Overview
Assets Under Management: $123 million
High-Net-Worth Clients: 9
Average Client Assets: $13 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (DISCLOSURE BROCHURE 2A + 2B)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $5,000,000 | 0.75% |
$5,000,001 | $7,500,000 | 0.50% |
$7,500,001 | $10,000,000 | 0.00% |
$10,000,001 | $20,000,000 | 0.40% |
$20,000,001 | $50,000,000 | 0.25% |
$50,000,001 | and above | 0.20% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $7,500 | 0.75% |
$5 million | $37,500 | 0.75% |
$10 million | $50,000 | 0.50% |
$50 million | $165,000 | 0.33% |
$100 million | $265,000 | 0.26% |
Clients
Number of High-Net-Worth Clients: 9
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 98.49
Average High-Net-Worth Client Assets: $13 million
Total Client Accounts: 37
Discretionary Accounts: 32
Non-Discretionary Accounts: 5
Regulatory Filings
CRD Number: 174441
Last Filing Date: 2024-03-22 00:00:00
Website: https://www.linkedin.com/company/strategic-probability-partners-llc
Form ADV Documents
Primary Brochure: DISCLOSURE BROCHURE 2A + 2B (2025-03-27)
View Document Text
Disclosure Brochure
March 31, 2025
STRATEGIC PROBABILITY PARTNERS, LLC
a Registered Investment Adviser
292 14th Avenue South, Unit A
Naples, Florida 34102
http://www.strategicprobabilitypartners.com
(305) 619-3566
This brochure provides information about the qualifications and business practices of Strategic Probability
Partners, LLC (hereinafter, “SPP” or the “Firm”). If you have any questions about the contents of this brochure,
please contact the Firm at this telephone number listed above. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission (SEC) or by any state
securities authority. Additional information about the Firm is available on the SEC’s website at
www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of
skill or training.
Disclosure Brochure
Strategic Probability Partners, LLC
Item 2. Material Changes
There have been no material changes in this brochure from the last annual updating amendment of Strategic
Probability Partners, LLC on March 31, 2024.
Page | 2
Disclosure Brochure
Strategic Probability Partners, LLC
Item 3. Table of Contents
Item 2. Material Changes ........................................................................................................................................................ 2
Item 3. Table of Contents........................................................................................................................................................ 3
Item 4. Advisory Business ...................................................................................................................................................... 4
Item 5. Fees and Compensation............................................................................................................................................... 5
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 ............................................................................................................................................. 9
Item 10. Other Financial Industry Activities and Affiliations ................................................................................................... 9
Item 11. Code of Ethics .......................................................................................................................................................... 9
Item 12. Brokerage Practices ................................................................................................................................................ 10
Item 13. Review of Accounts ................................................................................................................................................ 12
Item 14. Client Referrals and Other Compensation ................................................................................................................ 12
Item 15. Custody ................................................................................................................................................................. 12
Item 16. Investment Discretion ............................................................................................................................................. 13
Item 17. Voting Client Securities .......................................................................................................................................... 13
Item 18. Financial Information .............................................................................................................................................. 13
ADV Part 2B Brochure Supplement………………………………………………………………………………………..……15
Page | 3
Disclosure Brochure
Strategic Probability Partners, LLC
Item 4. Advisory Business
SPP was formed in November 2014 by its principal Craig R. Sutherland, to offer investment management
and planning services to its clients. Prior to SPP rendering any of the foregoing advisory services, clients
are required to enter into one or more written agreements with SPP setting forth the relevant terms and
conditions of the advisory relationship (the “Advisory Agreement”).
While this brochure generally describes the business of SPP, certain sections also discuss the activities of
its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or any other person who provides investment
advice on SPP’s behalf and is subject to the Firm’s supervision or control.
As of December 31, 2024, SPP’s assets under management were $125,839,054, of which $91,413,633
were on a discretionary basis, and $34,423,421 were on a non-discretionary basis. Additionally, SPP had
$131,600,888 in assets under advisement through two sub-advisory relationships as of December 31,
2024, for an AUM and AUA combined total of $257,439,942.
