View Document Text
Item 1 - Cover Page
A & I Financial Services, LLC
Doing Business As
A & I Wealth Management
9605 Kingston Court, Suite 190
Lone Tree, CO 80112
(303) 690-5070
WWW.ASSETSANDINCOME.COM
Date of Brochure: March 16, 2026
____________________________________________________________________________________
This brochure provides information about the qualifications and business practices of A & I Financial
Services LLC dba A & I Wealth Management. If you have any questions about the contents of this
brochure, please contact us at (303) 690-5070. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about A & I Wealth Management is also available on the Internet at
www.adviserinfo.sec.gov. You can view information on this website by searching for A & I Wealth
Management’s name or by using its CRD number: 148357.
*Registration as an investment advisor does not imply a certain level of skill or training.
Item 2 – Material Changes
The firm will ensure that clients receive a summary of any material changes to this and subsequent
Disclosure Brochures within 120 days after the firm’s fiscal year end—December 31. This means clients
will receive the summary of material changes no later than April 30 each year. At that time, A & I Wealth
Management will also offer a copy of its most current Disclosure Brochure and may also provide other
ongoing disclosure information about material changes as necessary.
On March 16, 2026 we submitted our annual updating amendment filing for fiscal year 2025. We have
updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management of
approximately $506,347,455, and non-discretionary assets under management of approximately
$53,650,659.
We have made technical amendments to Advisory Services (Item 4) and Fees and Compensation (Item
5) adding disclosure pertaining to the use of Sub-Advisers.
In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item
8) of the document to disclose additional material investment risks (Item 8) pertaining to Securities
Backed Lines of Credit (SBLOCs) and Artificial Intelligence ("AI") Risk.
We have made technical amendments to Other Financial Industry Activities and Affiliations (Item 10) to
clarify disclosures regarding Insurance Sales.
We removed disclosures under Code of Ethics, Participation in Client Transactions and Personal Trading
(Item 11) regarding the advisory council for The Denver Foundation, an unaffiliated charitable foundation.
The individual responsible for this activity is no longer affiliated with our firm.
Clients and prospective clients can receive the most current Disclosure Brochure for A & I Wealth
Management at any time by contacting Karl Frank at (303) 690-5070.
2
A & I Wealth Management
Disclosure Brochure 03/16/2026
Item 3 – Table of Contents
Item 1 - Cover Page ...................................................................................................................................... 1
Item 2 – Material Changes ............................................................................................................................ 2
Item 3 – Table of Contents ............................................................................................................................ 3
Item 4 – Advisory Business ........................................................................................................................... 5
General Description of Primary Advisory Services ................................................................................... 5
Asset Management Services ................................................................................................................ 5
Use of Third Party Money Managers .................................................................................................... 6
Financial Planning Services (Plans and Consultations) ....................................................................... 7
Limits of Advice to Certain Types of Investments ..................................................................................... 8
Tailor Advisor Services to Individual Needs of Clients ............................................................................. 9
Wrap-Fee Program versus Portfolio Management Program .................................................................... 9
Client Assets Managed by Advisor ........................................................................................................... 9
Item 5 – Fees and Compensation ................................................................................................................. 9
Asset Management Services .................................................................................................................... 9
Use of Third Party Money Managers ...................................................................................................... 11
Consultations (Limited and Ongoing) ...................................................................................................... 13
Additional Fees and Expenses ............................................................................................................... 14
Compensation for the Sale of Securities or Other Investment Products ................................................ 14
Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................... 15
Item 7 – Types of Clients ............................................................................................................................ 16
Minimum Investment Amounts Required ................................................................................................ 16
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 16
Methods of Analysis ................................................................................................................................ 16
Technical ............................................................................................................................................. 16
Trend Following ................................................................................................................................... 16
Cyclical ................................................................................................................................................ 16
3
A & I Wealth Management
Disclosure Brochure 03/16/2026
Fundamental ....................................................................................................................................... 17
Investment Strategies ............................................................................................................................. 17
Risk of Loss ............................................................................................................................................. 17
Primary Method of Analysis or Strategy .................................................................................................. 18
Primarily Recommend One Type of Security .......................................................................................... 22
Item 9 – Disciplinary Information ................................................................................................................. 22
Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 22
Securities Sales ...................................................................................................................................... 22
Insurance Sales ...................................................................................................................................... 22
Recommendation of Other Advisers ....................................................................................................... 23
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 23
Code of Ethics ......................................................................................................................................... 23
Item 12 – Brokerage Practices .................................................................................................................... 24
Research and Other Soft Dollar Benefits ................................................................................................ 24
Investment Advisor Services, Money Manager X-Change Program Participation ................................. 25
Brokerage for Client Referrals ................................................................................................................ 25
Directed Brokerage ................................................................................................................................. 25
Block Trades ........................................................................................................................................... 26
Item 13 – Review of Accounts..................................................................................................................... 26
Account Reviews ..................................................................................................................................... 26
Account Reports ...................................................................................................................................... 27
Item 14 – Client Referrals and Other Compensation .................................................................................. 27
Item 15 – Custody ....................................................................................................................................... 27
Item 16 – Investment Discretion ................................................................................................................. 28
Item 17 – Voting Client Securities ............................................................................................................... 28
Item 18 – Financial Information ................................................................................................................... 29
Class Action Lawsuits ................................................................................................................................. 29
Customer Privacy Policy ............................................................................................................................. 29
4
A & I Wealth Management
Disclosure Brochure 03/16/2026
Item 4 – Advisory Business
General Description of Primary Advisory Services
A & I Financial Services, LLC, doing business as A & I Wealth Management (“A & I Wealth Management”
or “we”) is a registered investment adviser based in Lone Tree, CO. We are organized as a limited liability
company under the laws of the State of Colorado. We have been providing investment advisory services
since 2009. A & I Holdings, LLC is the principal owner of A & I Financial Services LLC. Currently, we
offer the following investment advisory services, which are personalized to each individual client:
• Asset Management Services
• Use of Sub Advisors
• Use of Third Party Money Managers
• Financial Planning Services (Plans and Consultations)
• Retirement Plan Services
Asset Management Services
We offer investment supervisory services defined as giving continuous investment advice to you (or
making investments for you) based on your individual needs, goals and objectives. Through this service,
we offer a customized investment program providing you with advice regarding allocation among various
asset classes, ongoing assistance with evaluation and selection of investments, and adjustment and
balancing of portfolios. We meet with you to conduct a detailed financial analysis and assess your
financial situation, financial goals and risk tolerance. Based on this analysis, we select portfolio strategist
and investment managers. The portfolio strategist and investment managers may be representatives
associated with us, they may be sub-advisors who provide model portfolio recommendations, or they may
be registered with outside money managers with whom we have relationships. We manage multiple
model portfolios that utilize different asset mixes and trading strategies. A client account may participate
in several model portfolios or a single model portfolio. We continuously monitor and review each model
portfolio and implement block trades when we determine that investment changes are required.
