____________________________________________________________________________________________________ Overview Alternative Investment Advisors, LLC (hereafter "AIA" or "the Adviser") is an investment advisor registered with the Securities and Exchange Commission ("SEC") pursuant to the Investment Advisers Act of 1940 (the "Advisers Act"). AIA, founded in 1986 and incorporated in New Jersey, is headquartered at 698 N. Maitland Avenue, Suite 101, Maitland, FL. The Adviser also maintains an office at 5002 South Broadband Lane, Suite 100, Sioux Falls, South Dakota. Principal Owners AIA's owners are Thomas W. Hood, Managing Member & Chief Compliance Officer, and Jeffrey M. Skraban, Managing Member, who undertake all of the Adviser's significant strategic and administrative decisions. First Florida Strategies, LLC DBA (“FFS“), an investment-related financial services located in Maitland, FL, is the firm's parent company. (Please refer to each Principal's Form ADV Part 2B Brochure Supplement for additional details on their formal education and business background and Item 10: Other Financial Industry Activities & Affiliations for further information on FFS.) Advisory Business As used in this Brochure, the words "we," "our," or "us" refer to AIA and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. The term "Associates" refers to AIA's Supervised Persons - the firm's Officers and Directors ("Control Persons"), employees, and Investment Professionals - the Investment Advisor Representatives of AIA ("Advisor Representatives” or “IARs"), who are licensed as necessary for their roles and client base, supervised, and approved by AIA to provide investment advice or advisory services on behalf of the Adviser. AIA serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, AIA upholds a duty of loyalty, fairness, and good faith towards each client and seeks to mitigate potential conflicts of interest. In providing investment advice to clients, AIA strives to act with a degree of care, skill, judgment and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use. AIA's advisory services are made available to clients primarily through its Advisor Representatives. Each advisory relationship at AIA is managed by one or more IARs registered with the firm, who serve as the primary point of contact between the firm and the client. IARs are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Advisor Representative can or cannot recommend certain services, investments, or models depending on the licenses or training obtained. They can transact business or respond to inquiries only in the state(s) and locations in which they are appropriately qualified. For more information about the individual providing advisory services, clients should refer to their IARs Form ADV 2B Brochure Supplement, a separate disclosure document offered to the client, along with this Brochure and the AIA's other important Disclosure Documents before or at the time of relationship inception. (If the client did not receive a Form ADV 2B Brochure Supplement, they should contact their IAR or AIA directly.) Non-Exclusive Relationship AIA's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations If requested by the client, AIA can recommend the services of other professionals for implementation purposes, such as accountants, lawyers, and insurance agents. In connection with their approved outside business activities, certain of AIA’s IARs are also Registered Representatives (“RRs”) of APW Capital Inc.(CRD# 43814), a comprehensive asset management and servicing firm, Member FINRA and SIPC, or licensed insurance agents, engaged directly by the client on an as-needed basis. AIA does not receive referral fees for such recommendations, and clients are under no obligation to engage in any suggested professional services. Clients wishing to engage in such services will execute a separate agreement between the client and their selected referred professional(s). Unless disclosed otherwise, AIA is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any referred AIA client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider’s separate contract, including fees and charges and for those charges when assessed, should they choose to engage the referred professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from AIA. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities AIA’s advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their written services contract. IARs will rely upon the accuracy of information furnished by the client or on their behalf without further investigation, and the Adviser is expressly authorized to rely on such information. AIA will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. It is the client’s responsibility to inform AIA promptly of significant changes in their individual or family circumstances or financial situation or in the investment goals or objectives, investment time horizon, tolerance for risk, or liquidity needs of their account so that appropriate changes can be made. Clients will acknowledge and agree to their obligation to promptly notify us in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. Unless the client notifies AIA in writing of material changes in this information, designates a different portfolio for their account, or advises of any other material change to their account, AIA will continue to manage the client’s account according to the suitability information and executed client documents within its records. The client or their successor shall also promptly notify us in writing of the client’s dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their services contract or our authority thereunder. AIA reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of advisory services covered by this Brochure. Because specific terms of a client's Advisory Agreement are negotiable, clients should always refer to their individual Advisory Agreement for terms and Fee Schedules that apply specifically to them. Description of Advisory Services AIA is an investment advisory firm; it does not sell securities on a commission basis. Our IARs emphasize client contact and interaction in providing the following individually tailored investment advice and advisory services:
• Separately Managed Account Program Services (collectively, the "Traditional Program" or “Programs”)
