Introduction
Stratos Investment Management, LLC (“SIM”) is wholly owned by Stratos Intermediate Holdco LLC
within the Stratos Wealth Holdings, LLC family of companies and has been a registered investment
adviser since 2016. Stratos Intermediate Holdco LLC is a holding company which owns the following
registered investment advisers and a limited purpose broker-dealer.
1. Stratos Wealth Partners, Ltd. (“SWP”), a retail investment firm offering advice
primarily through Investment Advisor Representatives (“IARs”) who are
securities licensed through LPL Financial Corporation (“LPL Financial”), Member
FINRA/SIPC.
2. Stratos Wealth Advisors, LLC (“SWA”), a retail investment firm offering advice
primarily through IARs who are not securities licensed.
3. Stratos Wealth Securities, LLC (“SWS”), a limited purpose broker-dealer, Member
FINRA/SIPC. SWS does not process securities transactions or maintain client accounts.
4. Renaissance Investment Group, a retail investment firm offering advice through IARs
who are not securities licensed.
Please see Item 10 for more information.
Overview
SIM acts as portfolio manager for wrap fee programs sponsored by its affiliated registered investment
advisers, SWP and SWA. SIM also provides subadvisory services to IARs of SWP and SWA on a
non-wrap fee basis. Finally, Stratos Investment Management provides subadvisory services to IARs
of Lineweaver Wealth Advisors, LLC on a non-wrap fee basis. SIM offers ongoing portfolio
management based on the individual goals, objectives, time horizon, and risk tolerance of each client.
The wrap fee program allows the client to pay one stated fee that includes management fees and
transaction costs. SIM also provides its services on a non-wrap fee basis generally in situations where
wrap fee programs are not permitted or economically unfeasible. Clients may end up paying more
or less in a wrap fee program than in a non-wrap fee program.
SIM primarily acts as a subadviser to IARs. Its portfolio management services include, but are not
limited to, the following:
• Investment strategy
• Asset allocation
• Portfolio construction
• Risk tolerance
• Regular portfolio monitoring
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SIM will typically require discretionary authority in order to select securities and execute
transactions without permission from the client prior to each transaction.
As of December 31, 2022, SIM had approximately $1,521,000,000 in assets under management on a
discretionary basis and $0 in assets under management on a non-discretionary basis.
SIM’s investment decisions are driven by the Investment Policy Statement (“IPS”) for each Strategy.
Tax considerations are secondary to asset allocation decisions.
SIM has agreements with the following broker-dealer custodians:
• Fidelity Brokerage Services, LLC and National Financial services, LLC, Member
FINRA/SIPC;
• Charles Schwab, Member FINRA/SIPC; and
• LPL Financial, Member FINRA/SIPC.
The choice of custodian is determined by the primary advisor and/or client.
SIM seeks to provide investment decisions that are made in accordance with the fiduciary duties
owed to its accounts and without consideration of SIM’s economic, investment or other financial
interests. To meet its fiduciary obligations, SIM attempts to avoid, among other things, investment
or trading practices that systematically advantage or disadvantage certain client portfolios. It is
SIM’s policy to allocate investment opportunities and transactions it identifies as being appropriate
and prudent among its clients on a fair and equitable basis to avoid favoring one client over another
over time. Clients should refer to below for further details regarding SIM’s model portfolios.
Description of Model Portfolios
SIM Tactical Models
Accounts managed based on a SIM Tactical Model Portfolio will be managed similar to other clients
utilizing this model. There are no guarantees a portfolio managed based on a model will ensure
positive results. Past performance is no guarantee of future results. Further, any model account
assembled based on prior performance analysis has the benefit of having knowledge of all facts of
the market and performance of securities after the fact. SIM provides portfolio management services
for the Tactical Models on both a wrap and a non-wrap fee basis.
• The Tactical Conservative Composite contains all discretionary portfolios
managed to the SIM Tactical Conservative strategy. This composite is a Tactical
Conservative strategy consisting of primarily mutual funds and exchange traded
products, but can include closed end funds and individual securities (equities or
bonds). The benchmark for this strategy is a 35%/65% mix of the MSCI All
Country World Investable Market Index Net Return and the Barclays Capital US
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Aggregate Bond Total Return index. Its inception year is 2011, and the account
minimum is $100,000.
• The Tactical Moderate Composite contains all discretionary portfolios managed
to the SIM Tactical Moderate strategy. This composite is a Tactical Moderate
strategy consisting of primarily mutual funds and exchange traded products but
can include closed end funds and individual securities (bonds or equities). The
benchmark for this strategy is a 55%/45% mix of MSCI All Country World
Investable Market Index Net Return and the Barclays Capital US Aggregate Bond
Total Return index. Its inception year is 2011, and the account minimum is
$100,000.