Recommendation of Sub Adviser(s)
As part of our overall investment management strategy, we normally manage money internally for each
client, but we may recommend sub adviser(s) to manage all or a portion of your account. All sub advisers
recommended by our firm must either be registered as investment advisers or exempt from registration
requirements. Factors that we take into consideration when making our recommendations include, but
are not limited to, the following: the sub adviser’s performance, methods of analysis, fees, your financial
needs, investment goals, risk tolerance, and investment objectives. The sub adviser(s) will actively
manage your portfolio and will assume discretionary investment authority over your account(s). We will
periodically monitor the sub adviser’s performance to ensure its management and investment style
remains aligned with your investment goals and objectives.
You may be required to sign an agreement directly with the sub adviser(s). You may terminate your
advisory relationship with the sub adviser(s) according to the terms of your agreement with the sub
adviser(s). You should review each sub adviser’s Form ADV Brochure for specific information on how
you may terminate your advisory relationship with the sub adviser and how you may receive a refund, if
applicable. You should contact the sub adviser directly for questions regarding your advisory agreement
with the sub adviser.
5
A & I Wealth Management
Disclosure Brochure 03/16/2026
Use of Third Party Money Managers
As part of our overall asset management strategy, we may also recommend third party money managers
or programs to manage all or a portion of your account. All third party money managers recommended by
our firm must either be registered as investment advisers or exempt from registration requirements. We
will periodically monitor the third party investment advisor’s performance to ensure its management and
investment style remains aligned with your investment goals and objectives.
After gathering information about your financial situation and objectives, we will recommend that you
engage a specific third-party money manager or investment program. Factors that we take into
consideration when making our recommendation(s) include, but are not limited to, the following: the
money manager’s performance, methods of analysis, fees, your financial needs, investment goals, risk
tolerance, and investment objectives.
Where we are appointed as your agent to buy and sell securities or other investments for your account on
a discretionary basis, you delegate to A & I Wealth Management the authority to retain one or more third
party investment advisor(s) to provide all, or a portion, of the discretionary management services with
respect to your account. We shall have the discretion to hire and fire any third party investment advisor.
To the extent you participate in a specific program offered by A& I Wealth Management that is provided
through a third party investment advisor or platform, the investments that are available to you through that
program may be limited to certain types of securities. You may not be able to impose investment
restrictions with respect to the securities and other assets that are purchased for, or held in, the account
by such third party investment advisor(s).
In some cases, you may be required to sign an agreement directly with the third party investment
advisor(s). In which case, you may terminate your advisory relationship with the third investment
advisor(s) according to the terms of your agreement with the third party investment advisor(s). You should
review each third party investment advisor’s brochure for specific information on how you may terminate
your advisory relationship with the third party investment advisor and how you may receive a refund, if
applicable. You should contact the third party investment adviser directly for questions regarding your
agreement with the third party investment adviser. Our representatives are available to answer questions
regarding your account. Our representatives also act as the communication conduit between you and the
third-party investment advisors.
Third party managed programs generally have account minimum requirements and these minimum
requirements vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts. A complete description of the third-party
investment advisor’s services, fee schedules and account minimums are disclosed in the third-party
investment advisor’s Disclosure Brochure that is provided to clients at the time an agreement for services
is executed and an account established. The type and frequency of reports provided to clients will also
depend upon the third-party investment advisor selected.
Third-party investment advisors may take discretionary authority to determine the securities to be
purchased and sold for the client. In some instances, we may be considered a sub-advisor because we
are responsible for the initial and on-going suitability review and are also responsible for maintaining your
current information. The third-party investment advisor may also use other sub-advisors in providing
management and other advisory services to your accounts.
Recommendation of Variable Annuities
We offer discretionary asset management of variable annuity portfolios through Nationwide Advisory
Solutions. The Nationwide platform gives us access to a large range of investment strategies and
securities. Investments are determined by the investment adviser representative managing the account
and in accordance with the client’s investment objectives. Variable annuities managed through the
Nationwide Advisory Solutions platform are fee based and do not incur commission charges. For its
services as custodian, Nationwide Advisory Solutions charges a flat monthly insurance charge of $20
6
A & I Wealth Management
Disclosure Brochure 03/16/2026
without regard to the size of account. Specifics regarding the annuities are found in the annuities’
prospectuses and application documents.
Financial Planning Services (Plans and Consultations)
A & I Wealth Management offers financial planning services that focus on your specific needs and
concerns. The services may be comprehensive in nature (focusing on your overall financial situation, risk,
goals, and objectives) or they may be modular in nature (focusing on specific areas of concern that you
have.) Financial planning services may include giving advice on investment and non-investment related
matters. For example, we also conduct business exit strategy planning on a stand-alone basis.
