FIRM DESCRIPTION
Sound Income Strategies, LLC (“SIS” and/or the “Firm”) was founded in 2014 and is wholly owned
by Sound Income Group LLC (“SIG”) David Scranton, the Firm’s Managing Member, owns the
majority interest in SIG with the remaining interest owned by current and former management
through an employee incentive plan, along with a select few of the Firm’s current Investment
Adviser Representatives (each a “IA-Rep”).
SIS is a fee based financial planning and investment management firm. The Firm and its IA-Reps,
through its affiliate Advisor’s Academy, recommends and sells insurance commissioned products to
the Firm’s clients..
SIS does not act as a custodian of client assets.
Other professionals (e.g., lawyers, accountants, tax preparers, insurance agents, etc.) are engaged
directly by the client on an as-needed basis and may charge fees of their own as their outside
businesses. Conflicts of interest will be disclosed to the client in the event they should occur.
This Brochure provides clients with a general overview of SIS’ services and responsibilities. Clients
can obtain more specific information about the process by which portfolios are constructed, how
investment strategies are carried out, options to customize investments, investment returns, and
other information by discussing with their IA-Rep. SIS encourages all clients to review the material
provided in this Brochure and other disclosures provided and discuss any questions related to
services offered with their IA-Rep to make certain they fully understand SIS’ investment process.
TYPES OF ADVISORY SERVICES
ASSET MANAGEMENT
SIS offers discretionary and non-discretionary direct asset management services to advisory clients.
SIS will offer clients ongoing portfolio management services through determining individual
investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment
selection, asset allocation, portfolio monitoring and the overall investment program will be based
on the above factors. The client will authorize SIS discretionary authority to execute selected
investment program transactions as stated within the Investment Advisory Agreement (“IAA”). SIS
provides such investment advisory services to its clients through customized managed investment
portfolios it creates for its clients. SIS is constantly searching for securities that have an improving
credit story and as we find these opportunities, we will "swap" out of some current holdings into
newer securities. We look for at least one of the following conditions before making a swap:
lowering duration, lowering interest rate risk, increasing yield, or lowing credit risk.
Under limited circumstances, the Firm may allow an IA-Rep to create a customized portfolio for its
client(s) which will be allocated and traded by the SIS trading team. These customized portfolios do
not track the Firm’s models. Just like the Firm’s models, these customized models will be adjusted
on an as needed basis by the IA-Rep and all positions will be reviewed by the Firm to ensure
suitability with the client’s risk tolerance and investment objectives.
In other limited circumstances, the Firm may allow an IA-Rep to enter into a non-discretionary
arrangement with its clients. Under this non-discretionary arrangement, the IA-Rep shall review
periodically the investments held by the client and shall make such recommendations to client with
reference to investments or changes in investments as it considers to be in the best interests of
client, including recommendations for the investment of cash. The Firm and/or IA-Rep shall not sell
or purchase any securities except upon approval from client. Client shall at all times have control or
management of the assets of the account(s), including the power to acquire and dispose of the
assets of the account(s).
ERISA PLAN SERVICES
SIS provides service to qualified and non-qualified retirement plans including 401(k) plans, 403(b)
plans, pension and profit-sharing plans, cash balance plans, and deferred compensation plans. SIS
may act as either:
• Limited Scope 3(21) Fiduciary. SIS typically acts as a limited scope 3(21) fiduciary that can
advise, help, and assist plan sponsors with their investment decisions. The plan sponsor is
still ultimately responsible for the decisions made in their plan, though using SIS can help
mitigate that plan sponsor’s liability by following a diligent process.
• 3(38) Investment Manager. SIS can also act as an ERISA 3(38) Investment Manager in which
it has discretionary management and control of a given retirement plan’s assets. SIS would
then become solely responsible and liable for the selection, monitoring and replacement of
the plan’s investment options.
FINANCIAL PLANNING AND CONSULTING
If financial planning services are applicable, the client will compensate SIS on a per plan fee basis
described in detail under “Fees and Compensation” section of this brochure. In a financial plan, the
IA-Rep may recommend specific stocks to increase sector weighting and/or dividend potential. The
IA-Rep may employ several different strategies, including long-term purchases, short-term
purchases, and short-term trading. All of these strategies may be used at various times as a possible
hedge against market movement, which may adversely affect the client’s portfolio.
In a financial plan, the IA-Rep may recommend selling positions for reasons that include, but are not
limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security
or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in
risk tolerance of the client or any risk deemed unacceptable for the client’s risk tolerance.
