Form ADV Part 2A

Firm Overview

Sequoia Financial Advisors, LLC (“Sequoia Financial Advisors”, “Sequoia”, “us”, “we”, “advisor” or “SFA”) is an Ohio limited liability company, founded in 2000, and is a Registered Investment Advisory (“RIA”) firm under the Investment Advisers Act of 1940, 15 U.S.C. § 80b-1, et. seq. We have been registered with the Securities and Exchange Commission since 2002 and are 100% owned by Sequoia Financial Group, LLC, an independent financial services firm formed in 2000. Sequoia Financial Advisors’ President, Thomas Haught has ownership interest in Sequoia Financial Group, LLC. Further detail regarding SFA ownership can be found under the ADV, in Schedule A and Schedule B.

Advisory Services

SFA provides wealth planning, consulting and investment management services. Prior to engaging SFA for investment advisory services, the client is required to enter into one or more written agreements with SFA setting forth the terms and conditions under which SFA renders its services.

Asset Management Services

Clients can engage SFA to manage all or a portion of their assets on a discretionary or non-discretionary basis. SFA provides continuous and regular account supervision and advice about investments held within a client’s portfolio as indicated in their individual agreement. SFA may utilize some or all of the services described below in providing asset management services.

Model Portfolios

SFA may recommend allocation model portfolios on a discretionary basis. These model portfolios are created, monitored, and updated by SFA. The model portfolios are a combination of but not limited to open-end mutual funds and exchange traded funds (“ETFs”), as well as individual stocks. Some models may include the use of an Affiliated ETF (See “Affiliated ETF” description below). We may add other asset classes, such as private funds if we feel it is in the client’s interest. We offer models in different asset allocation combinations. Our investment committee reviews the model portfolios on a regular basis. We reserve the right to make adjustments at any time.

These models vary from client to client. These variations include taxable and tax sensitive as well as ranges from one hundred percent equity to one hundred percent fixed income. Further information is available upon request.

Affiliated ETF

SFA serves as a subadvisor to an affiliated exchange traded fund—the CCM Global Equity ETF (the “Affiliated ETF”). SFA may recommend and use its investment discretion to invest clients in the Affiliated ETF. Depending on a client’s investment strategy and asset allocation, SFA can invest up to 100% of a client’s account in the Affiliated ETF. This arrangement creates a conflict of interest as SFA stands to receive a portion of the fee a client incurs investing in the CCM Global Equity ETF in addition to the fees described in Item 5 below. As of April 1, 2025, the adviser to the Affiliated ETF is entitled to receive an advisory fee based on the Affiliated ETF’s average daily net assets for the services and facilities it provides payable at the annual rate of 0.34%.
1 The adviser pays SFA as subadvisor to the Affiliated ETF a fee, which is calculated daily and paid monthly, at an annual rate of 0.17% based on the fund’s average daily net assets2. SFA mitigates this conflict of interest by disclosing it to clients, providing clients with an opportunity to ask questions, and seeking a clients informed consent to manage their account in this manner in through disclosures present in their Investment Management Agreement. A client may also limit SFA’s ability to invest in the Affiliated ETF by informing SFA of that restriction. The Affiliated ETF’s prospectus details the investment objectives, strategy, and the schedule of fees to be received by SFA, and clients should carefully review this document, as well as the statement of additional information.

Custom Portfolios­­

In a Custom Portfolio, SFA will manage the client’s assets to their stated risk tolerance and investment objectives utilizing stocks, bonds, mutual funds, ETFs, REITs and potentially private investments. Custom portfolios are reviewed periodically and discussed during client reviews.

Mutual Fund Share Class

SFA evaluates a fund’s share class options in order to select the most appropriate share classes to purchase. While this typically results in SFA choosing the lowest internal cost share class available, the process also accounts for the total amount of the investment, trading costs if applicable, and expected holding time among other factors. As a result, there may be instances where purchasing a share class with a higher internal cost but no transaction costs appears to be the total lower cost option for the client. Periodically, SFA will review the share classes of funds in client accounts and determine if we believe that we should conduct an interfund class exchange (movement from one share class to another) to a lower internal cost share class based on the above. SFA will make the exchange in our model accounts and initiate the exchange in custom accounts, after review with the individual advisors. This helps SFA account for share classes in client accounts as a result of transfers and firm mergers.