Additionally, we offer consulting services in regard to your specific needs and concerns and this can
include both investment and non-investment matters. Consultations can also include specialized
business exit planning services. Consultation services can be contracted on a case-by-case basis
(limited) or on an on-going basis. You have sole discretion whether or not to implement any
recommendation from us. It is your responsibility to notify us if there are any changes in your financial
situation or investment objectives that could affect the advice provided by us.
We collect a variety of information from you that is necessary to perform the requested services. We
gather the information to review your current financial condition, assist you in determining your attitude
toward risk and identify your financial goals, objectives and challenges. Financial data that we gather and
review may include statements and account data from banks, broker/dealers and mutual funds, as well as
tax returns and insurance policies. Depending on the level and scope of the financial planning
engagement, we may also review wills and trusts. We rely on the information provided by you. Therefore,
it is important the information you provide is complete and accurate. Neither we nor our investment
advisor representatives (“representatives”) are responsible for verifying the information you provide. In
addition, if authorized by you, we will gather information or documentation from your other professionals
and are expressly authorized to rely on the information provided. We urge you to work closely with your
attorney, accountant or other professionals regarding your financial and personal situation.
We meet with you to discuss our recommendations and outline steps you must take to implement those
recommendations. Although financial planning services are provided with the intention that you will
implement the recommendations contained in the plan, you are not obligated to do so. You retain
discretion over implementing decisions relating to financial planning services and are free to accept or
reject any recommendation from us. It is your responsibility to notify us of any changes in your financial
situation or investment objectives. You should notify us of any changes so that we can work with you to
determine if the changes will affect the advice provided by us. Together, we will determine if you wish to
engage us to review, evaluate and revise previous recommendations.
Retirement Plan Services
A & I Wealth Management offers retirement plan services to retirement plan sponsors and to individual
participants in retirement plans. Our services can include, but are not limited to, the following:
• Preparation of Investment Policy Statement. An Investment Policy Statement (“IPS”) is a
document drafted for the purpose of determining an investment philosophy for the retirement plan
investment program which may exceed the tenure of the various individuals charged with
managing it. The IAR assists The Plan in the preparation and implementation of a suitable IPS.
• Non-Discretionary Investment Advice. Advisor provides non-discretionary investment advice
regarding assets classes and investment options, consistent with the plan’s investment policy
statement.
7
A & I Wealth Management
Disclosure Brochure 03/16/2026
• Default Investment Alternative Advice. We provide non-discretionary investment advice to assist
with development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg.
Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who
otherwise fail to make an investment election. The Plan Sponsor retains the sole responsibility to
provide all notices to participants required under ERISA Section 404(c)(5).
•
Investment Recommendations. IAR recommends, for selection by the Plan, an array of
investments to be offered under the Plan consistent with the policies outlined in the IPS.
•
Investment Monitoring. IAR monitors the plan investments and determine their suitability pursuant
to the criteria set forth in the IPS. When appropriate, IAR will recommend, for selection by the
Plan, suitable replacement investments.
• Performance Reports. IAR prepares and presents reports evaluating the performance of plan
investments pursuant to the criteria set forth in the IPS.
• Participant Enrollment and Education. IAR conducts retirement plan investment education
seminars and individual (one-on-one) meetings with participants for the purpose of providing
them with the opportunity to take full advantage of the benefits provided by the retirement plan.
A & I Wealth Management acknowledges that in performing the services it is acting as a limited scope
“fiduciary” as defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974
(“ERISA”) for purposes of providing non-discretionary investment advice only. A & I Wealth Management
acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and
circumstances, such services cause A & I Wealth Management to be a fiduciary as a matter of law.
However, in providing the fiduciary consulting services, A & I Wealth Management (a) has no
responsibility and does not (i) exercise any discretionary authority or discretionary control respecting
management of the client’s retirement plan, (ii) exercise any authority or control respecting management
or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or
discretionary responsibility in the administration of the client’s retirement plan or the interpretation of
retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and
does not have the power to manage, acquire or dispose of any plan assets and (c) is not the
“Administrator” of the retirement plan as defined in ERISA.
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 interests ahead of yours.
All recommendations are submitted to the client for ultimate approval or rejection. It is the client’s
responsibility to evaluate the Advisor’s recommendations and make changes to the plan itself.
Limits of Advice to Certain Types of Investments
We offer advice on equity securities, corporate, municipal and government debt securities, certificates of
deposit, investment company securities, and others.
We also advise on certain investment products such as variable life insurance and annuity contracts, and
assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, we direct or recommend the allocation of Client assets among the various investment options
available with the product. Client assets are generally maintained at either the insurance company or the
custodian designated by the product’s provider.
8
A & I Wealth Management
Disclosure Brochure 03/16/2026
Additionally, we may advise you on types of investments that we deem appropriate 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.
You may request that we refrain from investing in particular securities or certain types of securities. You
must provide these restrictions to our firm in writing.
Tailor Advisor Services to Individual Needs of Clients
We provide services based on your specific needs. You are given the ability to impose restrictions on
your accounts, including specific investment selections and sectors. However, we will not enter into an
investment advisor relationship with a client whose investment objectives may be considered
incompatible with our investment philosophy or strategies or where the prospective client seeks to impose
unduly restrictive investment guidelines.
Wrap-Fee Program versus Portfolio Management Program
In traditional management programs, advisory services are provided for a fee but transaction services are
billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction
services are provided for one fee. We do not act as a portfolio manager of or sponsor wrap fee
programs.
Client Assets Managed by Advisor
As of December 31, 2025, we manage $506,347,455 in client assets on a discretionary basis, and non-
discretionary assets under management of approximately $53,650,659.