• The Tactical Growth Composite contains all discretionary portfolios managed to
the SIM Tactical Growth strategy. This composite is a Tactical Growth strategy
consisting of primarily mutual funds and exchange traded products but can
include closed end funds and individual securities (bonds or equities). The
benchmark for this strategy is a 70%/30% mix of the MSCI All Country World
Investable Market Index Net Return and the Barclays Capital US Aggregate Bond
Total Return Index. Its inception year is 2011, and the account minimum is
$100,000.
• The Tactical Aggressive Growth Composite contains all discretionary portfolios
managed to the SIM Tactical Aggressive Growth strategy. This composite is a
Tactical Aggressive Growth strategy consisting of primarily mutual funds and
exchange traded products but can include closed end funds and individual
securities (bonds or equities). The benchmark for this strategy is a 85%/15% mix
of the MSCI All Country World Investable Market Index Net Return and the
Barclays Capital US Aggregate Bond Total Return Index. Its inception year is 2023,
and the account minimum is $100,000.
• The Tactical Diversified Income Composite contains all discretionary portfolios
managed to the SIM Tactical Diversified Income strategy. This strategy is a Tactical
Diversified Income strategy consisting of primarily mutual funds and exchange
traded products but can include closed end funds and individual securities (bonds
or equities). The benchmark for this strategy is 60% MSCI World High Dividend
Index and 40% Bloomberg Barclays US Aggregate Bond Total Return Index. Its
inception year is 2011, and the account minimum is $100,000.
• The Tactical Low Duration Income Composite contains all discretionary
portfolios managed to the SIM Ultra Low Duration strategy. This composite is a
Tactical Ultra Low Duration strategy consisting of primarily mutual funds and
exchange traded products but can include closed end funds and individual
securities (bonds or equities). The benchmark for this strategy is a 50%/50% mix
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of the Bloomberg Barclays US 1-5 Year Government Credit Float Adjusted Total
Return Index and the Bank of America Merrill Lynch US Treasuries 1-3 Year Total
Return Index. Its inception year is 2017, and the account minimum is $100,000.
• The SIM Barnwood MidCap Composite contains all discretionary portfolios
managed to the SIM Barnwood MidCap strategy. This strategy consists of
individual equities whose market capitalization lie between $1 billion and $15
billion. The benchmark for this strategy is the S&P 400 index. The inception year
is 2024, and the account minimum is $100,000.
• The SIM Barnwood Small Cap Composite contains all discretionary portfolios
managed to the SIM Barnwood Small Cap strategy. This strategy consists of
individual equities whose market capitalization lie below $2 billion. The
benchmark for this strategy is the Russell 2000 index. The inception year is 2024,
and the account minimum is $100,000.
SIM Strategic Models
Accounts managed based on a SIM Strategic Model will be managed similar to other clients utilizing
this model. There are no guarantees a portfolio managed based on a model will ensure positive
results. Past performance is no guarantee of future results. Further, any model account assembled
based on prior performance analysis has the benefit of having knowledge of all facts of the market
and performance of securities after the fact. SIM provides portfolio management services for the
Strategic Models on a wrap and a non-wrap fee basis.
• The Strategic Conservative Composite contains all discretionary portfolios
managed to the SIM Strategic Conservative strategy. The benchmark for this
strategy is a 35%/65% mix of the MSCI All Country World Investable Market
Index Net Return and the Barclays Capital US Aggregate Bond Total Return Index.
The inception year is 2015, and the account minimum is $10,000.
• The Strategic Moderate Composite contains all discretionary portfolios managed
to the SIM Strategic Moderate strategy. Its inception year is 2012. The benchmark
for this strategy is a 55%/45% mix of MSCI All Country World Investable Market
Index Net Return and the Barclays Capital US Aggregate Bond Total Return
indices. Composite minimum is $10,000.
• The Strategic Growth Composite contains all discretionary portfolios managed to
the SIM Strategic Growth strategy. Its inception year is 2012. The benchmark for
this strategy is a 70%/30% mix of the MSCI All Country World Investable Market
Index Net Return and the Barclays Capital US Aggregate Bond Total Return index.
Composite minimum is $10,000.
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SIM Enhanced Index Models
Accounts managed based on a SIM Enhanced Index Model will be managed similar to other clients
utilizing this model. There are no guarantees a portfolio managed based on a model will ensure
positive results. Past performance is no guarantee of future results. Further, any model account
assembled based on prior performance analysis has the benefit of having knowledge of all facts of
the market and performance of securities after the fact. SIM provides portfolio management services
for the Enhanced Index Models on both a wrap and a non-wrap fee basis.