Independent Investment Managers

SFA may recommend that certain clients utilize the active discretionary management of a portion of their assets by certain independent non-affiliated investment managers (“Independent Manager”), based upon the investment objectives of the client.

The terms and conditions of the relationship between SFA, the client and the Independent Manager are set forth in separate written agreements. SFA will serve as a discretionary investment advisor to clients in recommending an Independent Manager but may not have discretion over the trading in the account. In some cases, the client may sign a separate agreement with the designated Independent Manager. SFA will continue to be responsible for monitoring and reviewing each client’s account to ensure that the assets are being managed in accordance with their investment objectives. SFA will receive an advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Manager.

When recommending or selecting an Independent Manager for a client, SFA reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager and independent third parties. Factors that SFA considers in recommending an Independent Manager include the management style, performance, reputation, financial strength, reporting, pricing, and research of the Independent Manager. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, SFA’s investment advisory fee set forth below.

In addition to SFA’s written disclosure brochure, the client will also receive the written disclosure brochure of the designated Independent Manager. Certain Independent Managers will impose more restrictive account requirements and may have billing practices different than SFA. In such instances, SFA can alter its corresponding account requirements and/or billing practices to accommodate.

In limited cases, SFA may also recommend a Client invest in a private fund (described below) or a private fund managed by a third party.

Private Funds

SFA acts as General Partner, Managing Member or Advisor to several private funds (“Funds”), each exempt from registration under Regulation D. These Funds are available only to certain qualified investors pursuant to the respective Fund’s offering documents. Information regarding the funds’ fees, expenses, risks and investment objectives can be found in the Funds’ offering documents. Details of each Fund can be reviewed under Section 7B of Form ADV.

We recommend our Funds to our Clients, which creates an inherent conflict of interest in achieving scale and lowering the expense ratios for each Fund.

SFA currently manages legacy private funds that charge Clients a fund-level management fee, and / or a performance fee, creating a conflict of interest in recommending them to clients of SFA. SFA mitigates this conflict by not offering investment in these Funds to new investors or Clients.

Wealth Planning Services

SFA offers Clients financial planning services including estate planning, insurance planning, retirement planning, college planning, estate planning, business succession planning and/or investment planning. These services are generally referred to as “Wealth Planning Services”. SFA’s Wealth Planning Services involves gathering personal and financial data, identifying the Clients’ needs, goals and objectives and processing and analyzing this information to assist Clients to try and meet their stated objectives. Clients engaging formal plan services will be provided a financial plan summarizing the client’s financial situation and SFA’s observations and recommendations. Clients are under no obligation to hire SFA to implement strategies recommended under Wealth Planning Services. Financial consulting arrangements and hourly project work are less formal and do not necessarily include a written summary. SFA does not provide legal, accounting or tax advice.

Estate Document Preparation and Review

SFA offers to provide estate document preparation through an unaffiliated third party for clients electing estate planning as a service. Estate document preparation is included as part of the overall estate planning service.

SFA does not provide legal guidance. Clients utilizing this service to create estate documents are urged to seek guidance from a licensed attorney.

Retirement Plan Services

SFA offers advisory services to qualified and non-qualified retirement and deferred compensation plans. Services can be tailored to client requirements. We will recognize and accept a fiduciary role under ERISA when applicable. Clients can choose to use any or all of the following services:

1. Plan Design - SFA develops customized retirement plans specifically designed and optimized to meet plan sponsor goals and objectives.
2. Investment Policy Statement preparation or review: Determining an appropriate investment strategy that reflects the plan sponsor’s stated investment objectives for management of the overall plan.
3. SFA may act as a 3(38) investment manager to our client plans ensuring that investment options include a diversified menu of covering the full spectrum of equities, fixed income, and cash equivalents.
4. Selection or Review of Investment Vehicles: We assist plan sponsors in constructing appropriate asset allocation models (or review existing models) and recommend various mutual funds (both index and managed) to implement the client’s investment strategy.
5. Monitoring of investment performance of plan assets.
6. Plan Benchmarking: SFA assists clients in ensuring their plans are competitive in total cost structure for the services they are receiving.
7. Education and Training: general investment, fiduciary, and / or educational support designed for the plan participants, plan sponsors, or trustees.
8. Financial Wellness Programming – for an additional fee, SFA provides access to a financial wellness technology platform and programming designed to increase overall financial literacy and efficacy for plan participants, decrease absenteeism and turnover related to financial stress, develop financially well employees that are able to meet current obligations and address future planning/preparedness, and meet employees where they are in their own personal financial journey.