Item 5 – Fees and Compensation
Asset Management Services
If you decide to engage A & I Wealth Management for asset management services, we will charge an
annual fee based upon a percentage of the market value of the assets being managed. Our fee for asset
management services is set forth in the following fee schedule:
Assets Under Management
Annual Fee
Under $100,000
$100,000 to $250,000
$250,001 to $2,000,000
$2,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $15,000,000
$15,000,001 to $20,000,000
$20,000,001 to $25,000,000
$25,000,001 to $30,000,000
$30,000,001 to $999,999,999
1.50%
1.25%
1.00%
0.90%
0.80%
0.65%
0.50%
0.40%
0.35%
0.30%
Fees are typically billed monthly in arrears and are typically calculated based on the average daily
account balance. The initial fee charge begins the first day the account is funded. Certain third-party
money managers charge fees in arrears or in advance. Fees are prorated based on the number of days
that services are provided. The above fee schedule is negotiable based on the amount of assets under
management, the complexity of your financial situation, the complexity of the assets maintained in the
account, and other relationships we have with you. The exact fee charged is disclosed to you in the asset
9
A & I Wealth Management
Disclosure Brochure 03/16/2026
management agreement signed by you prior to receiving services. Certain assets maintained in the
account may be exempted from management fees. For example, if we have recommended the purchase
of a commissionable security or insurance product and our representatives implement the
recommendation and earn a commission in their separate capacities as registered representatives, we do
not charge a management fee on such assets until they have been held for 24 months. In these
instances, if the assets are or will be considered managed assets, we may begin earning fees in the 25th
month after the date of purchase.
At our discretion, we may combine the account values for accounts held at our primary custodian for
individuals or family members in the same household to determine the applicable advisory fee. For
example, we may combine account values for you and your children, joint accounts with your spouse, and
other types of related accounts. Combining account values may increase the asset total, which may result
in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated
above. Accounts that are grouped by household for fee determination do not include the value of
commissionable products, such as life insurance policies, annuities, and/or brokerage products.
We assist you in establishing a managed account(s) through a qualified custodian. Typically, we require
a minimum account size of $10,000 to establish and maintain a managed account. Exceptions may be
granted to this account minimum at our discretion. We may grant exceptions based on accounts held by
members of the same household, anticipated future deposits, history with the client, and other reasons.
Certain programs offered by us require that you use a particular custodian to maintain the managed
account. If you wish to contract with us for asset management services, you are required to use only
those broker/dealers and custodians approved by us. Additionally, our representatives are also
registered representatives with Geneos Wealth Management, Inc. (Geneos), a dually registered
investment advisor and broker/dealer. Due to our representatives’ relationship with Geneos, we are
limited to using Geneos as a broker/dealer or any custodian or broker/dealer that Geneos has approved
for advisory activities.
Negotiability of Fees
We allow investment advisor representatives servicing the account to negotiate the exact investment
management fees within the range disclosed in our Form ADV Part 2A Brochure with management
approval. As a result, the Associated Person servicing your account may charge more or less for the
same service than another Associated Person of our firm. Further, our annual investment management
fee may be higher than that charged by other investment advisors offering similar services/programs.
Billing on Cash Positions
The firm treats cash and cash equivalents as an asset class. Accordingly, all cash and cash equivalent
positions (e.g., money market funds, etc.) are included as part of assets under management for purposes
of calculating the firm’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for defensive,
liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could
miss market advances and, depending upon current yields, at any point in time, the firm’s advisory fee
could exceed the interest paid by the client’s cash or cash equivalent positions.
Periods of Portfolio Inactivity
The firm has a fiduciary duty to provide services consistent with the client’s best interest. As part of its
investment advisory services, the firm will review client portfolios on an ongoing basis to determine if any
changes are necessary based upon various factors, including but not limited to investment performance,
style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s
investment objectives. Based upon these and other factors, there may be extended periods of time when
the firm determines that changes to a client’s portfolio are neither necessary nor prudent.
Notwithstanding, the firm’s annual investment advisory fee will continue to apply during these periods,
and there can be no assurance that investment decisions made by the firm will be profitable or equal any
specific performance level(s).
10
A & I Wealth Management
Disclosure Brochure 03/16/2026
You must provide written authorization to have fees deducted from your managed account. Geneos may
serve as the paying agent for us and may retain a portion of the advisory fee for administrative, support,
and other services it provides to us.
Either of us may terminate the asset management client agreement at any time by providing written
notice to the appropriate party. If services are terminated within five business days of executing the
agreement, services are terminated without penalty and no fees are due. If services are terminated after
the initial five-day period, termination takes effect thirty days after such written notice is delivered or at a
later date if so stated in the notice of termination. The final fee is prorated based on the number of days
that services are provided prior to the effective date of the termination. You are responsible for paying
fees for services rendered until the effective date of termination.
Recommendation of Sub Adviser(s)
Sub-adviser(s) charge clients an asset-based fee on amounts invested in the sub-adviser’s investment
strategies. Sub-advisory fees currently range from 0.25% to 0.50% of account balances. The asset-based
fee is charged quarterly in arrears. Sub-adviser(s) collect fees directly from client account(s) pursuant to
the terms of the sub-advisory agreement with each client.
We will also charge clients a fee in addition to the sub-advisory fee charged to clients for assets held in
sub-advisory investment strategies. Clients utilizing a sub-adviser may pay a higher aggregate fee than if
the investment advisory services were purchased separately. Advisory fees that you pay to a sub-adviser
are established and payable in accordance with the Form ADV Brochure provided by each sub-adviser to
whom you are referred. These fees may or may not be negotiable. Depending on the sub-adviser, clients
may or may not be able to negotiate the fee payable to the third-party adviser.
Use of Third Party Money Managers
Fees are charged as previously discussed under Asset Management Services, above. The third-party
investment advisor and/or the platform service provider automatically deducts the fees from the account.
The actual fee charged to you varies depending on the third-party investment advisor selected. The fee
will range from 0.30% to 2.75% annually of your total account value. The maximum advisory fee paid to
us is 1.50%. Fees are calculated and collected by the selected third-party investment advisor. Fees are
paid either through the platform service provider or to Geneos as our paying agent, and Geneos then
pays the fee to us. Geneos may also receive a portion of the fee for administrative, support, and other
services it provides to us.