• Financial Planning & Consulting Services
• ERISA, Retirement & Employee Benefit Plan Services
• Third-Party Management Referral Services
• Educational Seminars & Workshop Services Before forming an investment advisor-client relationship, AIA may offer a complimentary general consultation to prospective clients to discuss the nature of its service offerings and determine the possibility of a potential advisory relationship. Investment advisory services begin only after the prospective client and AIA formalize their relationship with a properly executed written advisory agreement. Clients can engage AIA for additional services at any time. (Please refer to Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management style.) AIA's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contract; AIA’s Investment Advisory Agreement (the “Advisory Agreement” or “Agreement”) that discloses, in substance, the scope of service, contract term, Advisory Fee, formula for computing the fee, and type of authority granted to AIA. Final Advisory Fee structures are documented within the written Advisory Agreement. IARs are restricted to providing the services and fees specified within each Advisory Agreement, subject to the client's listed objectives, limitations, and restrictions. Once established, no Investment Advisory Agreement can be assigned - within the meaning of the Advisers Act - by AIA without the client's consent as outlined in the Agreement. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment.) Separately Managed Account Program Services Under AIA’s Separately Managed Account Program Services, we provide portfolio management services, primarily on a discretionary and annual asset-based advisory fee (the “Advisory Fee”), to individuals and non-natural persons through its various Separately Managed Account (“SMA”) Programs (collectively, the “Traditional Programs” or “Programs”). In participating in any of the foregoing Traditional Programs, the client will retain AIA to provide customized asset management services based on their unique investment goals, objectives, and risk tolerance, as described herein. While each Program offers customized portfolio management, each is subject to different minimum investment requirements and fee structures. (For more information, see Item 5 - Fees & Compensation and Item 7: Types of Clients.) AIA will generally meet and work with each client individually to determine the client's portfolio needs and limitations. Clients may be requested to fill out specific questionnaires to better assist their IAR in making such a determination. AIA may also ask clients to provide proof of authority, directed trading letters or qualified purchaser status, or other documents and information to allow us to manage their account(s). Based on the information shared by the client, AIA will recommend an appropriate "base model portfolio" from the following selections: 1. Conservative Allocation Portfolio 2. Diversified Balanced Portfolio 3. Tactical Growth Portfolio Following selecting a base model portfolio, the client’s IAR will further customize the asset allocation and investment strategy to manage the account in a way that comports with the client's particular financial circumstances, goals, and risk tolerance (“Suitability Information”). AIA will continuously implement this customized investment plan, working directly with each client thereafter. AIA does not maintain physical custody of client funds or securities other than the standard business practice of deducting management fees from advisory accounts. According to the client’s Agreement, custody of client assets will be held by AIA’s chosen independent and separate Qualified Custodian. AIA has selected Charles Schwab & Co., Inc. (“Charles Schwab” or “Schwab”), an independent and separate registered broker-dealer, Member of The Financial Industry Regulatory Authority (“FINRA”) and Securities Investor Protection Corporation (“SIPC”), as its preferred Qualified Custodian, who will take possession of the cash, securities, and other assets within the client's account unless the client directs otherwise. (See Item 15: Custody for additional information.) As account goals and objectives will often change over time, suggestions are made and implemented ongoing as the client and IAR review their financial situation and account through regular contact and annual meetings to determine fluctuations in their financial situation or investment objectives, confirm realistic restrictions on account management and verify if the client wishes to modify any existing restrictions reasonably. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable IAR. Financial Planning & Consulting Services AIA offers comprehensive or limited scope Financial Planning & Consulting Services on an hourly or fixed-fee basis. Services can range from broad-based financial planning to consultative or single-subject planning and/or guidance and may encompass, but is not limited to, some or all of the following issues, as may be requested by the client:
• Asset Allocation
• Business Planning
• Cash Flow Forecasting
• Charitable Giving
• Distribution Planning
• Educational Funding
• Estate Planning
• Financial & Cash Management Issues
• Financial Issues Relating Marital Issues or Divorce
• Financial Reporting
• Insurance Needs Analysis
• Investment Consulting, Planning & Asset Allocation
• Investment Goal Setting
• Retirement Planning
• Retirement Plan Analysis
• Risk Management
