Austin Money Management Corporation was formed in May 2018 and has been registered with the U.S. Securities & Exchange Commission as an Investment Adviser since February 2020. The principal Owner, President and Chief Compliance Officer is Steven D. Aycock, CFP®. Mr. Aycock also serves as the single Investment Advisor Representative. Advisory Services Austin Money Management Corporation’s (“AMMC” or “Advisor”) principal service is providing fee-based investment management and consulting services and financial planning services. The Advisor practices custom management of portfolios, on a discretionary or non-discretionary basis according to the client’s objectives. The Advisor’s primary approach is to use an allocation strategy aimed at reducing risk and increasing performance. While AMMC can advise on any investment asset, our recommendations are primarily related to investments in exchange traded funds and mutual funds.
• AMMC measures and selects mutual funds by using various criteria, such as the fund manager’s tenure, and/or overall career performance as well as the diversify the portfolio.
• AMMC uses cash positions as a hedge against adverse market movements and selling certain positions for tax harvesting purposes.
• AMMC will tailor its advisory services to its client’s individual needs based on meetings and conversations with the client.
• If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions with the client to have a clear understanding of the client’s requirements. AMMC offers two fee options. 1. Wrap fee Program Wrap fee programs offer services for one all-inclusive fee, subject to limited exceptions. AMMC sponsors and is the portfolio manager of a wrap fee program held at either National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") or Charles Schwab & Co., Inc. (“Schwab”) herein known as the custodian(s). Both Fidelity and Schwab are independently owned and operated, and have no affiliation with AMMC, and neither acts as a sponsor or portfolio manager of the wrap fee program. 2. Non-Wrap Fee Program Other or the same clients will pay a management fee to AMMC for the advisory services, and separately pay the custodial and securities execution fees directly to the custodian and executing broker-dealer from their brokerage account. The specific fee arrangement will be based on client circumstances and will be defined in the investment advisory agreement between the client and AMMC. A wrap fee program is defined as one where a fee is charged to the account that is not based directly on transactions in the account. The total or “wrapped” fee includes both the investment advisory services and the costs of executing the transactions in the account are “sponsored” by AMMC. Management fees for the wrap fee pricing option are typically slightly higher than management fees where the client pays securities transaction costs separately, to compensate for the estimated costs of trading in the account. The exact fee is negotiable and will generally not exceed the maximum fee described in Item 5. Assets under management are updated at least annually within 90 of the December 31st fiscal year-end. Assets Under Management (03/01/2024) Discretionary $139,067,254 Non-discretionary $74,758,401 Total: $213,825,655 AMMC has approximately an additional $49,144,536 of assets under advisement. Real Estate Investments AMMC can advise on commercial real estate, multi-family developments and land acquisition opportunities that may be appropriate for accredited investors. Such investments may include investing in land zoned for mixed use such as retail shopping, restaurants, schools and universities as well as medical facilities, parks and residential properties. There are various risks to consider such as a lack of public interest and the lack of registration with the SEC or the securities commission of any state or country. In addition, the following, not limited, risks apply:
• Lack of Liquidity
• Zoning Restrictions and Potential Changes
• Lack of Control
• Minimal Transparency
• Changing Economic Conditions affecting Consumer Demand
• Construction Delays due to Costs of Materials or Labor Disputes
• Unexpected Environmental Complications
• Tenants/Residents Ability to make Rent/Mortgage Payments (Risk of Default) Like other Alternative Investments and Limited Partnerships, performance can be volatile. Investments are subject to a complete loss of the principal amount invested with extended time frames before a potential return on capital, if any. In addition, such investments often have concentrated positions that can exaggerate investment risk. Clients with the appropriate risk profile should only consider a portion of their total assets to be help in high risk, volatile positions. Private Equity AMMC can introduce and advise qualified clients on private equity opportunities. Private equity investments involve a higher degree of risk compared to public equity investments due to a lack of registration and disclosure requirements, the potential for operational and managerial challenges as well as market risks, and a potentially high debt position. However, successful private equity investments can yield significant returns for investors. Private equity investments are generally suitable for sophisticated investors with a high risk tolerance, a long- term investment horizon, and the ability to sustain losses up to the entire principal amount invested. Private equity investments are complex and are not suitable for all investors. Investments in private equity are often illiquid, meaning that it can be challenging to sell or exit the investment before the agreed-upon holding period, which is typically several years. This lack of liquidity can tie up capital for an extended period, limiting the investor's ability to react to changing financial needs or market conditions. Pension Consulting Services ERISA 3(21) – Non-Discretionary AMMC will provide research and analysis with regard to investment advice and fiduciary due diligence services for the Client. The goal of the investment due diligence process is to establish a logical, technical, and prudent process that is consistently employed in the selection and ongoing monitoring of funds for plan sponsors and individuals, accompanied by an investment policy statement (for plan sponsors only), that defines the process utilized to recommend prudent investment actions to plan fiduciaries, or their representatives. In providing the investment advice to the Client’s plan the AMMC will follow the investment policy statement and undertake procedural due diligence to arrive upon, or facilitate, prudent investment-related recommendations. However, services provided by the Adviser under this Agreement will not include any services with respect to employer securities, company stock, or the design and monitoring of asset allocation model glide