Advisory services provided in such a manner may have fees higher or lower than if you obtained similar
services separately. Therefore, we have a conflict of interest since third party investment advisor
arrangements provide a financial incentive to recommend third party investment advisors with whom we
have more favorable compensation arrangements. Nevertheless, we mitigate this conflict since we are a
fiduciary and are obligated to act in your best interests. We also have policies and procedures in place
that require us to perform due diligence on third party investment advisors to ensure that we make every
effort to recommend a third party investment advisor that is appropriate for you based on the facts and
circumstances you disclose to us including, but not limited to, your risk tolerance, financial objectives, and
financial circumstances.
You may also incur additional charges imposed by third parties in connection with investments made
through the account. The third-party money manager may participate in these fees. You should review
the investment prospectuses and/or disclosure brochures for all fees and expenses. Additional charges
may include but are not limited to, mutual fund sales loads, 12b-1 fees and surrender charges and IRA
and qualified retirement plan fees. We do not receive any portion of such commissions or fees. We are
only compensated by the fees described above, and do not receive any other compensation in
11
A & I Wealth Management
Disclosure Brochure 03/16/2026
connection with your account. When we negotiate lower fees and expenses charged by third parties, all
negotiated improvements are for your benefit.
Any third-party investment advisors recommended by us must be registered or exempt from registration in
the state where you reside. You should know that there may be other third party managed programs that
may be suitable to you and that may be more or less costly. No guarantees can be made that your
financial goals or objectives will be achieved. Further, no guarantees of performance can be offered.
Investments involve risk, including the possible loss of principal.
You can terminate these services without penalty by providing notice within five business days of signing
the Agreement. Termination is effective 30 days after the written notice is delivered, or such later date as
the parties may state in the notice. Our representatives will continue any work in progress but will not
begin any new services during the 30-day period. You are responsible for fees until the effective date of
termination.
Recommendation of Variable Annuities
We charge an annualized portfolio management fee of assets under management in variable annuity
products in accordance with the portfolio management fee schedule listed above. The fees are negotiable
and are billed monthly in arrears based on the average daily account balance. If the advisory agreement
is executed at any time other than the first day of a billing cycle, our fees will apply on a pro rata basis,
which means that the advisory fee is payable in proportion to the number of days in the billing cycle for
which you are a client.
We will deduct our fee directly from a designated investment account through the qualified custodian
holding your funds and securities. We will deduct our advisory fee only when you have given us written
authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will
deliver an account statement to you at least quarterly. The account statements will show all
disbursements from your account. You should review all statements for accuracy.
The portfolio management agreement between you and A & I Wealth Management will continue in effect
until either party terminates the investment management agreement in accordance with the terms of the
investment management agreement. A & I Wealth Management 's annual fee will be pro-rated through
the date of termination. Refunds are not applicable since fees are payable in arrears.
For its services as custodian, Nationwide Advisory Solutions charges a flat monthly insurance charge of
$20. It does not charge an upfront sales charge, surrender charges, commission paid on sale, or mortality
costs. All custodial charges will be deducted from investment account, as applicable, and retained by the
custodian.
Financial Planning Services
Financial planning fees generally range from $500 to $25,000 and are negotiable based on the scope of
the services provided and the anticipated time to complete the services, your financial situation,
expectations and goals, and our relationship with you. A retainer of 50% of the quoted fee is due at the
time you sign the client agreement with the remainder due upon presentation of the plan, unless both
parties agree to a different payment schedule. We provide a quote for services before beginning any
work.
Financial planning services terminate upon presentation of the plan. Either of us can terminate the client
agreement at any time by providing written notice to the other party. Termination is effective upon receipt
of the notice. If services are terminated within five business days of executing a client agreement,
services are terminated without penalty. You are responsible for paying fees for the services completed
prior to notice of termination. The fee is calculated as a percentage of work completed on the requested
plan prior to the effective date of termination. We provide you with a billing statement that details the
prorated fee and any refund due to you or additional fees due from you.
12
A & I Wealth Management
Disclosure Brochure 03/16/2026
Consultations (Limited and Ongoing)
Fees for limited consulting services generally range from $500-$25,000 and are negotiable based on the
scope of the services provided and the anticipated time to complete the services, your financial situation,
expectations and goals and our relationship with you. A retainer of 50% of the quoted fee is due at the
time you sign the client agreement with the remainder due upon presentation of the plan, unless both
parties agree to a different payment schedule.
Fees for on-going consultation services are charged at the end of each quarter at a rate of up to $2,500
per quarter. Fees are negotiable based on the scope of the services provided and the anticipated time to
complete the services, your financial situation, expectations and goals and our relationship with you. If
you enter into a client agreement at any time other than the beginning of a quarter, we charge you an
initial fee prorated based on the number of days that services are provided during the quarter.
Both limited and on-going consultation services terminate upon completion of the requested services.
Either of us can terminate services at any time by providing written notice to the other party. Termination
is effective upon receipt of the notice. If services are terminated within five business days of executing
the client agreement, services are terminated without penalty. You are responsible for paying fees for the
services completed prior to notice of termination. For limited consultations, the prorated fee is calculated
based on the percentage of requested consultations completed. For on-going consultations, the prorated
fee is based on the number of days services were provided prior to receipt of the termination notice. We
provide you with a billing statement that details the prorated fee due from you.
IRA Rollover Considerations
As a normal extension of financial advice, we provide education or recommendations related to the
rollover of an employer-sponsored retirement plan. A plan participant leaving employment has several
options. Each choice offers advantages and disadvantages, depending on desired investment options
and services, fees and expenses, withdrawal options, required minimum distributions, tax treatment, and
the investor's unique financial needs and retirement plans. The complexity of these choices may lead an
investor to seek assistance from us.
An Associated Person who recommends an investor roll over plan assets into an Individual Retirement
Account (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in
the plan. Thus, we have an economic incentive to encourage an investor to roll plan assets into an IRA.