• Taxation Issues To participate in any of the above options, clients will execute a Financial Planning & Consulting Services Advisory Agreement (the “Financial Planning & Consulting Agreement”) setting forth the terms and conditions of the engagement, including termination, describing the services' scope and Advisory Fees due before AIA commences services. Final fee structures are documented within the executed contract, including whether any written report or electronic or online financial plan will be provided. (See Item 5 - Fees & Compensation for more information.) Neither AIA nor the client’s IAR will have discretionary investment authority when offering Financial Planning & Consulting Services. Scope of Financial Planning & Consulting Services Financial Planning & Consulting Services generally include evaluating the client's overall investments and financial situation to develop a financial plan and/or provide potential solutions. Through a series of personal interviews and/or questionnaires, AIA will collect pertinent data to identify the client's goals, objectives, risk tolerance, investment time horizon, and prospective financial problems and discuss any consulting needs, among other critical factors. Clients may be asked to provide detailed information about their personal and family situation, estate and retirement plans, trust agreements, wills, investments, insurance, or other information necessary to deliver the specific services requested. Based on the information provided by the client, the IAR will develop recommendations to help the client strive to achieve their investment objectives and/or address the topic(s) of discussion. Financial plans are based on the client's financial situation when the plan is presented according to the financial information disclosed by the client to AIA at the time of the Financial Planning & Consulting Services Agreement execution. Financial plans typically do not include information or analysis concerning liability risks, tax planning, or tax preparation services. If such services are necessary, the client shall be responsible for obtaining them from one or more third parties. All Financial Planning Services provided are expected to be completed within six (6) months of the acceptance date of a Financial Planning & Consulting Services Agreement or as may otherwise be specified in the contract, assuming the client timely provides the information needed to complete the planning analysis and recommendations. Subject to our discretion, clients may receive this service at no extra charge. If services are not delivered within six months, any unearned revenue is pro-rated and refunded to the client following the terms and conditions of the executed contract. Consulting services are provided as needed. Since financial planning is a discovery process, situations occur wherein the client is unaware of specific financial exposures or predicaments. If the client's case differs substantially from what was disclosed at the initial meeting, a revised Advisory Fee will be provided for review and acceptance. When an Advisory Fee increase is necessary, the client must approve and agree to the scope change before any additional work is performed. In such cases, we will notify the client to obtain this approval. Further reviews may be conducted upon request, and written updates to the financial plan may be provided in conjunction with the review. Any subsequent Financial Planning & Consulting Services require the execution of a new contract, and updates to financial plans may be subject to our then-current hourly rate, which the client must approve in writing before any additional services commence. (See Item 5: Fees & Compensation for further information.) As with all AIA advisory services, the client is expected to promptly notify us in writing of any material changes in assets, net worth, indebtedness, or planning objectives that AIA would not otherwise know. The client or their successor shall also promptly notify us in writing of the dissolution, termination, merger, or bankruptcy of the client if the client is other than a natural person and occurrence of any other event that might affect the validity of their executed Financial Planning & Consulting Services Agreement or AIA’s authority thereunder. AIA reserves the right to terminate any financial planning or consulting engagement where a client has willfully concealed or has refused to provide pertinent information about financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. Clients should consult their Financial Planning & Consulting Services Agreement for complete details. Financial planning and consulting assistance may be the only service provided to the client. Executing a Financial Planning & Consulting Services Agreement neither constitutes an agreement for nor requires that the client use or purchase investment advisory or other services offered by AIA, or any insurance or other products or services provided by an AIA IAR as a result of any business activities in which they may participate outside their advisory activities with AIA. This service does not include implementing or monitoring AIA’s recommendations to the client. Clients are not obligated to act on any AIA financial planning or consultation recommendations or implement any financial plan or recommendation through our firm. Clients may act on recommendations by placing securities transactions with any brokerage or firm they choose. ERISA, Retirement & Employee Benefit Plan Services AIA provides ERISA, Retirement & Employee Benefit Plan Services, investment due diligence, education, and other advisory services to clients with employee benefit plans or other retirement accounts (i.e., IRAs) for a level fee. As part of our investment advisory services, we may recommend that clients withdraw the assets from their employer's retirement plan and roll them over to an individual retirement account (IRA) we will manage on their behalf. If clients elect to roll the assets to an IRA subject to our management, AIA will charge them an asset-based Advisory Fee as outlined in the client's Agreement with our