• The Enhanced Index Conservative Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Conservative strategy. This
strategy consists of ETFs and mutual funds. The benchmark for this strategy is as
follows: 35% Barclays Capital US Aggregate Bond Total Return Index; 29% BofA
US Treasury 1 Year Total Return Index; 16% Citi World Govt Bond Total Return
Index; and 20% MSCI All Country World Investable Market Index Net Return.
The
inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Moderate Conservative Composite contains all
discretionary portfolios managed to the SIM Enhanced Index Moderate
Conservative strategy. This strategy consists of ETFs and mutual funds. The
benchmark for this strategy is as follows: 26% Barclays Capital US Aggregate Bond
Total Return Index, 22% BofA US Treasury 1 Year Total Return Index, 12% Citi
World Govt Bond Total Return Index and 40% MSCI All Country World
Investable Market Index Net Return. The inception year is 2017, and the account
minimum is $100,000.
• The Enhanced Index Moderate Composite contains all discretionary portfolios
managed to the SIM Enhanced Index Moderate strategy. This strategy consists of
ETFs and mutual funds. The benchmark for this strategy is as follows: 29%
Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1
Year Total Return Index; 8% Citi World Govt Bond Total Return Index; and 60%
MSCI All Country World Investable Market Index Net Return. The inception year
is 2017, and the account minimum is $100,000.
• The Enhanced Index Growth Composite contains all discretionary portfolios
managed to the SIM Enhanced Index Growth strategy. This strategy consists of
ETFs and mutual funds. The benchmark for this strategy is as follows: 13%
Barclays Capital US Aggregate Bond Total Return Index; 3% BofA US Treasury 1
Year Total Return Index; 4% Citi World Govt Bond Total Return Index; and 80%
MSCI All Country World Investable Market Index Net Return. The inception year
is 2017, and the account minimum is $100,000.
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• The Enhanced Index Aggressive Composite contains all discretionary portfolios
managed to the SIM Enhanced Index Aggressive strategy. This strategy consists
of ETFs and mutual funds. The benchmark for this strategy is the MSCI All
Country World Investable Market Index Net Return. The inception year is 2017,
and the account minimum is $100,000.
• The Enhanced Index Moderate-US Only Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Moderate-US Only strategy. This
strategy consists of ETFs and mutual funds. The benchmark for this strategy is as
follows: 37% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA
US Treasury 1 Year Total Return Index; and 60% Russell 3000 Total Return Index.
The inception year is 2017, and the account minimum is $100,000.
• The Enhanced Index Aggressive-US Only Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Aggressive-US Only strategy. This
strategy consists of ETFs funds and mutual funds. The benchmark for this strategy
is the Russell 3000 Total Return Index. The inception year is 2017, and the account
minimum is $100,000.
• The Enhanced Index Focused Conservative Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Focused Conservative strategy.
This strategy consists of ETFs and mutual funds. The benchmark for this strategy
is as follows: 35% Barclays Capital US Aggregate Bond Total Return index, 29%
BofA US Treasury 1 Year Total Return Index, 16% Citi World Govt Bond Total
Return Index and 20% MSCI All Country World Investable Market Index Net
Return. The inception year is 2017, and the account minimum is $10,000.
• The Enhanced Index Focused Moderate Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Focused Moderate strategy. This
strategy consists of ETFs and mutual funds. The benchmark for this strategy is as
follows: 29% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA
US Treasury 1 Year Total Return Index; 8% Citi World Govt Bond Total Return
Index; and 60% MSCI All Country World Investable Market Index Net Return. The
inception year is 2017, and the account minimum is $10,000.
• The Enhanced Index Focused Growth Composite contains all discretionary
portfolios managed to the SIM Enhanced Index Focused Growth strategy. This
strategy consists of ETFs and mutual funds. The benchmark for this strategy is as
follows: 13% Barclays Capital US Aggregate Bond Total Return Index; 3% BofA
US Treasury 1 Year Total Return Index; 4% Citi World Govt Bond Total Return
Index; and 80% MSCI All Country World Investable Market Index Net Return. The
inception year is 2017, and the account minimum is $10,000.
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SIM Global Individual Equity Model
Accounts managed based on the SIM Global Individual Equity Model will be managed similar to
other clients utilizing this model. There are no guarantees a portfolio managed based on a model
will ensure positive results. Past performance is no guarantee of future results. Further, any model
account assembled based on prior performance analysis has the benefit of having knowledge of all
facts of the market and performance of securities after the fact. SIM provides portfolio management
services for the Global Individual Equity Model on both a wrap and a non-wrap fee basis.
• The Global Individual Equity Composite contains all discretionary portfolios
managed to the SIM Global Individual Equity strategy. This strategy consists of
individual equities and may include ETFs and mutual funds at modest levels. The
benchmark for this strategy is the S&P 500 Total Return Index. The inception year
is 2017, and the account minimum is $100,000.
