A. Description of the Advisory Firm
• Astoria Portfolio Advisors LLC. (hereinafter “APA” or “Astoria”) is a Limited Liability Company
founded in April 2017 and organized in the State of New York. APA is an independently owned
LLC. The majority of APA’s business involves providing investment management services and
support to a variety of clients including registered investment advisors, high net worth individuals,
corporations, turnkey asset management platforms, and other financial institutions (hereinafter
referred to as “clients”). APA is a sub-advisor for the AXS Astoria Inflation Sensitive ETF (Ticker is
PPI) and the Astoria US Quality Kings ETF (Ticker is ROE).
• APA’s core business model is providing a comprehensive range of investment management services
to small and mid-sized RIAs. As this demographic of RIAs typically does not have an internal
investment management team, our services constitute what is typically referred to as Outsourced
Chief Investment Officer (OCIO) services. Our four main vectors of service are:
o Investment strategies: Astoria manages a range of ETF managed portfolios, quantitative
equity portfolios, and customized multi-asset portfolios.
o Portfolio construction: In addition to allocating their client’s assets to our myriad core
strategies, Astoria works continuously with our RIA clients in the construction and
management of customized investment portfolios.
o Research: Astoria provides a robust amount of research products to our RIA clients which
include market commentaries and a quarterly market review. Additionally, we are
contributing editors at multiple media affiliates.
o Sub-Advisory services: As a sub-advisor at the custodians Charles Schwab, TD Ameritrade,
Wells Fargo, and Fidelity, Astoria physically manages our RIA client’s investment accounts
providing a full suite of operational and trading services.
• Astoria has two core methods of delivery for our services to RIA clients:
o Model Delivery: In the instance of model delivery (AUA) Astoria does not physically ‘touch
client accounts’ by managing our client’s investments at a custodian. We provide these
customers with allocations to our investment models along with continuous updates on all
model changes. We work with the advisor on the appropriate set model or customized
portfolios. We provide continuous and ongoing investment management and portfolio
research services to these clients on a direct and reverse inquiry basis for the entirety of
their investable assets. Hence, we do not have discretion on these assets, so these are
considered Assets Under Advisement (AUA).
o Physical Sub-Advisory: In the instance of physical sub-advisory at a custodian (AUM), our
full range of contractual services is the same as model delivery, only we ‘touch client
accounts’ by physically managing our client’s portfolios via trading and operational services
at our mutual custodian. These accounts are where we have complete discretion and are
considered Assets Under Management (AUM).
o While Astoria’s core business model is providing our full range of investment services to
small and mid-sized RIAs, Astoria does manage a small amount of individual client assets
with no RIA intermediaries.
APA’s research-driven portfolios are structured using a variety of macro-economic, quantitative,
and portfolio construction tools. APA has manufactured institutional caliber investment strategies
utilizing the benefits of the ETF product (liquidity, tax efficiency, diversification, and
transparency). APA applies its quantitative portfolio construction background to additionally
create thematic stock portfolio which are largely quantitative and systematic in nature.
•
APA’s investment management process is a constant feedback loop between research, portfolio
construction, and risk management. Investment decisions are made using strong economic and
quantitative rationale backed by data. APA employs ongoing research assessment of these models
to manage its investment processes and outcomes.
• Effective 12/30/2021, APA became the sub-advisor for the AXS Astoria Inflation Sensitive ETF
(Ticker is PPI). The ETF is an actively managed strategy that seeks to achieve its investment
objective by investing principally in securities across multiple assets classes which have the
potential to benefit, either directly or indirectly, from increases in the rate of rising costs of goods
and services (i.e., inflation). More details about APA’s role as a sub-advisor to PPI can be found in
the Sub-Advisory section below.
• Effective 8/1/2023, APA became the sub-advisor for the Astoria US Quality Kings ETF (Ticker is
ROE). The Astoria US Quality Kings ETF is an actively managed fund that seeks long-term capital
appreciation by investing in 100 high-quality US large-cap and mid-cap stocks, equally weighted
and sector optimized. The fund allocates equal weights to the components to mitigate the
potential issues associated with market cap-weighted indices. It is sector-optimized, screening
for and selecting the highest quality stocks in each respective sector in their weight, as they exist
in the S&P 500. More details about APA’s role as a sub-advisor to ROE can be found in the Sub-
Advisory section below.
•
APA’s Founder, CEO, and CIO, John Davi, is an award-winning research strategist and portfolio
manager with over two decades of experience spanning across Macro ETF Strategy, Quantitative
Research, and Portfolio Construction. John was Head of Morgan Stanley’s Institutional ETF
Content where he produced hundreds of reports over an 8-year period. While working for
Morgan Stanley, John advised many of the world’s largest Hedge Funds, Asset Managers,
Pensions, and Endowments. John’s ETF content was top-ranked twice by Institutional Investor
magazine between 2009 through 2017. John began his career in 2000 doing research on ETFs in
Merrill Lynch’s Global Equity Derivatives Research group. During his tenure in research, John
produced several hundred reports on ETFs, Futures, Options, & Indices. John was part of a team
from 2000 to 2008 that was ranked top 3 by Institutional Investor magazine in 6 of his 8 years.