firm. In this capacity, AIA is considered a fiduciary under the Employee Retirement Income and Securities Act ("ERISA") and regulations under the Internal Revenue Code of 1986, and it must abide by the Impartial Conduct Standards as defined by ERISA. (See Item 5: Fees & Compensation for further information.) In connection with such services, for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, clients should be aware of the following: When we provide investment advice to you regarding your retirement plan 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 laws governing retirement accounts. How we are compensated conflicts with your interests, so AIA operates under a special rule requiring 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 provide 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. AIA benefits financially from the rollover of a client’s assets from a retirement account to an account we manage or provide investment advice for because the assets increase our assets under management and, in turn, our Advisory Fees. AIA’s policy as a fiduciary is only to recommend a client rollover retirement assets if we believe it is in the client's best interest. If clients elect to roll their retirement assets to an IRA subject to our management, they will be charged an Advisory Fee as outlined in the Agreement they executed with our firm. Clients are not contractually or otherwise under any obligation to complete a rollover. If they elect to complete a rollover, they are not obligated to have their retirement assets managed by AIA. Finally, we will receive no compensation if a client or a prospective client receives a recommendation to leave their plan assets with their old employer. When establishing ERISA accounts, AIA will have plan fiduciaries for discretionary accounts, evidence of their authority to retain our advisory services and appoint us as an "investment manager" within Section 3(38) of ERISA for those plan assets that comprise the client's account. They will confirm that the services described in AIA's Agreement are consistent with plan documents and furnish accurate and complete copies of all records that establish and govern the plan. If an established plan account contains only partial plan assets, as ERISA requires, the client will acknowledge that AIA has no responsibility for the overall diversification of all the plan's investments and no duty, responsibility, or liability for any partial plan asset not under advisement. If ERISA or other applicable law requires bonding for the account's assets, AIA will ensure bonding is in place to satisfy the obligation to cover AIA and all Associates whose inclusion is expected by law. Plan fiduciaries will promptly agree to provide appropriate documents evidencing such coverage upon request. IRA Rollover Considerations In determining whether to make an IRA rollover to AIA, clients must understand the differences between accounts to decide whether a rollover is best for them. Many employers permit former employees to maintain their retirement assets in their company plans. Further, current employees can sometimes move assets from their company plan before retiring or changing jobs. There are various factors AIA will consider before recommending retirement plan rollovers, including but not limited to the investment options available in the plan versus the other investment options available, plan fees and expenses versus those of alternative account types, the services and responsiveness of the plan's investment professionals versus those of AIA, required minimum distributions and age considerations, and employer stock tax consequences if any. To the extent the following options are available, clients should carefully consider the costs and benefits: 1. leaving the funds in the employer's/former employer's plan, 2. moving the funds to a new employer's retirement plan, 3. cashing out and taking a taxable distribution from the plan, and 4. rolling the funds into an IRA rollover account. Each of the above options has advantages and disadvantages. If you contemplate rolling over retirement funds to an IRA for us to manage, we encourage you to speak with your CPA or tax attorney before making a change. The following are additional points for consideration before making any changes: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might wish to consider other investment types: - Employer retirement plans generally have a more limited investment menu than IRAs. - Employer retirement plans may have unique investment options not available to the public, such as employer securities or previously closed funds. 2. Consider plan fees - your current plan may have lower fees than AIA’s fees: - If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. - You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. 3. Our strategy may have a higher risk than your plan's option(s). 4. Your current plan may also offer financial advice. 5. If you keep your assets in a 401(k) or retirement account, you could potentially delay your required minimum distribution beyond age 72. 6. Your 401(k) may offer more liability protection than a rollover IRA; each state may vary. - Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have mainly been protected from creditors in bankruptcies. However, there can be some exceptions to the usual rules, so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401(k), but not from an IRA. 8. IRA assets can be accessed anytime; however, distributions are subject to ordinary income tax and may be subject to a 10% early distribution penalty unless they qualify for an exception, such as disability, higher education expenses, or a home purchase. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire AIA as the manager and keep the assets in the plan name. Selection of Other Advisers -Third-Party Management Referral Services AIA retains the ability to offer Third-Party Management Referral Services to clients, where IARs will, after appropriate due diligence, select or recommend independent and separate account managers, licensed investment advisers, or third-party program providers (collectively each referred third-party manager a “TPM”) to administer their clients' accounts. For this advisory service option, AIA acts in a Promoter capacity, and the clients are the potential investors it introduces to each referred TPM, who may decide to open an account, invest with the referred TPM, and become the referred manager's client. AIA will only refer clients to investment advisers registered with the U.S. Securities and Exchange Commission (“SEC”) or the applicable state(s). AIA will refer only to those individuals or entities suitable for the services. The client maintains sole discretion when engaging any recommended third-party advisers. Clients are