The SIM ESG USA No Energy Model
Accounts managed based on the SIM ESG USA No Energy Model will be managed similar to other
clients utilizing this model. There are no guarantees a portfolio managed based on a model will
ensure positive results. Past performance is no guarantee of future results. Further, any model
account assembled based on prior performance analysis has the benefit of having knowledge of all
facts of the market and performance of securities after the fact. SIM provides portfolio management
services for the SIM ESG USA No Energy Model on both a wrap and a non-wrap fee basis.
• The ESG USA No Energy Composite contains all discretionary portfolios
managed to the SIM ESG USA No Energy strategy. This strategy consists of
selected individual equities that are held in the benchmark. The benchmark for
this strategy is the MSCI USA Extended ESG Focus GR Index. The inception year
is 2019, and the account minimum is $100,000.
The SIM Dividend Growth Strategy
Accounts managed based on the SIM Dividend Growth Strategy will be managed similar to other
clients utilizing this model. There are no guarantees a portfolio managed based on a model will
ensure positive results. Past performance is no guarantee of future results. Further, any model
account assembled based on prior performance analysis has the benefit of having knowledge of all
facts of the market and performance of securities after the fact. SIM provides portfolio management
services for the Dividend Growth Strategy on both a wrap and a non-wrap fee basis.
• The Dividend Growth Composite contains all discretionary portfolios
managed to the SIM Dividend Growth strategy. This strategy consists of
individual equities and may include ETFs and mutual funds at modest levels. The
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benchmark for this strategy is the Morningstar U.S. Dividend Growth Index.
The inception year is 2020, and the account minimum is $100,000.
The SIM Multi Asset Strategies
Accounts managed based on a SIM Multi Asset Strategy will be managed similar to other clients
utilizing this model. There are no guarantees a portfolio managed based on a model will ensure
positive results. Past performance is no guarantee of future results. Further, any model account
assembled based on prior performance analysis has the benefit of having knowledge of all facts of
the market and performance of securities after the fact. SIM provides portfolio management services
for the Multi Asset Strategies on both a wrap and a non-wrap fee basis.
• The Multi Asset Municipals Composite contains all discretionary portfolios
managed to the SIM Multi Asset Municipals strategy and offers of multiple
equities/fixed income asset allocations. This strategy consists of individual stocks,
bonds, mutual funds and exchange traded products. The benchmark for the
equity portion of this composite is the MSCI All Country World IMI Net Return,
and the benchmark for the fixed income portion of this composite is the
Bloomberg Barclays Municipal Bond 5 Year, rebalanced annually. The
inception year is 2019, and the account minimum is $250,000.
• The Multi Asset Taxable Composite contains all discretionary portfolios
managed to the SIM Multi Asset Taxable Strategy and offers multiple
equities/fixed income asset allocations. This strategy consists of individual stocks,
bonds, mutual funds and exchange traded products. The benchmark for the
equity portion of this composite is the MSCI All Country World IMI Net Return,
and the benchmark for the fixed income portion of this composite is the
Bloomberg Barclays US Aggregate Municipal Bond, rebalanced annually. The
inception year is 2019, and the account minimum is $250,000.
The SIM custom indexing model
Accounts managed based on the SIM Custom Indexing Model will be managed similar to other
clients utilizing this model. There are no guarantees a portfolio managed based on a model will
ensure positive results. Past performance is no guarantee of future results. Further, any model
account assembled based on prior performance analysis has the benefit of having knowledge of all
facts of the market and performance of securities after the fact. SIM provides portfolio management
services for the SIM Custom Indexing Model on both a wrap and a non-wrap fee basis.
• SIM has established agreements to work with a third-party investment adviser in
a sub-advisory capacity. The sub-advisor is responsible for all investment-related
decisions and trading in the client accounts. The sub-advisor may be limited to
only manage assets through specific custodians. For more information about what
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custodians a specific sub-advisor is authorized to offer services through, please
refer to the sub-advisor’s ADV. SIM retains the authority to hire and fire sub-
advisors at our discretion. The account minimum size is $100,000.
Custom Strategies
SIM also offers two types of Custom Strategies, as described below. Custom Strategies may
not be available to all clients, new clients, all primary advisors, and/or at all custodians. Each
Custom Strategy is approved separately by SIM on a case-by-case basis and may be offered
on both a wrap and non-wrap fee basis.
• Client Specific Constraints – Strategies designed and monitored specifically for one
client or household.
• Advisor Specific Constraints – Strategies designed and monitored in conjunction with
the client’s primary advisor.
For every approved Custom Strategy, an Investment Policy Statement is created and approved by
either the client (for Client Specific Constraints) or the primary advisor (for Adviser Specific
Constraints).
SIM may utilize third party research to assist in analyzing investment opportunities; SIM will then choose how
to act on that information in executing its analysis and investment strategies.