paths or other custom asset allocation management services or solutions, whether available through the Adviser or an affiliate thereof The Advisor acknowledges that it is a fiduciary with respect to the Plan under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974, as amended (ERISA) and, as such, is a co-fiduciary with the plan sponsor fiduciary(ies) of the Client’s Plan solely with respect to: (a) the provision of investment education of the employer and/or plan participants (depending on the specific advisory services provided); (b) the periodic reporting on, and analysis of, the investment options available under the Plan, excluding company stock and investments made available through a brokerage account/window or similar such investment vehicle; and, (c) the provision of advice to the plan sponsor fiduciary(ies) regarding the elimination or addition of investment options available under the Plan; provided, however, that the plan sponsor fiduciary(ies) acknowledge and agree that the plan sponsor fiduciary(ies) have the final and conclusive responsibility for the investment options selected to be available under the Plan. The Adviser will not be responsible for investment decisions made by the Plan participants with respect to the investment of their individual accounts. ERISA 3(38) – Discretionary AMMC can be engaged on a discretionary basis for the selection, mapping, and ongoing monitoring, of investments offered within the Plan sponsored by the Client. Upon agreement, the Client engages the Adviser for management of Plan assets and shall delegate specified authority and discretion to AMMC for the selection, mapping, and ongoing monitoring (including replacement, as prudent), of investments offered within the plan. However, services provided by the AMMC under this Agreement will not include any services with respect to employer securities, company stock, or the design and monitoring of asset allocation model glide paths or other custom asset allocation management services or solutions. AMMC acknowledges that it is a fiduciary with respect to the Plan under Section 3(38) of ERISA and, as such, is a fiduciary to the Client’s Plan solely with respect to the selection, mapping, monitoring, and replacement of plan investment options for which the it has explicit authorized discretionary control. AMMC will not be responsible for investment decisions made by individual Plan participants with respect to the investment of their accounts and/or investment into a model portfolio managed by Adviser, if applicable. Participant Education (Plan and Participant Level) AMMC can assist with developing an education and communication strategy for the Plan’s participants that includes developing a calendar of educational meetings, determining appropriate topics, establishing meeting dates and schedule, prioritizing group versus one-on-one meetings, and so on. AMMC can meet with participants, regularly or as requested, to present information regarding the benefits of Plan participation; the impact of pre-retirement withdrawals on retirement income, investment objectives, and philosophies; and risk/return characteristics. AMMC can provide nonfiduciary

education, but not advice, concerning the availability of withdrawals and rollovers from the Plan at any group meetings held for Plan participants but will not discuss the advisability of withdrawals or rollovers at such meetings. AMMC may provide written general financial information related to investment concepts such as diversification, dollar-cost averaging, estimating future retirement income needs, and assessing risk tolerance. AMMC may furnish investment materials, such as worksheets or questionnaires, which allow participants to estimate future income needs and assess different asset allocation models. Participant Advice (Participant Level) The Adviser can either conduct in-person one-on-one meetings to be coordinated with the Client, or via alternative means of communication (via the telephone, electronically, etc.) as requested by the Client, and each individual participant in the Plan wishing to engage the Adviser for individual investment advice. AMMC can determine the Plan participant’s investment return objectives, risk tolerance, time horizon, and other preferences; recommend a suitable asset allocation model for the participant; and advise the participant to periodically rebalance his or her asset allocation mix to maintain consistency with the asset allocation model. For these services, and only these services described as Investment Advice (Participant Level), the Adviser acknowledges that it will be a fiduciary to the Plan under ERISA section 3(21)(a)(i). Adviser’s fiduciary responsibilities to the Plan, however, will be limited to the advice provided to each individual participant. AMMC does not possess discretionary control and thus will not be responsible for actual investment elections made by the Plan participants if not in accordance with the advice provided. AMMC assumes no other fiduciary responsibilities under this Agreement other than those specifically outlined herein. Investment Management of Model Portfolios (Plan Level) AMMC can manage asset allocation model portfolios (the “Models”) for the Client. Client grants Adviser discretion or non-discretionary authority regarding asset allocation design, investment selection, and weighting of investment options within each of the Models. Discretionary authority is limited to management of the Models and does not apply to any other aspect of the Client’s account or Plan. For these services, and only these services described as Investment Management of Model Portfolios (Plan Level), AMMC acknowledges that it will be a fiduciary to the Plan under ERISA section 3(21)(a)(i) or ERISA section 3(38). The fiduciary responsibilities to the Plan, however, will be limited to the management of the Models. AMMC will not be responsible for investment decisions made by the Plan participants about the investment of their accounts into the Models. AMMC assumes no other fiduciary responsibilities under this Agreement other than those specifically outlined herein. Services Offered Investment Advisor Representatives perform one or more of the following services, as selected by the Client in the client agreement:
• Investment Policy Statement. Advisor Representative will assist the Plan in the preparation or review of an investment policy statement (“IPS”) for the plan based upon consultation with Client
• Ongoing Investment Recommendations. Advisor Representative will recommend, for consideration and selection by Client, specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. Advisor Representative will recommend for consideration and selection by Client, investment replacements if an existing investment is determined by the Client to no longer be suitable as an investment option.