never obligated to use the above or any additional recommended TPM the Adviser may engage in the future under this service. AIA primarily recommends the following TPM to clients: City National Rochdale, LLC (CRD # 117198) AIA does not maintain the authority to accept any client on behalf of any referred manager, and referred TPMs are not responsible for accepting any prospective investor (and possible future client) referred to them by AIA. Each manager has the right to reject any referred client for any reason or no reason at all. AIA's role is to verify that clients are appropriate to become TPM clients, determine if the potential referred client has assets to invest, and confirm they have a minimum understanding of financial investing. AIA will then facilitate referred manager client portfolio management by assisting clients in selecting the managers and allocation models believed suitable for their unique needs. AIA will help clients understand the referred manager's Investment Management Agreement ("IMA") and help them complete their client profile and suitability information to help the manager determine the appropriate allocation strategy for the account. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending the relationship receives an economic benefit, as the payment received could incentivize the referral. AIA will receive revenue from any fees paid when acting in this capacity. AIA’s Advisory Fees are charged in addition to each referred manager's fee. AIA’s portion of the total management fee represents the maximum fee AIA may earn under the Third Party Management Referral Services Program. Shared fees will not exceed the limits imposed by any regulatory agency. Clients and potential clients will receive full disclosure of the above information and the nature of the relationship at the time of referral via receipt of AIA's Form ADV Part 2A Brochure, a copy of their IAR’s Form ADV Part 2B Brochure Supplement, our Privacy Notice, a brochure describing AIA's relationship and referral compensation arrangement with the TPM to which the client is referred, material conflicts of interest arising from the relationship/compensation arrangement, and all other relevant disclosure brochures and material terms of the arrangement, to provide pertinent disclosures. All documents will be supplied before or after receipt of AIA's Advisory Agreement, and clients will sign an acknowledgment, which will be returned to the referred manager confirming their receipt of the material operative documentation, disclosures detailing the nature of the relationship, compensation to AIA, and other general terms of the referred services. Clients are encouraged to read and understand all disclosure documents. As AIA and the referred manager have different roles and provide separate services, clients will execute two contracts to participate in this advisory service: 1. The client will sign AIA’s standard Advisory Agreement and an additional Selection& Monitoring of Third-Party Adviser Addendum (“Addendum”) to the written standard Agreement they execute with us to outline the services provided to the client by AIA and the fees associated with those services. The Addendum will allow their IAR to monitor the performance of the TPM on the client’s behalf, and AIA shall maintain its relationship with the client by monitoring the status of the portion of the assets managed by the referred manager, meeting with the client periodically, and acting as the client's Advisor. 2. The client will sign a second, separate IMA with the referred manager detailing the TPM’s services, fees, and other paperwork or arrangements as necessary. Specific account management and implementation will be documented within and depend on the client's arrangements with the referred TPM, as dictated by their investment profile, account management authority granted for the referred account (discretionary or non-discretionary) and the type of IMA they enter into with each manager, which is then used to select a portfolio intended to match their investment plan. Under this arrangement, the TPM will be responsible for primary ongoing client account supervision and rebalancing and/or asset reallocation of the client’s assets amongst different security types chosen to strive to achieve the client’s specific objective within the context of each client's stated investment goals and guidelines, to maintain the client’s model allocation selections. The portfolio management, best execution, portfolio reporting, trading, trade error resolution, and custodian reconciliations for the portion of the client's assets become the responsibility of the TPM. Custody of client assets will be held with the TPM's independent and separate Qualified Custodian, who will take possession of the cash, securities, and other assets within the client's portfolio account and buy and sell securities upon the referred manager’s instructions, as indicated in each client’s written IMA. Unless the client directs otherwise, the client will enter a separate agreement between the client and the TPM’s selected custodian to establish the TPM custodial account. City National Rochdale has selected Pershing LLC, an SEC-registered broker-dealer and member of FINRA and SIPC, to act as its preferred custodian and clearing broker. AIA will neither access the assets nor the income produced from the client's TPM custodial account nor have physical custody of the client's funds or securities. The client is responsible for all expenses billed by the custodian. AIA is not responsible for any acts or omissions of the referred manager or custodian, any fees, charges, or other costs related to the client's referred account, the client's payment of required brokerage or custodial charges/fees, or for ensuring custodian compliance with the terms of the client's brokerage account. In selecting a referred manager, the client is responsible for understanding the fee agreement they are executing with the TPM. Clients should consult the referred manager's IMA for details concerning TPM fee disclosures, account discretion, custody, account investments, and management. According to Agreement provisions, either party's written notice