This Firm Brochure, dated 9/9/2015, provides you with a summary of MarketAlly LCC's advisory services and fees, professionals, certain business practices and policies, as well as actual or potential conflicts of interest, among other things. This Item is used to provide our clients with a summary of new and/or updated information; we will inform of the revision(s) based on the nature of the information as follows.

1. Annual Update: We are required to update certain information at least annually, within 90 days of our firm’s fiscal year end (FYE) of October 31. We will provide you with either a summary of the revised information with an offer to deliver the full revised Brochure within 120 days of our FYE or we will provide you with our revised Brochure that will include a summary of those changes in this Item.

2. Material Changes: Should a material change in our operations occur, depending on its nature, we will promptly communicate this change to clients (and it will be summarized in this Item). "Material changes" requiring prompt notification will include changes of ownership or control; location; disciplinary proceedings; significant changes to our advisory services or advisory affiliates – any information that is critical to a client’s full understanding of who we are, how to find us, and how we do business.

MarketAlly presently does not offer advisory services while we pivot new service offerings compared to the information previously provided in our Firm Brochure to date.


MarketAlly LLC. is a registered investment adviser with its principal place of business located in Bradenton, Florida. MarketAlly LLC. provides investment services to individuals, families and businesses. The firm's principal shareholders are listed below. (i.e., those individuals and/or entities controlling 25% or more of the company).

• David H. Friedel, Jr.

Types of Advisory Services

MarketAlly presently does not offer any advisory services while we pivot our new product lines.



Presently we are not collecting fees while we pivot our product line to support new services.


MarketAlly LLC provides advisory services to the following types of clients:

• Individuals (other than high net worth individuals)

• High net worth individuals

• Pension and profit sharing plans (other than plan participants)

• Charitable organizations



Methods of Analysis

We use the following methods of analysis in formulating our investment advice for our newsletter but only employ the technical analysis for our automated trading services:

Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).

Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the vehicle.

Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. We use this specifically for certain asset classes to allow algorithms to make tactical allocation changes to our portfolios.

Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. An additional risk with using technical analysis for tactical allocation changes is that the allocation change may not produce the desired result due to unanticipated market movements.

Investment Strategies

Our primary strategy is allowing our algorithms to make adjustments as needed to maximize reward and minimize risk.  This may at times result in short term holdings while other times be long term in nature.  As our automated trading platform manages these decisions, the drawdowns are designed to be short in nature which means if markets are choppy the time horizons will be short and vice versa.


We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management.

Neither our firm nor our management personnel have reportable disciplinary events to disclose.


MarketAlly LLC endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict:

  • we disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees;
  • we disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies;
  • we collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance;
  • our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances;
  • we require that our employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed;
  • we periodically monitor these outside employment activities to verify that any conflicts of interest continue to be properly addressed by our firm; and
  • we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients.


Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws.

MarketAlly LLC and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code.

Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts.

Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security (ies) which may also be recommended to a client.

As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest:

  1.     No principal or employee of our firm may put his or her own interest above the interest of an advisory client.
  2.     No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public.
  3.     It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts.
  4.     Our firm requires prior approval for any IPO or private placement investments by related persons of the firm.
  5.     It is our firm’s policy not to engage in agency cross trades or principal trades.
  6.     We have established procedures for the maintenance of all required books and records.
  7.     All clients are fully informed that related persons may receive separate commission compensation when effecting transactions during the implementation process.
  8.     Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority which we do not engage in.
  9.     All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices.

10.  We require delivery and acknowledgement of these Code of Ethics by each supervised person of our firm.

11.  We have established policies requiring the reporting of Code of Ethics violations to our senior management.

12.  Any individual who violates any of the above restrictions may be subject to termination.


It is MarketAlly's policy not to accept or allow our related persons to accept any form of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the advisory services we provide to our clients.


The custody rule under the Investment Advisers Act of 1940 defines custody as "holding, directly or indirectly, client funds or securities, or having any authority to obtain possession of them." Any arrangement or capacity that authorizes or permits the adviser or a related person of the adviser to withdraw client funds or securities, e.g. a general power of attorney or serving as trustee on a client's trust constitutes custody for advisers.

MarketAlly LLC does not have custody of any client’s funds.


Under no circumstances do we require or solicit payment of fees in excess of $500 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement.

MarketAlly LLC. has never been the subject of a bankruptcy petition.