• Ongoing Investment Monitoring. Advisor Representative will perform ongoing monitoring of investment options in relation to the criteria provided by the Client to the Advisor Representative.
• Qualified Default Investment Alternative Assistance. Advisor Representative may assist Client with selecting investment products or managed accounts offered by third parties in connection with the definition of a “Qualified Default Investment Alternative” (“QDIA”) under ERISA (for plans subject to ERISA).
• Non-Discretionary Model Portfolios. Advisor Representative will recommend, for consideration and approval by Client: 1. asset allocation target-date or risk-based model portfolios for the Plan to make available to Plan participants and 2. funds from the line-up of investment options chosen by the Client to include in such model portfolios.
• Performance Reports. Advisor Representative will prepare periodic reports reviewing the performance of all Plan investment options, as well as comparing the performance thereof to benchmarks with Client. The information used to generate the reports will be derived directly from information such as statements provided by Client, investment providers and/or third parties.
• Service Provider Liaison. Advisor Representative shall assist the Plan by acting as a liaison between the Plan and service providers, product sponsors or vendors. In such cases, Advisor Representative shall act only in accordance with instructions from Client or Plan administration matters and shall not exercise judgement or discretion on such matters.
• Education Services to Plan Committee. Advisors Representative will provide training for the members of the Plan Committee with regard to their service on the Committee, including education and consulting with respect to fiduciary responsibilities.
• Participant Education. Advisors Representative will design an education plan and policy statement that may include information about the investment options under eh Plan (e.g. investment objectives, risk/return characteristics and historical performance, investment concepts *e.g. diversification, asset classes and risk and return), the determination of investment time horizons and the assessment of risk tolerance. Such information shall not include specific investment advice about investment options under the Plan as being appropriate for a particular participant.
• Participant Enrollment. Advisors Representative will assist Client in enrolling participants in the Plan, including conducting an agreed-upon number of enrollment meetings. As part of such meetings, Advisor Representative will provide participants with information about the Plan, which may include information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of preretirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan.
• Plan Search Support/Vendor Analysis. Advisor Representatives will assist with the preparation, distribution, and evaluation of Requests for Proposal, finalist interviews and conversion support.
• Benchmarking Services. Advisor Representative will provide Client with comparisons of Plan data (e.g. regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans.
• Assistance Identifying Plan Fees. Advisor Representative will assist Client in identifying the fees and other costs borne by the Plan, as specified by Client, for investment management, recordkeeping, participant education, participant communication and/or other services provided with respect to the Plan. Publicly Traded Employer Stock If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, Representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or obtain participant loans. AMMC does not provide individualized advice or recommendations to the participants regarding such decisions. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan, if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations 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 (ERISA) 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. AMMC also provides educational services pertaining to retirement plan assets that could potentially be rolled- over to an IRA managed by AMMC. Education is based on a particular client’s financial circumstances. AMMC has an incentive to recommend such a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a client’s best interest and acting accordingly. Financial Planning Financial planning is generally incorporated into the larger asset management agreement but it is available as a stand-alone services. The Financial Planning services will be tailored to the specific needs of clients, but generally include recommendations for investment portfolio customization based on investment objectives, goals and financial situation, recommendations relating to investment strategies as well as tailored investment advice. Financial planning can include specific topic advice non-investment issues such as developing strategies to achieve retirement or other financial goals, tax optimization strategies, cash flow and budgeting analysis and recommendations, financing and financial education, estate planning, and asset protection strategies.