may terminate the agreement between the Adviser and the Third-Party Adviser. Educational Seminars & Workshop Services AIA provides complimentary investment Educational Seminars & Workshop Services and can speak at community events and conferences on various investment topics on an "as-announced" basis for groups seeking general instruction on investments and other personal finance areas. Seminar and workshop content will vary depending upon the attendees' needs and are purely educational – they do not involve selling any investment products. The information presented will not be based on any individual’s needs. AIA does not provide personalized investment advice to attendees during such events. AIA will only provide investment advice if engaged independently and only where the attendee's individualized financial information, investment goals, and objectives are known. Any materials provided are for general educational purposes and do not deliver specific accounting, investment, legal, tax, or professional advice. Attendees have no obligation to schedule a consultation, purchase services from AIA, or become clients. Client-Tailored Advisory Services AIA offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at AIA’s discretion, as detailed herein and defined in each client's written IAA. (For more information, see Item 5: Fees & Compensation.) Client Imposed Restrictions Clients can, at any time, impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to AIA in writing. Clients can also amend/change such limitations by providing written instructions. Reasonable efforts are made to comply with client investment guidelines, including any client's reasonable limits by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similar account without restrictions. It is important to note that client-imposed restrictions within their account and variations could result in positive or negative performance differences for the account compared to accounts without such limits. The restrictions can also potentially prevent achieving a client's specific goals. Upon receiving a client's written restrictions, AIA will discuss the restriction request's feasibility to confirm expectations are met and verify the client's acknowledgment and understanding of the imposed restriction's possible outcomes. AIA reserves the right to reject client- imposed restrictions or end the client relationship. Client-imposed limits will not be effective unless acknowledged/accepted by AIA in writing. Regardless of the advisory service provided, AIA is not obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Types of Investments AIA will work with the client to build what it deems an appropriate portfolio under AIA's management by utilizing securities that are part of the client's account, managing across multiple accounts where applicable and managing the client's portfolio to aim to meet the client's specific distribution needs and tax goals. AIA intends to provide its clients with investment advisory and portfolio management services regarding securities only. The assets traded within allocation models primarily consist of exchange-traded funds (“ETFs”) and options but may include, without limitation, a mix of securities such as mutual funds, equities, and bonds. Frequently, AIA will work alongside and with the client's other financial advisor(s) to provide an investment experience that complements the client's overall investment picture. Where appropriate, AIA may also recommend to clients of the Traditional Programs that certain independent third-party investment advisors be engaged to manage all or a portion of the client's assets. Although AIA provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives and will use other securities to help diversify a portfolio when appropriate. Before acting on any analysis, advice, or recommendation, AIA recommends prospective investors consult with their legal counsel, tax, and other financial investment professionals, as necessary, to aid in due diligence as proper for their situation and determine the suitability of the risk associated with any investment. (For additional information on investment considerations, see Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Wrap Program A Wrap Fee Program differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset- based Advisory Fee (the "Program Fee" or "Wrap Fee") regardless of the number of trades completed by a client. AIA does not offer a Wrap Fee Program as part of its advisory services. Conflicts of Interest Clients should know that the specific advisory services selected and the compensation to AIA and their IAR will differ according to the chosen service. The compensation we receive can be greater than the amounts otherwise received had the client participated in another service or paid separately for investment advice, brokerage, or other relevant services. Due to the differences in fee schedules among the various advisory Programs and services offered by AIA and the client’s IAR, a conflict of interest exists when there is a financial incentive to recommend a particular service over others. Clients are not obligated to act upon any recommendations or purchase products or services. If they elect to act on any recommendation received, they are not obligated to place the transaction through AIA or any recommended third party. The client can act on recommendations received by placing their business and securities transactions with any brokerage. AIA does not represent that the products or services offered are at the lowest available cost - clients could obtain the same or similar products or services at a lower price from other providers. AIA has adopted and implemented compliance policies and procedures and a Code of Ethics (“Code”) to mitigate conflicts of interest. AIA’s Code is available for review free of charge to any client or prospective client upon request. Assets Under Management As of December 31, 2023, our client assets under management total $296,441,242. The following represents assets under management by account type: Type of Account Assets Under Management Discretionary $ 266,475,156 Non-Discretionary $ 29,966,086 Total $ 296,441,242