John structured ETF portfolio solutions as early as 2002 for Merrill Lynch’s client base where
several billion in assets were raised and executed. John’s research has been recognized and
featured on ETF.com, ETFTrends.com, InsideETFs, Institutional Investor Magazine, and he is a
regular contributor to CNBC, Bloomberg, and other media outlets. He was recognized by
Bloomberg as an “ETF Master Chef” and by CNBC as an “ETF expert”.
•
David Clark is President and Head of Business Development for Astoria Portfolio Advisors LLC. He
has more than 25 years of experience in the financial services industry. David spent the first 18
years of his career at Merrill Lynch (subsequently Bank of America), holding various institutional
sales management and business development leadership roles in London and New York. David
was Head of Merrill’s European Convertible Bond, Equity Derivative, ETF and Delta One sales, and
sat on the firm’s European Markets Operating Committee. He also served as Head of Bank of
America’s Americas International Derivative and Swap sales. Additionally, David was Head of
Americas Global Delta One, ETF, Stock Loan Distribution and Product, and a member of the North
American Equity Sales Operating Committee. He later spent six years at Société Générale, where
he was head of U.S. Sales for Global Securities Financing, overseeing distribution of ETF, Swap and
Structured Financing products. David graduated from Villanova University with a Bachelor of Arts
degree in Economics and currently sits on the school’s President’s Advisory Council. He lives in
Madison, New Jersey with his wife and three children.
• Bruce Lavine is a Senior Strategy Advisor of Astoria Portfolio Advisors LLC. Bruce has a long history
in the ETF and asset management business beginning with Barclays Global Investors over 20 years
ago. He was one of the earliest employees at iShares and had roles including CFO, Head of Product
Development and CEO of iShares Europe. In 2006, Bruce joined WisdomTree as President and
Chief Operating Officer. He was there for 10 years as an employee and remains active with
WisdomTree today as a member of their Board of Directors. Most recently, Bruce was the CEO of
55 Capital. Bruce has an MBA and BS both from the University of Virginia and he is a Chartered
Financial Analyst (CFA).
B. Types of Advisory Services
Portfolio Management Services
• APA manages investment portfolios for a variety of clients including registered investment
advisors, high net worth individuals, corporations, turnkey asset management platforms, and
other financial institutions.
• APA will create a portfolio designed to target the advisor and its end client's investment policy
goals and risk tolerance. APA will allocate the client's assets among various investments taking
into consideration the overall management style and risk tolerance selected by the client. APA’s
ETF portfolios consists primarily of passive, market-capitalization weighted, factor-based
(sometimes referred to as Strategic or Smart Beta), commodity, liquid alternative, and actively
managed funds. Additionally, APA has developed a suite of thematic stock portfolios which are
quantitively driven and systematic in nature. APA also offers ESG solutions for investors who
desire such outcomes. APA may also hold or supervise actively managed or passive mutual funds,
individual stocks, and bonds, non-listed REITs, as well as options, typically resulting from pre-
existing client holdings prior to becoming an APA client.
• APA manages portfolios on a discretionary and non-discretionary basis. APA does its own internal
macro-economic and quantitative research and leverages these capabilities to design portfolios
for investors. At times, individuals from outside of APA may join the firm’s investment committee
meetings strictly for the purpose of participating in a group setting discussion on larger macro-
economic and investment themes that are currently and prospectively underway. These
individuals are in no way functionally involved, with all matters as it pertains to the business,
investment, and operational endeavors of APA.
• APA offers its services primarily through other registered financial service intermediaries. APA
offers ongoing investment management services based on the client’s goals, objectives, time
horizon, and risk tolerance level. APA works closely with these financial service intermediaries to
create an agreed-upon Investment Policy Statement, which generally outlines the client’s financial
wealth being and risk tolerance levels. Using the parameters set forth in the Investment Policy
Statement, APA will then construct a plan to aid in the selection of a portfolio that matches each
client's specific situation. Investment management services include, but are not limited to, the
following:
o Investment strategy
o Investment policy statement
o Asset allocation
o Asset selection
o Risk tolerance
o Portfolio management and rebalancing
• APA regularly evaluates the current investments of each client with respect to their agreed upon
investment strategy, risk tolerance level, and time horizon. APA will request discretionary
authority from clients in order to select securities and execute transactions without permission
from the client prior to each transaction. There may be at times instances where APA does not
have discretion and may simply provide an ETF or stock portfolio, portfolio construction analytics,
and other investment advisory services to the client. Risk tolerance levels are documented in the
Investment Policy Statement.