In most cases, fees and expenses will increase to the investor as a result because the above-described
fees will apply to assets rolled over to an IRA and outlined ongoing services will be extended to these
assets.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interests
and not put our interest ahead of yours. At the same time, the way we make money creates some
conflicts with your interests.
Commission and Fee Offset
Our representatives are also registered representatives of Geneos Wealth Management, Inc. (“Geneos”),
a dually registered broker/dealer and investment advisor. Geneos and A & I Wealth Management are not
related entities. If you elect to have our representatives implement the advice provided as part of the
financial planning or consulting services, this may be done by them in their separate capacities as
registered representatives. This situation represents a conflict of interest because our representatives
could receive fees for the advice and could also receive commissions for implementing the
13
A & I Wealth Management
Disclosure Brochure 03/16/2026
recommendations in their separate capacity as registered representatives. You are not obligated to
implement the advice provided by us or to implement transactions through our representatives or the
broker/dealer with which they are registered. You are free to select any broker/dealer or registered
representative to implement the recommendations provided by us.
If you do implement through us, commissions and fees charged by Geneos and our advisory fees may be
higher or lower than at other broker/dealers and investment advisors. Registered representatives with
Geneos that are also representatives with us may have a conflict of interest if you purchase securities
through Geneos because the higher their production with Geneos the greater potential they have for
obtaining a higher pay-out on commissions earned. Further, registered representatives are restricted to
only offering those products and services that have been reviewed and approved for offering to the public
by Geneos and for which Geneos has obtained a selling agreement, if applicable.
If you elect to implement our advice through one of our asset management programs described in this
disclosure brochure, we may waive or reduce the financial planning or consulting fees as a result of the
on-going fees that we will earn for asset management services. Additionally, if you choose to implement
our advice through one of our representatives in their separate capacities as registered representatives or
insurance agents, or through us as a licensed insurance agency, we may waive or reduce the financial
planning or consulting fee as a result of the commissions our representatives will earn in those separate
capacities.
Additional Fees and Expenses
Administrative fees, account maintenance fees, brokerage commissions, transaction ticket fees, and/or
other trading fees and account fees charged by the custodian are billed directly to you by the custodian.
These fees and charges vary depending on account type and size. We do not receive any portion of
such commissions or fees from the custodian or from you. You may incur other charges imposed by third
parties besides us in connection with investments made through the account including, but not limited to,
mutual fund sales loads, 12(b)-1 fees, contingent deferred sales charges and surrender charges, short
term redemption fees, variable annuity fees and surrender charges, and IRA and qualified retirement plan
fees. Our management fees are separate and distinct from the fees and expenses charged by
investment company securities that we may recommend to you. A description of these fees and
expenses are available in each investment company security’s prospectus.
To the extent mutual funds are selected to fill components of the overall investment strategy, the asset
management fee previously referenced does not include the customary fees and expenses associated
with investing in mutual funds or other costs of establishing and maintaining an account with mutual funds
including 12(b)-1 fees and expenses. You are advised that in addition to our management fee, each
mutual fund in which assets are invested will incur separate investment advisory fees and other expenses
for which the client will bear a proportionate share. A description of these fees and expenses is available
in each investment company security’s prospectus.
Our advisory fees are separate and distinct from these other fees and we do not receive or share in a
portion of such fees. However, our representatives, in their separate capacities as registered
representatives of Geneos, may receive a portion of the 12(b)-1 fees. You should be aware that these
12(b)-1 fees come from fund assets, and thus, indirectly from your assets. Receiving these fees could
represent an incentive for registered securities agents to recommend funds with 12(b)-1 fees or higher
12(b)-1 fees over funds with no fees or lower fees, therefore creating a potential conflict of interest. Our
representatives only recommend mutual funds to you if such mutual funds are suitable for you and
appropriate for fulfilling your objectives.
Compensation for the Sale of Securities or Other Investment Products
As discussed previously, some of our representatives are also registered representatives of Geneos
Wealth Management, Inc. (Geneos), a dually registered broker/dealer and investment advisor. If you
14
A & I Wealth Management
Disclosure Brochure 03/16/2026
elect to implement our recommendations and select our representatives to implement the transactions,
they may earn commissions when selling securities in this separate capacity. You are not obligated to
implement the advice provided by us or to implement transactions through our representatives. You are
free to select any broker/dealer or registered representative to implement the recommendations provided
by us.
Certain Executive officers and other Associated Persons of our firm are licensed as independent
insurance agents. These persons will earn commission-based compensation for selling insurance
products, including insurance products they sell to our clients. Insurance commissions earned by these
persons are separate from and in addition to our advisory fees. The sale of insurance instruments and
other commissionable products offered by Associated Persons are intended to complement our advisory
services. However, this practice presents a conflict of interest because persons providing investment
advice on behalf of our firm who are insurance agents have an incentive to recommend insurance
products to you for the purpose of generating commissions rather than solely based on your needs. We
address this conflict of interest by recommending insurance products only where we, in good faith,
believe that it is appropriate for the client’s particular needs and circumstances and only after a full
presentation of the recommended insurance product to our client. In addition, we explain the insurance
underwriting process to our clients to illustrate how the insurer also reviews the client’s application and
disclosures prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers
advisory services are informed that they are under no obligation to purchase insurance services. Clients
who do choose to purchase insurance services are under no obligation to use our licensed Associated
Persons and may use the insurance brokerage firm and agent of their choice.
Where fixed annuities are sold, clients should also note that the annuity sales may result in substantial
up-front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities
contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can
have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments
only and are not available for cash surrender or in a death benefit unless specified in the annuity contract.
In some annuity products, fees can apply when using an income rider. Annuity guarantees are based on
the financial strength and claims-paying ability of the issuing insurance company. We urge our clients to
read all insurance contract disclosures carefully before making a purchase decision. Rates and returns
mentioned on any program presented are subject to change without notice. Insurance products are
subject to fees and additional expenses.
