ACM is an SEC-registered investment advisor. All services are provided through a “fee-only” arrangement that precludes ACM from earning income from commissions, referral fees, or any other forms of compensation in connection with advice provided to clients. The firm was founded in August 2009 by Mark Armbruster, who is the CEO and majority owner of the firm. Process ACM works with clients to set up investment solutions and provide on-going portfolio management services. We start by meeting to discuss our philosophy and to gather information about the client’s personal and financial circumstances. Later, we propose what we believe will be an appropriate investment plan, based upon the client’s unique risk tolerance and return objectives. This plan lays out our recommended asset mix among stocks, bonds, cash, and alternative investments. We try to maintain this asset mix through time, rebalancing to meet asset allocation targets as taxes and other constraints allow. Each portfolio is customized to an individual client’s goals and needs. As described in Item 8, clients’ tax circumstances and other personal preferences are factored into how a portfolio is constructed. For example, if a client expresses a preference to hold a certain security, we will adjust our portfolio management strategy accordingly, while informing the client of the potential risks of such a holding. As a registered investment advisor, ACM acts as a fiduciary in all aspects of its business, including when recommending the rollover or transfer of retirement accounts. Portfolio Management ACM’s core business is the discretionary management of investment portfolios. With a basis in academic research, we pursue the general objectives of broad diversification, risk control, low costs, and tax efficiency in client portfolios. We generally use index or asset class funds.

These may take the form of exchange-traded funds (ETFs) or index mutual funds. We use index-based funds because of their broad diversification, low costs, and tax efficiency. We then employ quantitative analysis that may lead to more sophisticated investment approaches. For example, in our equity portfolios, we try to capture extra return by “tilting” portfolios toward quantitative factors, such as size, value, and momentum. In certain portfolios, we may also try to capture alternative sources of return and risk control through such investments as real estate, commodities, currencies, reinsurance, and various types of alternative investment strategies. The extent to which we apply alternative strategies will vary from client to client. Financial Planning ACM does not charge additional fees for the financial planning advice it offers. Additionally, we do not sell any products or earn any commissions for products recommended to clients. In order to discern an appropriate investment plan, it is necessary for us to ask our clients questions about their personal and financial circumstances. Often this information raises financial planning issues that need to be addressed. While we are not comprehensive financial planners, ACM will discuss these matters with clients and will help align other professional resources if required. For example, we are not able to give tax or legal advice, but we are familiar with many of these issues. We can help identify areas in estate plans, tax strategy, or insurance coverage that could be improved. If the client would like to follow up, we enlist the help of their attorney, CPA, or insurance professional to implement the recommendation. Assets Under Management As of December 31, 2023, ACM managed approximately $698.3 million on a discretionary basis and $44.2 million on a non-discretionary basis.