Investment Management Services
SPP g e n e r a l l y manages client investment portfolios on a discretionary basis within a pre-established
and agreed upon investment policy statement for each client relationship. SPP only handles non-
discretionary accounts on a limited, exception basis. As part of an investment management
offering, SPP may provide clients with certain investment planning advice and guidance.
SPP will also offer sub-advisory services to other investment management firms in certain circumstances,
providing timely information regarding the portfolio construction for investment strategies. All trading
instructions to the custodian for sub-advised accounts will be the sole responsibility of the investment
advisory firm retaining SPP as subadviser.
In providing its advisory services, SPP is not required to verify any information received from the client or
from the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely
on such information. SPP always recommends that clients engage other legal and tax professionals to
review, coordinate, and implement all changes to their financial plans ancillary to their investment planning
process. Clients retain absolute control over all planning decisions and are under no obligation to act upon
any of the planning suggestions and recommendations made by SPP.
SPP primarily allocates clients’ assets among various exchange-traded funds (“ETFs”), index funds, mutual
funds, and individual debt securities in accordance with their stated investment objectives.
SPP generally limits its investment advice to mutual funds, fixed income securities, real estate funds,
equities, ETFs, treasury inflation protected/inflation linked bonds and non-U.S. securities. SPP may use
Page | 4
Disclosure Brochure
Strategic Probability Partners, LLC
other securities as well to help diversify a portfolio when applicable.
SPP tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a
continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives.
SPP consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon,
liquidity constraints and other related factors relevant to the management of their portfolios. Clients are
advised to promptly notify SPP if there are changes in their financial situation or if they wish to place any
limitations on the management of their portfolios.
Written Acknowledgement of Fiduciary Status
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. The way we make money creates some conflicts with your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this
special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.
Item 5. Fees and Compensation
Investment Management Fees
SPP offers investment management services for an annual fee based on the market value of assets under
the Firm’s management. Any planning advice and guidance provided by the Firm are included in the
investment management fee. This management fee generally varies in accordance with the following fee
schedule:
Direct Investment Management
PORTFOLIO VALUE
BASE FEE
First $5,000,000
Next $2,500,000
Next $2,500,000
Next $10,000,000
Next $30,000,000
Above $50,000,000
0.75%
0.50%
0.00%
0.40%
0.25%
0.20%
Page | 5
Disclosure Brochure
Strategic Probability Partners, LLC
Sub-Advisory Fees
SPP may also act as a sub-advisor to other unaffiliated advisers. SPP charges a negotiated sub-advisory fee
for providing such services to such sub-advisory client firms and their clients, and do not exceed any limit
imposed by any regulatory agency. Currently our sub-advisory fees average 0.25% (25 basis points).
Sub-advisory client firms charge and collect our SPP sub-advisory fee directly from their client accounts,
based on the value of assets placed in SPP strategies. SPP does not share such sub-advisory fees with sub-
advisory client firms, nor does SPP share in any of the advisory fees charged by sub-advisory client firms
for their own services to their own clients. This relationship is memorialized in each contract between SPP
and sub-advisory client firms.
The annual fee is prorated and charged monthly, in arrears, based on the average business day billable
market value at the end of each month. For the initial period of an engagement, the fee is calculated
on a pro rata basis. In the event the Advisory Agreement is terminated, the fee for the final billing
period is prorated through the effective date of the termination and the outstanding portion of the fee is
charged to the client, as appropriate.
Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g.,
held-away assets, accommodation accounts, alternative investments, etc.), SPP may negotiate a fee rate that
differs from the range set forth above.
Fee Discretion
In very limited circumstances, SPP may, in its sole discretion, negotiate to charge a lesser fee based upon
certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar
amount of assets to be managed, related accounts, account composition, pre-existing/legacy client
relationship, account retention and pro bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to SPP, clients may also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges may include securities brokerage
commissions, transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a
client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund
expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund
fees, and other fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage
practices are described at length in Item 12, below.
