client’s account. Where investment discretion has been granted by the client, PF Advisors will manage the client’s
account and has the ability to make investment decisions without consulting with the client as to what securities
are to be bought and/or sold, when the securities are to be bought and/or sold, the amount of securities to be
bought and/or sold, and/or the price per share of said security. In some instances, PF Advisors discretionary
authority will be limited; as a client can impose certain conditions and/or instructions that PF Advisors must
adhere to.
Non-Discretionary Authority
PF Advisors manages certain client’s investments in a non-discretionary fashion. PF Advisors and its client
must both agree to an investment decision prior to taking action in said investment. Because of this, all new
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investments must be agreed upon prior to taking an initial position in a client’s account or portfolio. A client
always has a right to decline to implement any new investment advice provided by PF Advisors.
Discretionary Authority for Sub-Manager(s)
PF Advisors may use other money managers within a client’s portfolio. Internally these investments have
discretionary authority within the investment vehicle being used. PF Advisors will only use sub-managers that
have made a valid and up to date prospectus available to the public in which it describes the fund’s
investment objective, internal structure and investment guidelines. Sub-Manager(s) have the authority to buy,
hold, and/or sell securities for a client’s assets delegated to the Sub- Manager(s).
Item 17: Voting Client Securities
Proxy Votes
PF Advisors can and will assist clients with voting proxies if the client chooses. If a client owns an investment
that client is a shareholder and can exercise their right to vote proxies as a shareholder. In most cases, clients
will receive proxy materials directly from the account custodian. However, in the event we were to receive any
written or electronic proxy materials, the materials would be forwarded directly to clients by mail, unless
clients have authorized the firm to contact clients by electronic mail, in which case, we would forward any
electronic solicitation to vote proxies. Clients that would like assistance from PF Advisors in understanding the
material within the proxy and/or would like assistance with the voting process can contact PF Advisors by
phone or by email using the contact information on the front of this brochure.
Class Action Lawsuits
PF Advisors is not responsible for determining if securities held by clients are the subject of a class action
lawsuit or whether clients are eligible to participate in said class action settlement or litigation nor does PF
Advisors initiate or participate in litigation to recover damages on a client’s behalf for damages as a result of
said actions, misconduct, or negligence of said party. Any and all inquiries regarding this should be initially
directed to the custodian in which the assets are/were held.
Item 18: Financial Information
Financial Condition
PF Advisors does not have any financial situations that will result in PF Advisors from meeting contractual
commitments to clients.
Item 19: Requirements for SEC-Registered Advisers
A. PF Advisors currently has only one management person and/or executive officer; Mr. Phil Fraley. Mr.
Phil Fraley’s education and business background can be found on the Supplemental ADV Part 2B form.
B. Mr. Phil Fraley’s other business activities can be found on ADV Part 2B.
C. PF Advisors does not accept performance-based fees or other fees based on a share of capital gains on
and/or capital appreciation of the assets of its clients.
D. PF Advisors and/or affiliated/related persons have not been involved in any arbitration claim or been
found liable in a civil or criminal court, self-regulatory organization, or administrative proceeding.
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E. PF Advisors and its management persons do not have a relationship and/or arrangement of any kind
with any issuers of securities.
Item 20: Additional Information
Privacy
PF Advisors is committed to maintaining the confidentiality, integrity and security of the personal information
that is entrusted to us by both prospects and clients. The categories of nonpublic information that we collect
from clients may include information about a client’s personal situation to the extent that it is needed for the
money coaching and financial planning process, information about transactions between clients and third
parties, and information from consumer reporting agencies, e.g., credit reports. PF Advisors uses this
information to assist clients with developing and the implementation of a client’s financial plan. With a client’s
permission, PF Advisors will disclose limited information to attorneys, accountants, and mortgage lenders and
to whom ever a client has an established relationship. PF Advisors shares limited amounts of information
about clients with service providers, such as the custodian of clients account, so that we may enhance the
service level provided to clients. PF Advisors maintains a secure location for the storage of client information.
PF Advisors employs a firewall, secure data encryption techniques and authentication procedures on our
computer network and cloud providers. We will never provide a client’s personal information to mailing list
vendors, solicitors and/or third parties of any kind. We require strict confidentiality in our agreements with
unaffiliated third parties that require access to a client’s personal information, including financial service firms,
consultants and auditors. Federal and state securities regulators may review our company records and client’s
personal records as permitted by law. Personal information about clients will be maintained for the required
period. Thereafter, records are required to be maintained by federal and state securities laws. After that time,
information will be either destroyed or returned to the client. PF Advisors will notify clients in advance if the
PF Advisors privacy policy were to change. We are required by law to deliver this Privacy Notice to clients
annually, in writing.
Business Continuity Plan (BCP)
PF Advisors has created a written BCP that is available to clients and prospects upon request. A written BCP
helps in identifying procedures relating to an emergency or significant business disruption, including death or
incapacitation of the investment adviser or any of its representatives. Such procedures are in place to help PF
Advisors’ IARs meet their existing fiduciary obligations to their clients.