• APA seeks to provide investment decisions that are made in accordance with the fiduciary duties
owed to its accounts and without consideration of APA’s economic, investment or other financial
interests. To meet its fiduciary obligations, APA attempts to avoid, among other things,
investment or trading practices that systematically advantage or disadvantage certain client
portfolios, and accordingly, APA’s policy is to seek fair and equitable allocation of investment
opportunities & transactions among its clients to avoid favoring one client over another over time.
It is APA’s policy to allocate investment opportunities and transactions it identifies as being
appropriate and prudent among its clients on a fair and equitable basis over time.
Sub-advisor Services
• APA serves as a sub-advisor to the AXS Astoria Inflation Sensitive ETF (Ticker is PPI). The ETF is an
actively managed strategy that seeks to achieve its investment objective by investing principally
in securities across multiple assets classes which have the potential to benefit, either directly or
indirectly, from increases in the rate of rising costs of goods and services (i.e., inflation). These
investments are expected to include, but are not limited to, equity securities of companies
engaged in the energy, financials, industrial, and materials sectors, as well as investments in other
ETFs that directly or indirectly invest in commodities and fixed income securities. The fund invests
in both domestic and international stocks.
• APA serves as a sub-advisor to the Astoria US Quality Kings ETF (Ticker is ROE). The Astoria US
Quality Kings ETF is an actively managed Exchange Traded Fund (ETF) that seeks long-term capital
appreciation by investing in 100 high-quality US large-cap and mid-cap stocks, equally weighted
and sector optimized. The fund allocates equal weights to the components to mitigate the
potential issues associated with market cap-weighted indices. It is sector-optimized, screening
for and selecting the highest quality stocks in each respective sector in their weight, as they exist
in the S&P 500.
• John Davi is the Portfolio Manager for PPI and ROE.
• APA may also act as a sub-advisor to advisers unaffiliated with APA. These third-party advisers
would outsource portfolio management services to APA. This relationship will be memorialized
in each contract between APA and the third-party adviser.
Model Licensing
• APA offers non-discretionary investment advisory services to unaffiliated investment advisers.
These licensing activities include the creation and maintenance of investment models. These
models and subsequent model changes are communicated as recommended allocations or
changes to the advisory firms that license the models. APA provides these recommendations on
a non-discretionary basis. APA is not responsible for enacting or making discretionary trades in
client accounts with respect to its model licensing activities. Investment adviser firms that license
these models from APA are responsible for any discretionary activities with respect to assets they
manage according to the models. APA’s compensation for these activities is subject to the terms
of a model licensing or a management agreement that is agreed upon with the advisory firm
utilizing these services.
Outsourced Chief Investment Officer Services
• APA serves as an Outsourced Chief Investment Officer to select clients. In these instances, APA
will deliver bespoke investment management solutions, provide consultative services, fund and
portfolio construction analytics, model portfolios, and portfolio optimization work in exchange
for a fixed dollar amount fee or as a percentage of assets under management.
Services Limited to Specific Types of Investments
• APA generally limits its investment advice to stocks as well as ETFs across the equity, fixed income,
commodity, and liquid alternatives space. As mentioned previously, APA’s portfolios may include
individual equity securities, mutual funds, non-listed REITs, bonds, options, or CDs, typically
resulting from pre-existing client holdings prior to becoming an APA client. In these instances,
APA will provide guidance on the optimal transition strategy keeping in mind the client’s stated
objectives, risk tolerance, and overall investment strategy. APA may use other securities such as
options as well to help diversify a portfolio or seek income when applicable.
C. Client Tailored Services and Client Imposed Restrictions
• APA will tailor a program for each individual client. This will include an interview session to learn
the client’s specific needs and requirements as well as an investment plan that will be executed
by APA on behalf of the client. APA may use model allocations together with a specific set of
recommendations for each client based on their personal restrictions, risk tolerance, needs, and
targets.
D. Assets Under Management
• As of December 31, 2023, APA oversees approximately $1,531,775,500 in assets under
management and advisement on behalf of its clients and the firm’s sub-advisory business. This
number includes assets under management of approximately $376,010,463 in discretionary
assets and $1,065,036 in non-discretionary strategies. APA oversees approximately
$1,154,700,000 in advisory assets which are non-managed strategies powered by APA’s research
and investment management services, portfolio construction analytics, model portfolios,
outsourced Chief Investment Officer support, or other non-managed investment assignments.
• As of Dec 31, 2023, there was $57,655,950 in assets in the AXS Astoria Inflation Sensitive ETF
(Ticker is PPI) and $69,420,000 in assets in the Astoria US Quality Kings ETF (Ticker is ROE).