Direct Fee Debit
Clients generally provide SPP with the authority to directly debit their accounts for payment of the
investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts,
Page | 6
Disclosure Brochure
Strategic Probability Partners, LLC
from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients
not less than quarterly detailing all account transactions, including any amounts paid to SPP. Where
required, SPP also sends to clients a written invoice itemizing the fee, including the formula used to
calculate the fee, the time period covered by the fee and the amount of assets under management on
which the fee was based.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to SPP’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients
may withdraw account assets on notice to SPP, subject to the usual and customary securities settlement
procedures. However, the Firm generally designs its portfolios as long-term investments and the
withdrawal of assets may impair the achievement of a client’s investment objectives. SPP may consult
with its clients about the options and implications of transferring securities. Clients are advised that when
transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees,
fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications.
Item 6. Performance-Based Fees and Side-by-Side Management
SPP does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
Item 7. Types of Clients
SPP offers services to individuals, high net worth individuals, endowments and foundations.
Minimum Account Fee
As a condition for starting and maintaining an investment management relationship, SPP generally imposes
a minimum annual fee of $37,500. This minimum fee may cause clients with smaller portfolios to incur an
effective fee rate that is higher than the Firm’s stated fee schedule. SPP may, in very limited circumstances,
in its sole discretion, elect to waive its minimum fee based upon certain criteria, including anticipated
future earning capacity, anticipated future additional assets, dollar amount of assets to be managed,
related accounts, account composition, pre-existing client, account retention, and pro bono activities.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
SPP at various times utilizes a combination of fundamental, technical, valuation and business cycle methods
of analysis.
Fundamental analysis includes an evaluation of the fundamental financial condition of a particular fund,
Page | 7
Disclosure Brochure
Strategic Probability Partners, LLC
as well as the overall valuation levels of asset classes held by such funds. A substantial risk in relying
upon fundamental analysis is that while the overall health and position of asset classes may be good,
evolving market conditions may negatively impact the underlying securities.
Technical analysis involves the examination of past market data rather than specific issuer information in
determining the recommendations made to clients. Technical analysis may involve the use of mathematical
based indicators and charts, such as moving or forward averages, price correlations, and historical
market patterns. A substantial risk in relying upon technical analysis is that spotting historical trends may
not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee
that SPP will be able to accurately predict such a reoccurrence.
Valuation analysis looks at particular asset classes, both relative to their historical levels as well as on a
relative basis compared to other asset classes.
Business cycle analysis is similar to technical analysis in that it involves the assessment of market
conditions at a macro (entire market or economy) or micro level. The risks with cyclical analysis are
similar to those of technical analysis.
Investment Strategies
The Firm utilizes strategic and tactical asset allocation to invest its clients’ portfolios across
approximately 10 to 12 core asset classes. Strategic asset allocation involves setting longer-term target
ranges of allocations to the core asset classes and periodically rebalancing the portfolio back to those
targets. Tactical asset allocation involves seeking to opportunistically invest in certain assets classes
and/or overweighting or underweighting existing asset classes within preapproved ranges.
Risk of Loss
Risk of Loss
Investing involves risk, including the potential loss of principal, and all investors should be guided
accordingly.
Market Risks
The profitability of a significant portion of SPP’s recommendations and/or investment decisions may
depend to a great extent upon correctly assessing the future course of price movements of indices, bonds
and other asset classes. There can be no assurance that SPP will be able to predict those price movements
accurately or capitalize on any such assumptions.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and
ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
Page | 8
Disclosure Brochure
Strategic Probability Partners, LLC
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities
for a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated
daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees,
redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day,
although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The
trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market
volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or
discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at
least once daily for indexed based ETFs and potentially more frequently for actively managed ETFs.