Please be aware that if we recommend the purchase of a commissionable security or insurance product
and our representatives implement that transaction and earn a commission in their separate capacities as
registered representatives and/or insurance agents, we do not charge a management fee on those
managed assets until they have been held for 24 months. In these instances, if the assets are or will be
considered managed assets, we may begin earning fees in the 25th month after the date of purchase.
Comparable Services
We believe our fees for advisory services are reasonable with respect to the services provided and the
fees charged by other investment advisors offering similar services. However, lower fees for comparable
services may be available from other sources.
Item 6 – Performance-Based Fees and Side-By-Side Management
Performance-based fees are defined as fees based on a share of capital gains on or capital appreciation
of the assets held in a client’s account. We do not receive performance-based fees.
15
A & I Wealth Management
Disclosure Brochure 03/16/2026
Item 7 – Types of Clients
We provide investment advice to the following types of clients:
Individuals (including high net worth individuals)
•
• Pension and profit sharing plans
• Trusts, estates, or charitable organizations
• Corporations or business entities other than those listed above
Minimum Investment Amounts Required
For managed accounts held at Axos Advisor Services, there is a minimum of $10,000 to establish an
account. At our discretion, we may open or retain accounts with less than the required minimum due to
factors such as other related accounts, anticipated future deposits, and history with the client.
Third party managed programs generally have account minimum requirements and these minimum
requirements vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We may use technical, cyclical, trend following and fundamental analysis when considering investment
strategies and recommendations. In simple terms, charting looks at historical patterns, cyclical analysis
looks at recurring periods, fundamental analysis involves analyzing company characteristics and technical
analysis studies past market data looking for price trends and movements. We may also use trend
following when managing assets.
Technical
This method of evaluating securities analyzes statistics generated by market activity, such as past prices
and volume. Technical analysts do not attempt to measure a security's intrinsic value, but instead use
charts and other tools to identify patterns that can suggest future activity. Technical analysts believe that
the historical performance of stocks and markets may indicate future performance.
Trend Following
This strategy tries to take advantage of long-term moves that appear to be playing out in various markets
and could result in profits or losses from both the ups and down of the markets. Traders using trend
following are not aiming to forecast or predict specific price levels but identify and participate in a trend.
This trading method involves risk management and looks at the number of shares held, the current
market price and the current market volatility.
Cyclical
Cyclical analysis looks at recurring periods of expansion and contraction that can impact a company’s
profitability and cash flow. There are a variety of cycles that can be examined and some are more
commonly known than others, such as a four-year presidential cycle or annual/quarterly fiscal reporting
cycles. Identifying cycles can help to anticipate tops and bottoms and also to determine trends. But
sometimes cycles don’t repeat themselves, sometimes they overlap and sometimes they offset each
other. Cyclical stocks tend to rise quickly when the economy turns up and fall quickly when the economy
16
A & I Wealth Management
Disclosure Brochure 03/16/2026
turns down (e.g., housing, automobiles, telecommunications, paper, etc. Non-cyclical industries (e.g.,
food, insurance, drugs, health care, etc.) are not as directly impacted by economic changes.
Fundamental
Fundamental analysis is a method of evaluating a company or security by attempting to measure its
intrinsic value. In other words, fundamental analysts try to determine its true value by looking at all
aspects of the business, including both tangible factors (e.g., machinery, buildings, land, etc.) and
intangible factors (e.g., patents, trademarks, “brand” names, etc.). Fundamental analysis also involves
examining related economic factors (e.g., overall economy and industry conditions, etc.), financial factors
(e.g., company debt, interest rates, management salaries and bonuses, etc.), qualitative factors (e.g.,
management expertise, industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity
and price-to-equity ratios).
The end goal of performing fundamental analysis is to produce a value that an investor can compare with
the security's current price in hopes of figuring out what sort of position to take with that security
(underpriced = buy, overpriced = sell or short). This method of security analysis is considered to be the
opposite of technical analysis. Fundamental analysis is about using real data to evaluate a security's
value. Although most analysts use fundamental analysis to value stocks, this method of valuation can be
used for just about any type of security.
Investment Strategies
When implementing investment advice to clients, we may employ the following investment strategies:
• Long term purchases (securities held at least a year.)
• Short term purchases (securities sold within a year.)
• Trading (securities sold within 30 days.)
Risk of Loss
Investing in securities involves a risk of loss that you should be prepared to bear, including loss of your
original principal. You should be aware that past performance of any security is not necessarily indicative
of future results. Therefore, you should not assume that future performance of any specific investment or
investment strategy will be profitable. We do not provide any representation or guarantee that your goals
will be achieved.
Investing in securities involves risk of loss. Further, depending on the different types of investments,
there may be varying degrees of risk:
• Market Risk. Either the market as a whole, or the value of an individual company, goes down,
resulting in a decrease in the value of client investments. This is referred to as systemic risk.
• Political Risk. Investment returns may be affected by political changes or instability in a country.
Instability affecting investment returns could stem from civil unrest, terrorist acts, changes in
government and foreign policy makers, or military control.
• Equity (Stock) Market Risk. Common stocks are susceptible to fluctuations and to volatile
increases/decreases in value as their issuers’ confidence in or perceptions of the market change.
Investors holding common stock (or common stock equivalents) of any issuer are generally
exposed to greater risk than if they hold preferred stock or debt obligations of the issuer.
• Company Risk. There is always a certain level of company or industry specific risk when
investing in stock positions. This is referred to as unsystematic risk and can be reduced through
17
A & I Wealth Management
Disclosure Brochure 03/16/2026
appropriate diversification. There is the risk that a company may perform poorly or that its value
may be reduced based on factors specific to it or its industry (e.g., employee strike, unfavorable
media attention).