Representatives of SIS may also provide general non-securities advice on topics including estate
planning, retirement planning, and mortgage consulting. Fees are billed at a fixed or an hourly rate,
negotiated in advance and paid as services are rendered. The non- securities financial planning will
not exceed 50% of the Firm’s billings.
EDUCATIONAL WORKSHOPS
SIS provides educational workshops to prospects and clients. These workshops will cover topics
such as social security, RMD’s or the Financial Markets where they cover benefits and any
regulatory changes. SIS will also discuss estate planning and explain the different options. If needed,
SIS will also refer clients to an attorney.
SUB-ADVISOR SERVICES
SIS offers sub-advisory services to other registered investment advisors whereby it provides such
advisors with access to customized managed investment portfolio options that they can make
available to their clients. Clients of advisory firms who engage SIS to provide sub-advisory services
work directly with their advisory firm to gather information about their financial situations, goals,
and objectives, including information on their investment time horizon, risk tolerance, and other
relevant information and factors.
Based on this information, the client’s advisory firm proposes an overall strategy that includes
investment portfolio recommendations in the form of one or more customized investment
portfolios managed by SIS. Representatives from the client’s advisory firm will periodically meet
with their clients to discuss any changes to their financial situations, goals, and objectives to help
ensure that the factors upon which recommendations are based continue to remain appropriate
and in their best interests.
SIS personnel do not possess knowledge of third-party advisory firm’s clients’ individual
information or investment goals or objectives to allow it to provide personalized investment advice
to such clients. The client’s advisory firm is responsible for determining suitable portfolio strategies
and, to the extent required, delivering this brochure to clients with assets under management by
SIS. Any modifications to the portfolios managed by SIS are affected through the sale of securities in
client accounts, which may have tax ramifications to clients.
CO-ADVISOR SERVICES
SIS offers co-advisory services to other registered investment advisors whereby it provides such
advisors with access to customized
managed investment portfolio options that they can make
available to their clients. Clients of advisory firms who engage SIS to provide co-advisory services
work directly with their advisory firm to gather information about their financial situations, goals,
and objectives, including information on their investment time horizon, risk tolerance, and other
relevant information and factors.
Based on this information, the client’s advisory firm proposes an overall strategy that includes
investment portfolio recommendations in the form of one or more customized investment
portfolios managed by SIS. Representatives from the client’s advisory firm will periodically meet
with their clients to discuss any changes to their financial situations, goals, and objectives to help
ensure that the factors upon which recommendations are based continue to remain appropriate
and in their best interests.
SIS will assign an IA-Rep to help assist in this process and that IA-Rep will possess knowledge of
third-party advisory firm’s clients’ individual information, investment goals, and objectives to allow
them to assist in providing personalized investment advice to such clients. The client’s advisory
firm is responsible for determining suitable portfolio strategies. Both representatives are
responsible for delivering the required brochures to clients. Any modifications to the portfolios
managed by SIS are affected through the sale of securities in client accounts, which may have tax
ramifications to clients.
SUB-ADVISORY SERVICES TO ETFS
SIS serves as investment sub-adviser to the (i) Tidal ETF Trust - Sound Equity Dividend Income ETF
(“DIVY”) and (ii) Sound Enhanced Fixed Income ETF (“FXED”) (together, the “SIS ETFs”), each SIS
ETF is independently registered with the SEC under the Investment Company Act of 1940 (the “’40
Act”) and listed on NYSE ARCA, Inc exchange. Please refer to the Firm’s website -
https://soundincomestrategies.com/etfs/ for additional information on the SIS ETFs.
SIS, Tidal Investments, LLC ,CRD # 164201, an SEC registered investment adviser, (“Tidal”), the
investment adviser to the SIS ETFs, and Tidal ETF Services, LLC “(“Tidal ETF”), which provides
consulting and administrative support for ETFs, have entered into two agreements with respect to
each SIS ETF: (i) a sub-advisory agreement (“Sub-Advisory Agreement”), which Tidal has agreed
to pay SIS a sub-advisory fee equal to 0.2% of the SIS ETFs daily average net assets; and (ii) an
Exchange-Traded Fund Platform Support Agreement (“Support Agreement”), which identifies
each parties respective financial obligations and right to any profits associated with the SIS ETFs.