However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata
NAV. There is also no guarantee that an active secondary market for such shares will develop or
continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually
20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular
ETF, a shareholder may have no way to dispose of such shares.
Item 9. Disciplinary Information
SPP does not have any required disclosures pursuant to this Item.
Item 10. Other Financial Industry Activities and Affiliations
SPP does not have any required disclosures pursuant to this Item.
Item 11. Code of Ethics
SPP has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. SPP’s Code of Ethics contains
written policies reasonably designed to prevent certain unlawful practices such as the use of material non-
public information by the Firm or any of its Supervised Persons and the trading by the same of securities
ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of SPP’s personnel to report their personal securities holdings
and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited
offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also
recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies
and procedures. This Code of Ethics has been established recognizing that some securities trade in
sufficiently broad markets to permit transactions by certain personnel to be completed without any
Page | 9
Disclosure Brochure
Strategic Probability Partners, LLC
appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions
may be made to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no
Supervised Person with access to this information may knowingly effect for themselves or for their
immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in
that security unless:
the transaction has been completed;
the transaction for the Supervised Person is completed as part of a batch trade with clients; or
a decision has been made not to engage in the transaction for the client.
•
•
•
These requirements are not applicable to: (i) direct obligations of the Government of the United States;
(ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact SPP to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
Recommendation of Broker/Dealers for Client Transactions
SPP generally recommends that clients utilize the custody, brokerage and clearing services of Schwab
Advisor ServicesTM (“Schwab”) for investment management accounts. However, clients of SPP are free to
direct the use of a custodian other than Schwab Advisor Services/Charles Schwab, Inc.
Factors which SPP considers in recommending Schwab or any other broker-dealer to clients include their
respective financial strength, reputation, execution, pricing, research and service. Schwab may enable the
Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction
charges. The commissions and/or transaction fees charged by Schwab may be higher or lower than those
charged by other Financial Institutions.
The commissions paid by SPP’s clients to Schwab comply with the Firm’s duty to obtain “best execution.”
Clients may pay commissions that are higher than another qualified Financial Institution might charge to
effect the same transaction where SPP determines that the commissions are reasonable in relation to the
value of the brokerage and research services received. In seeking best execution, the determinative
factor is not the lowest possible cost, but whether the transaction represents the best qualitative
execution, taking into consideration the full range of a Financial Institution’s services, including among
others, the value of research provided, execution capability, commission rates and responsiveness.
SPP seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client
transactions.
SPP periodically and systematically reviews its policies and procedures regarding its recommendation of
Page | 10
Disclosure Brochure
Strategic Probability Partners, LLC
Financial Institutions in light of its duty to obtain best execution.
Software and Support Provided by Financial Institutions
Specifically, SPP may receive the following benefits from Schwab:
• Access to a trading desk that exclusively services its institutional traders;
• Access to block trading which provides the ability to aggregate securities transactions and then
allocate the appropriate shares to client accounts; and
• Access to an electronic communication network for client order entry and account information.
Brokerage for Client Referrals
SPP does not consider, in selecting or recommending broker/dealers, whether the Firm receives client
referrals from the Financial Institutions or other third party.
Directed Brokerage
The client may direct SPP in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by SPP (as described above). As a result, the client
may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net
prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, SPP may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such
directed brokerage arrangements would result in additional operational difficulties.
Trade Aggregation
Transactions for each client generally will be effected independently, unless SPP decides to purchase or
sell the same securities for several clients at approximately the same time. SPP may (but is not obligated
to) combine or “batch” such orders to obtain best execution, to negotiate more favorable commission rates
or to allocate equitably among the Firm’s clients differences in prices and commissions or other transaction
costs that might not have been obtained had such orders been placed independently. Under this procedure,
transactions will generally be averaged as to price and allocated among SPP’s clients pro rata to the
purchase and sale orders placed for each client on any given day. To the extent that the Firm determines
to aggregate client orders for the purchase or sale of securities, including securities in which SPP’s
Supervised Persons may invest, the Firm generally does so in accordance with applicable rules
promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities
and Exchange Commission. SPP does not receive any additional compensation or remuneration as a result
of the aggregation.