Conflicts of Interest Disclosure
PF Advisors discloses all material conflicts of interest prior to a client signing the PF Advisors Investment
Advisory Agreement. This is done verbally and through PF Advisors’ ADV Brochures Part 2A & 2B, PF Advisors’
Conflict of Interest Disclosure document and the PF Advisors Advisory Agreement/Contract.
Chief Compliance Officer (CCO)
The Securities and Exchange Commission requires investment advisors designate a chief compliance officer
(CCO) to administer its compliance policies and procedures. Mr. Phil Fraley is the President & CCO of PF
Advisors and as the CCO he, has chosen to outsource PF Advisors regulatory filing responsibilities to Aurora
Compliance Solutions (ACS). ACS is a CT based firm that specializes in assisting investment advisory firms with
registrations, notice filings, compliance, and regulatory responsibilities. Please contact Mr. Edward
Romanowsky of ACS directly at (860) 856-8862 with any questions related to this ADV or any regulatory filing
submitted on behalf of PF Advisors.
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Additional Brochure: PF ADVISORS ADV 2B (2025-03-12)
View Document Text
Mr. Philip G. Fraley III
Brochure – ADV Part 2B
Investment Adviser Representative CRD # 5414013
March 2025
PF Advisors, LLC
225 Wilmington-West Chester Pike, Suite 200
Chadds Ford, PA 19317
Phone: (610) 470-4028
Email: PFraley@MyPFAdvisor.com
This brochure supplement provides information about Mr. Philip G. Fraley III that supplements the PF
Advisors, LLC brochure ADV Part 2A for CRD # 277156. If you did not receive the PF Advisors, LLC
brochure or if you have any questions about its contents and/or this supplement contents contact Mr.
Philip G. Fraley III at (610) 470-4028 or by email at: PFraley@MyPFAdvisor.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 PF Advisors, LLC and/or Mr. Philip G. Fraley III is also available on the
SEC’s website at www.adviserinfo.sec.gov
Registration does not imply a certain level of skill or training.
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Item 2: Educational and Business Experience
Name:
Philip G. Fraley III
Born: 1982
Education & Industry Exams Passed:
University of Pennsylvania - Wharton School of Business, Executive Education, Private Wealth
Management, 2013
Villanova University - School of Business, Graduate Coursework, 2011
University of Pittsburgh - Bachelor of Science in Accounting, 2004
Uniform Investment Adviser Law License – Series 65
Insurance Licensed: Life and Fixed Annuities, Accident and Health, Property and Casualty
Financial Services Experience & Work History:
08/2015 – Present, PF Advisors, LLC (CRD: 277156), Chads Ford, PA
08/2013 – 07/2015, Real Partners, President, Los Angeles, CA / King of Prussia, PA
11/2010 – 07/2013, Guggenheim Partners, Director/Family Advisor, King of Prussia, PA
04/2010 – 11/2010, Pershing LLC, King of Prussia, PA
08/2007 – 04/2010, Lockwood Advisors, Research Analyst, Malvern, PA
07/2004 – 08/2007, PJM Interconnection, Financial Analyst, Valley Forge, PA
Item 3: Disciplinary Information
As an Investment Advisor Representative you are required to disclose all material fact regarding any
legal or disciplinary events that would be material in your evaluation. Currently, Mr. Philip G. Fraley III
has no information applicable to this requirement. For more information about Mr. Philip G. Fraley III,
please visit FINRA’s Broker Check at www.finra.org/brokercheckand/or the SEC’s Investment Advisor
Search at www.adviserinfo.sec.gov.
Item 4: Other Business Activities
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Mr. Philip G. Fraley III does not act in an investment advisory representative (IAR) capacity for any
other firm other than PF Advisors and is therefore not registered as an IAR with any other firm other
than PF Advisors.
Mr. Philip G. Fraley III holds himself out as a business consultant and these services may be obtained
by others to include registered investment advisory firms and financial services related businesses.
While acting in the capacity of a business consultant, Mr. Fraley may receive compensation in various
forms (i.e. 1099, W2, etc…) that are determined by Mr. Fraley and the hiring party based on the job
and the work to be completed.
Item 5: Additional Compensation
At this time, Mr. Philip G. Fraley III does not receive any economic benefit from any person, company,
or organization, other than his work as an investment advisor representative of PF Advisors and his
work as a business consultant.
Item 6: Supervision
As the President of PF Advisors, LLC, Mr. Philip G. Fraley III supervises all activities of the firm. Mr.
Philip G. Fraley III's contact information is on the cover page of this disclosure document. Philip G.
Fraley III adheres to all required regulations regarding the activities of an Investment Adviser
Representative and follows all policies and procedures outlined in the firm’s policies and procedures
manual, the firms compliance manual including the code of ethics, and appropriate securities
regulatory requirements.
Item 7: Requirements for SEC‐Registered Advisers
Philip G. Fraley III has never been involved in a bankruptcy petition nor has he ever been involved in
any disciplinary events reportable under this item.
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