Ameraudi Asset Management, Inc. (herein after referred to as "Ameraudi", the "Company", "we", "us" and "our") is an investment adviser formed in January, 1999 as a Delaware corporation. Ameraudi is wholly owned by Interaudi Bank, a New York State chartered FDIC bank. George J. Audi is Ameraudi's President and Marlon Orantes is Ameraudi's Chief Compliance Officer.
Our firm assists clients with navigating global financial markets. We provide a macro-perspective on the prevailing economic environment and assist our clients with identifying suitable investment strategies that address their unique investment needs.
Ameraudi offers discretionary/managed and non-discretionary/trading portfolio management services to high net worth individuals. We may also recommend independent third-party money manager(s) to manage client portfolios.
Discretionary/Managed Portfolios - The minimum amount for a managed model portfolio is $1,000,000.
For the managed discretionary portfolio, the adviser will work with the client to determine the investment objectives, risk tolerance, asset allocation goals and time horizon. Clients have the right to place reasonable restrictions.
Non-Discretionary/Trading Portfolios - The minimum amount for a trading portfolio is $1,000,000. Ameraudi offers a full range of investment options on a non-discretionary basis and our investment team has the ability to provide trade ideas and execution. Clients can evaluate specific trade ideas with their financial advisers and may trade individual stocks, bonds, and funds with the assistance of our team.
Third Party Managers - Ameraudi may recommend independent third party managers, when appropriate, to manage all or a portion of a client's assets. Clients are responsible for executing separate investment management agreements with the third party manager. The third party manager manages the client assets on a discretionary basis and is responsible for the implementation of the investment strategy. Although Ameraudi does not oversee the third party manager, we will monitor the activity and performance of our client's accounts and at our discretion may terminate the relationship.
When recommending an independent manager for a client, Ameraudi reviews information about the third party manager, such as their disclosure brochure and/or other material supplied by the third party manager.
Ameraudi tailors advisory services to meet the individual need of the client. In order to determine the appropriate investment strategy, we engage prospects in a pre-advisory consultation in which our advisers will communicate with prospective clients in order to determine the investment objectives, risk tolerance, asset allocation goals and time horizon. In addition to the pre-advisory consultation, we require that the client or prospect themselves or with the assistance of an adviser, complete a risk questionnaire in order to obtain a better analysis of the client's specific needs and investment goals. We utilize this information to generate an Investment Policy Statement for the client to keep for their records.
Clients may impose reasonable investment restrictions, including restrictions on particular securities or types of investments, subject to our agreement. Ameraudi requires that any requests for investment limitations or restrictions be made in writing. Clients should be aware that performance of restricted portfolios may differ from performance of portfolios without such restrictions, which may affect overall returns.
4 Ameraudi reviews our client portfolios though an ongoing process of assessing client objectives, developing an appropriate asset allocation to best achieve those objectives and modifying that allocation when risk/opportunities are presented. Clients should notify Ameraudi if there are changes in their financial situation or investment objectives.
Selection of Other Advisers We may recommend that you use the services of a third party money manager ("TPMM") to manage all, or a portion of, your investment

portfolio. After gathering information about your financial situation and objectives, we may recommend that you engage a specific TPMM or investment program. Factors that we take into consideration when making our recommendation(s) include, but are not limited to, the following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate your assets to other TPMM(s) where we deem such action appropriate.
Sub-Advisory Services to Registered Investment Advisers We offer sub-advisory services to unaffiliated third party money managers (the "Primary Investment Adviser"). As part of these services, we will provide model portfolios, which the Primary Investment Adviser selects for their clients. We manage on both a discretionary and non-discretionary basis. We will not directly manage the Primary Investment Adviser's individual client accounts. The Primary Investment Adviser will be responsible for selecting the appropriate model or investments for its clients.
Types of Investments We primarily offer advice on ETFs. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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); 5
•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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
As of January 31, 2024, Ameraudi managed regulatory assets under management of approximately $1,440,282,033, of which $414,393,287 are assets managed on a discretionary basis and $1,025,888,746 are non-discretionary assets.