In the event that the Firm determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when
Page | 11
Disclosure Brochure
Strategic Probability Partners, LLC
only a small percentage of the order is executed, shares may be allocated to the account with the smallest
order or the smallest position or to an account that is out of line with respect to security or sector
weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account
when one account has limitations in its investment guidelines which prohibit it from purchasing other
securities which are expected to produce similar investment results and can be purchased by other accounts;
(iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may
be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order
is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in
cases when a pro rata allocation of a potential execution would result in a de minimis allocation in
one or more accounts, the Firm may exclude the account(s) from the allocation; the transactions may be
executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of
an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
Account Reviews
SPP monitors client portfolios on an ongoing basis while regular account reviews are conducted on at
least a quarterly basis. Such reviews are conducted by the Firm’s investment adviser representatives. The
Firm contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations. It is incumbent upon clients to communicate any changes to their financial situation
and/or investment objectives to the Firm on a timely basis.
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements directly
from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise
requested, clients may also receive written or electronic reports from SPP and/or an outside service
provider, which contain certain account and/or market-related information, such as an inventory of
account holdings or account performance. Clients should compare the account statements they receive from
their custodian with any documents or reports they receive from SPP or an outside service provider.
Item 14. Client Referrals and Other Compensation
Client Referrals
The Firm does not currently provide compensation to any third-party solicitors for client referrals.
Item 15. Custody
The Advisory Agreement and/or the separate agreement with any Financial Institution generally authorize
SPP to debit client accounts for payment of the Firm’s fees and to directly remit that those funds to the
Firm in accordance with applicable custody rules. SPP will be deemed to have limited custody of client’s
assets and must have written authorization from the client to do so. The Financial Institutions that act as the
Page | 12
Disclosure Brochure
Strategic Probability Partners, LLC
qualified custodian for client accounts, from which the Firm retains the authority to directly deduct
fees, have agreed to send statements to clients not less than quarterly detailing all account transactions,
including any amounts paid to SPP. Where required, SPP also sends to clients a written invoice itemizing
the fee, including the formula used to calculate the fee, the time period covered by the fee and the amount
of assets under management on which the fee was based.
In addition, as discussed in Item 13, SPP may also send periodic supplemental reports to clients. Clients
should carefully review the statements sent directly by the Financial Institutions and compare them to
those received from SPP.
Item 16. Investment Discretion
In discretionary accounts, SPP is given the authority to exercise discretion on behalf of clients. SPP
is considered to exercise investment discretion over a client’s account if it can effect and/or direct
transactions in client accounts without first seeking their consent. SPP is given this authority through a
power-of-attorney included in the Advisory Agreement between SPP and the client and consistent
with and within the guidelines authorized by the investment policy statement for each client relationship.
Clients may request a limitation on this authority (such as certain securities not to be bought or sold). SPP
takes discretion over the following activities:
• The securities to be purchased or sold;
• The amount of securities to be purchased or sold; and
• When transactions are made.
Item 17. Voting Client Securities
Declination of Proxy Voting Authority
SPP generally does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf.
Clients receive proxies directly from the Financial Institutions where their assets are custodied and may
contact the Firm at the contact information on the cover of this brochure with questions about any such
issuer solicitations.
Item 18. Financial Information
SPP is not required to disclose any financial information due to the following:
• The Firm does not require or solicit the prepayment of more than $1200 in fees six months or
more in advance of services rendered;
• The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
• The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
Page | 13
Disclosure Brochure
Strategic Probability Partners, LLC
This brochure supplement provides information about Craig R. Sutherland that supplements the Strategic Probability
Partners, LLC brochure. You should have received a copy of that brochure. Please contact Craig R. Sutherland if you did not
receive Strategic Probability Partners, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional information about Craig R. Sutherland is also available on the SEC’s website at www.adviserinfo.sec.gov.