Business Consulting Services

Under this program, we will directly assist a client in the sale of their business, or engage other non-affiliated professionals or firms to consult on and assist in providing these services. Clients can also receive business consulting services including, but not limited to, current business operational issues, tax consulting in conjunction with their accountant, and business succession planning.

Fiduciary Acknowledgement

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.

Other Legacy Services

SFA may continue to provide existing Clients legacy services, strategies or programs that are no longer offered to new clients.

Educational and Investment Seminars

From time-to-time SFA may host educational and investment seminars. Although these seminars are available to the public, SFA may tailor each seminar’s focus to a particular type of potential client (i.e. young professionals, retirement plan participants, etc.). Although these seminars are conducted with the aim of identifying new potential clients, SFA may charge a modest fee for attendance. The fees received from these events are used to offset the costs of hosting (i.e. venue charges, materials, food service, etc.).

Retirement Plan Rollovers – No Obligation / Conflict of Interest

A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If we recommend that a client roll over their retirement plan assets into an account to be managed by us, such a recommendation creates a conflict of interest if we will earn a new (or increase our current) advisory fee as a result of the rollover.

Client Service and Client Imposed Restrictions

In performing any of the above services, SFA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. SFA may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if SFA recommends its or its affiliates own services.

Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets not be sold for tax reasons) if, in SFA’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. With respect to SFA’s financial planning and/or consulting services, the client is under no obligation to act upon any of the recommendations made by SFA or to engage the services of any such recommended professional, including SFA itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of SFA’s recommendations.

Clients are advised to promptly notify SFA in writing if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon SFA’s management services.

Family Wealth Services

In addition to the asset management services described above, certain high net worth Clients may also be serviced by our family wealth division, Sequoia Sentinel. Additional services that may be offered to family wealth Clients include:

Aggregation Platforms

SFA may provide its Clients with access to an online platform to allow a Client to view their complete asset allocation, including those assets that SFA does not manage (the “Non-Managed Accounts”). SFA does not provide investment management, monitoring, or implementation services for the Non-Managed Accounts. Therefore, SFA shall not be responsible for the investment performance or data integrity of the Non-Managed Accounts. Rather, the client and/or their advisor(s) that maintain management authority for the Non-Managed Accounts, and not SFA, shall be exclusively responsible for such investment performance. If the aggregation platform also provides access to other types of information and applications, including financial planning concepts and functions, those additional concepts and functions should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by us. Finally, we shall not be held responsible for any adverse results or incorrect information a client may experience if the client engages in financial planning or other functions available on the aggregation platform without SFA’s assistance or oversight.

Selection and Reporting on Other Investment Managers

We also offer our Armada consulting services to clients through our selection and monitoring of other investment managers. The service is generally available only to clients with assets in excess of $10 million.

The process includes developing a written investment policy statement for the client. Then we assist the client with interviewing other investment managers, including illiquid alternative investments (hedge funds, private equity, real assets, etc.). After the investment managers are selected, the assets are invested by our firm and by the other investment managers according to the investment policy statement. Assets would typically be held by 2 or 3 custodians. For reporting purposes, we will aggregate assets held by all investment managers and report on a periodic basis, not less than quarterly.

Trust Support Services

Trustee Support Services are designed with the trustee or trust creator in mind. SFA provides a bundle of services through third party providers to assist a trustee in performing their required duties in a manner consistent with the spirit of the trust while serving all trust stakeholders effectively and efficiently. The bundle of services may include: Fiduciary Consulting, Trust Accounting & Tax Compliance, Investment Management & Advice, Operational Execution and Beneficiary Wealth Planning. SFA does not provide the Trust Accounting & Tax Compliance nor the Operational Execution portion of the bundled services.

Assets Under Management

Please see Section 5 of our Form ADV for details related to our Assets Under Managements (“AUM”)

As of December 31, 2024, SFG has over 22.6 billion in AUM

Our Business Continuity Plan

Our Firm’s business continuity plan is designed to meet the needs of our clients and minimize potential disruption in services during an emergency or disaster. The protocols and capabilities within the plan include:

• Sufficient technical infrastructure and network capacity to support employees working from home in specific areas, or companywide.
• Secure, remote access for all employees
• Videoconference capability in place for employees
• Redundancy capabilities within each of our business units