SIS is responsible for recommending portfolio securities and other investment instruments on
behalf of the SIS ETFs. The trading of the underlying securities are subject to the supervision of
TIDAL and TIDAL ETF. As of the filing of this Brochure, the Firm has not received any fees pursuant
to the terms of the two agreements. It is not anticipated the Firm will receive any fees for acting as a
sub-advisor to the SIS ETFs until certain thresholds under the agreements are met.
Like all other ETFs, the SIS ETFs are not tailored to the individualized needs of any fund
shareholder or investor and an investment in such a vehicle does not, in and of itself, create an
advisory relationship between the shareholder, investor, SIS, Tidal, or Tidal ETF. Clients of SIS may
authorize SIS to purchase these SIS ETFs in their accounts by signing a specific section of their IAA
which outlines the SIS ETFs, the fees pursuant to the Sub-Advisory and Support Agreements, and
any conflicts of interest that may arise.
Clients and the general public can invest directly in each of the SIS ETFs without paying additional
separate account management fees to SIS. It is recommended each client carefully review both the
SIS ETFs’ fees and SIS’s advisory fees in order to fully understand the total amount of fees clients
will pay in connection with their investments that are managed by SIS. In addition, it is
recommended for each client intending to authorize the Firm to invest clients’ assets in the SIS
ETFs to review their offering documents which set forth their investment strategies, guidelines, and
restrictions.
INSURANCE PLANNING AND CONSULTING SERVICES
IA-Reps of SIS may also be licensed as independent insurance agents who solicit, offer, recommend
supplemental insurance planning or consulting services.
Your IA-Rep in his or her separate capacity as an insurance agent, may suggest clients to purchase
disability insurance, life insurance, annuities, or other insurance products. If a client elects to
implement the purchase of an insurance product recommended by its IA-Rep, your IA-Rep will
receive insurance commissions and other compensation fees (“Insurance Fees”). Such Insurance
Fees can be paid upfront, paid from the Insurance company base, incentives, or in some cases
marketing credits paid by the wholesaler. Clients are recommended to carefully review their
policies and ask their IA-Reps any questions about the policy and the fees paid to the IA-Rep.
This receipt of Insurance Fees creates an incentive for your IA-Rep to recommend those insurance
products for which your IA-Rep may receive a portion of the Insurance Fees in his or her separate
capacity as an insurance agent, rather than on a client’s needs. Mr. Scranton, majority owner of SIS
consults with IA-Reps on insurance products and IA-Reps may place the insurance product
transaction through Advisors’ Academy, an affiliate of SIS which Mr. Scranton is the majority owner.
Consequently, the advice rendered to clients could be biased. To prevent conflicts of interest, the
Firm has developed written supervisory procedures that prohibit our IA-Reps from preferring their
own interests to that of the client. Any associated person not observing our policies is subject to
sanctions up to and including termination.
Clients are under no obligation to implement any insurance or annuity transaction through their IA-
Rep. (Please refer to Item 10 Other Financial Industry Activities and Affiliations for more details.)
RECOMMENDATIONS OR SELECTIONS OF OTHER INVESTMENT ADVISORS
SIS may enter into agreements with third party investment advisers specializing in mutual fund or
ETF management. SIS refers clients to such third-party advisers who charges a fee, and in return SIS
receives a portion of the advisory fee paid by the client. The programs may not be available to all
clients because of account minimums, client objectives and manager restrictions. SIS's services
include assisting a client in selecting a third-party investment adviser whose investment styles and
strategies suit the client’s individual needs and financial objectives. The investments managed in
these accounts are usually limited to mutual funds and ETFs. With most programs, SIS's role is
usually limited to making the referral. In others, SIS assists the client in completing an investment
planning questionnaire to help guide the third-party adviser’s investment decisions for the client.
SIS may also assist clients in making investment and portfolio allocation decisions for these
accounts. Depending on the program selected by the client, the third-party adviser may or may not
have discretionary power to purchase or sell investments in the client’s account. SIS Advisors are
available to their clients to discuss the selected manager’s performance. Also, clients may or may
not pay a sales load for mutual funds or annuities, or commissions on other investments placed
within the client’s account.
CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
The goals and objectives for each client are documented in our client files. Investment strategies are
created that reflect the stated goals and objective. Clients may impose restrictions on investing in
certain securities or types of securities.
Agreements may not be assigned without a client’s consent.
CLIENT ASSETS UNDER MANAGEMENT
As of May 17, 2024, SIS had $2,841,732,119 on a discretionary basis and $159,424,340 on a non-
discretionary basis.