STRATEGIC PROBABILITY PARTNERS, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Craig R. Sutherland
Personal CRD Number: 2778068
Investment Adviser Representative
Strategic Probability Partners, LLC
292 14th Avenue South, Unit A
Naples, FL 34102
(305) 619-3566
craig@s-p-partners.com
Page | 14
Disclosure Brochure
Strategic Probability Partners, LLC
Item 2: Educational Background and Business Experience
Craig R. Sutherland
Name:
Born: 1956
Education:
Indiana University │ B.S., Business │ 1979
Business Background:
Strategic Probability Partners, LLC │ Principal │ November 2014 – Present
Bank of New York Mellon │ President – Southeast US │ June 1999 – December 2013
Item 3: Disciplinary Information
There are no legal or disciplinary events pertaining to the Advisor.
Item 4: Other Business Activities
SPP is required to disclose information regarding any investment-related business or occupation in which Craig R. Sutherland
is actively engaged. SPP has no information to disclose in relation to this Item.
Item 5: Additional Compensation
SPP is required to disclose information regarding any arrangement under which Craig R. Sutherland receives an economic
benefit from someone other than a client for providing investment advisory services. Craig Sutherland, in his individual
capacity, receives compensation for serving as a general, independent investment consultant to a one private foundation, which
is not a client of SPP.
Item 6: Supervision
While Craig R. Sutherland is a Principal of the Firm and is responsible for his own supervision. Craig R. Sutherland seeks to
ensure that investments are suitable for his individual clients and consistent with their individual needs, goals, objectives and
risk tolerance, as well as any restrictions requested by SPP’s clients.
Page | 15
Disclosure Brochure
Strategic Probability Partners, LLC
information about Lori Tedd Sutherland
is also available on the SEC’s website at
This brochure supplement provides information about Lori Tedd Sutherland that supplements the Strategic Probability
Partners, LLC brochure. You should have received a copy of that brochure. Please contact Craig R Sutherland. if you did not
receive Strategic Probability Partners, LLC’s brochure or if you have any questions about the contents of this supplement.
Additional
www.adviserinfo.sec.gov.
STRATEGIC PROBABILITY PARTNERS, LLC
Form ADV Part 2B – Individual Disclosure Brochure
for
Lori Tedd Sutherland
Personal CRD Number: 2875634
Investment Adviser Representative
Strategic Probability Partners, LLC
292 14th Avenue South, Unit A
Naples, FL 34102
(305) 619-3566
Lori@s-p-partners.com
Page | 16
Disclosure Brochure
Strategic Probability Partners, LLC
Item 2: Educational Background and Business Experience
Lori Tedd Sutherland
Name:
Born: 1959
Education:
BSBA Business, Boston University – 1980
MBA Business, University of Miami – 1987
Business Background:
04/2016 - Present
Investment Adviser Representative
Strategic Probability Partners, LLC
07/2007 – 09/2008
Managing Director
SCS Financial
10/2000 – 04/2006
Managing Director
State Street/U.S. Trust Company
Item 3: Disciplinary Information
There are no legal or disciplinary events pertaining to the Advisor.
Item 4: Other Business Activities
Lori Tedd Sutherland is not engaged in any investment-related business or occupation (other than this advisory firm).
Item 5: Additional Compensation
Lori Tedd Sutherland does not receive any economic benefit from any person, company, or organization, other than Strategic
Probability Partners, LLC in exchange for providing clients advisory services through Strategic Probability Partners, LLC.
Item 6: Supervision
As a representative of Strategic Probability Partners, LLC, Lori Tedd Sutherland is supervised by Craig R Sutherland, the firm's
Chief Compliance officer. Craig R Sutherland is responsible for ensuring that Lori Tedd Sutherland. adheres to all required
regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in
the firm’s Code of Ethics and compliance manual. The phone number for Craig Sutherland is (305) 619-3566.
Page | 17