• Preferred Securities Risk. Preferred Securities have similar characteristics to bonds in that
preferred securities are designed to make fixed payments based on a percentage of their par
value and are senior to common stock. Like bonds, the market value of preferred securities is
sensitive to changes in interest rates as well as changes in issuer credit quality. Preferred
securities, however, are junior to bonds with regard to the distribution of corporate earnings and
liquidation in the event of bankruptcy. Preferred securities that are in the form of preferred stock
also differ from bonds in that dividends on preferred stock must be declared by the issuer’s board
of directors, whereas interest payments on bonds generally do not require action by the issuer’s
board of directors, and bondholders generally have protections that preferred stockholders do not
have, such as indentures that are designed to guarantee payments – subject to the credit quality
of the issuer – with terms and conditions for the benefit of bondholders. In contrast preferred
stocks generally pay dividends, not interest payments, which can be deferred or stopped in the
event of credit stress without triggering bankruptcy or default. Another difference is that preferred
dividends are paid from the issuer’s after-tax profits, while bond interest is paid before taxes.
• Fixed Income Risk. Investing in bonds involves the risk that the issuer will default on the bond
and be unable to make payments. In addition, individuals depending on set amounts of
periodically paid income face the risk that inflation will erode their spending power. Fixed-income
investors receive set, regular payments that face the same inflation risk.
• ETF and Mutual Fund Risk. ETF and mutual fund investments bear additional expenses based
on a pro-rata share of operating expenses, including potential duplication of management fees.
The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying
securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing
ETFs.
• Management Risk. Your investments also vary with the success and failure of our investment
strategies, research, analysis and determination of portfolio securities. If our strategies do not
produce the expected returns, the value of your investments will decrease.
Primary Method of Analysis or Strategy
We employ the strategies of selected research firms. Other strategies are technical analysis, cyclical
analysis, and trend following. One of the risks involved with using these methods is frequent trading of
securities. Frequent trading can affect investment performance, particularly through increased
transaction costs and possibly taxes. Other risks include the chance that investments may lose value and
results may not be correlated to broader market indices.
Active Management Risk: The success of a client’s account that is actively managed depends upon the
investment skills and analytical abilities of the portfolio manager to develop and effectively implement
strategies that achieve the client’s investment objective. Subjective decisions made by the portfolio
manager may cause a client portfolio to incur losses or to miss profit opportunities on which it may have
otherwise capitalized.
Concentrated Position Risk. Certain investment advisor representatives may recommend that clients
concentrate account assets in an industry or economic sector. In addition to the potential concentration of
accounts in one or more sectors, certain accounts may, or may be advised to, hold concentrated
positions in specific securities. Therefore, at times, an account may, or may be advised to, hold a
relatively small number of securities positions, each representing a relatively large portion of assets in the
account. As a result, the account will be subject to greater volatility than a more sector diversified
portfolio. Investments in issuers within an industry or economic sector that experience adverse economic,
18
A & I Wealth Management
Disclosure Brochure 03/16/2026
business, political conditions or other concerns will impact the value of such a portfolio more than if the
portfolio’s investments were not so concentrated. A change in the value of a single investment within the
portfolio will affect the overall value of the portfolio and may cause greater losses than it would in a
portfolio that holds more diversified investments.
Cyclical Analysis Risk: Economic/business cycles may not be predictable and may have many
fluctuations between long term expansions and contractions. The lengths of economic cycles may be
difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting
economic trends and consequently the changing value of securities that would be affected by these
changing trends.
Environment, Social, and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social and governance (ESG) investment criteria it may avoid purchasing certain
securities for ESG reasons when it is otherwise economically advantageous to purchase those securities,
or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold
those securities. In general, the application of the portfolio’s ESG investment criteria may affect the
portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the
financial performance of the portfolio, positively or negatively, depending on whether these issuers,
industries, sectors or geographic areas are in or out of favor. An adviser can vary materially from other
advisers with respect to its methodology for constructing ESG portfolios or screens, including with respect
to the factors and data that it collects and evaluates as part of its process. As a result, an adviser’s ESG
portfolio or screen may materially differ from or contradict the conclusions reached by other ESG advisers
concerning the same issuers. Further, ESG criteria are dependent on data and are subject to the risk that
such data reported by issuers or received from third-party sources may be subjective, or it may be
objective in principle but not verified or reliable.
Liquidity Risk: A client portfolio is exposed to liquidity risk when trading volume, lack of a market maker or
trading partner, large position size, market conditions, or legal restrictions impair its ability to sell particular
investments or to sell them at advantageous market prices. Consequently, a client portfolio may have to
accept a lower price to sell an investment or continue to hold it or keep the position open, sell other
investments to raise cash or give up an investment opportunity, any of which could have a negative effect
on the portfolio’s performance. These effects may be exacerbated during times of financial or political
stress.
Recommendation of Third-Party Investment Advisers Risk: In the event we recommend a third-party
investment adviser to manage all or a portion of your assets, we will advise you on how to allocate your
assets among various classes of securities or third-party investment managers, programs, or managed
model portfolios. We may rely on investment model portfolios and strategies developed by the third-party
investment advisers and their portfolio managers. If there is a significant deviation in characteristics or
performance from the stated strategy and/or benchmark, we may recommend changing models or
replacing a third-party investment adviser. The primary risks associated with investing with a third party is
that while a particular third party may have demonstrated a certain level of success in the past; it may not
be able to replicate that success in future markets. In addition, as we do not control the underlying
investments in third party model portfolios, there is also a risk that a third party may deviate from the
stated investment mandate or strategy of the portfolio, making it a less suitable investment for our clients.
A third party’s past performance is not a guarantee of future results and certain market and economic
risks exist that may adversely affect an account’s performance that could result in capital losses in your
account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure,
and associated disclosure documents for details on their specific investment strategies, methods of
analysis, and associated risks.
Use of Certain Securities that Employ Derivative Instruments: Securities that utilize derivative
instruments can lead to liquidity, credit, interest rate and market risks. Investments in derivative
instruments may be subject to greater volatility than investments in traditional securities, including the
high degree of leverage often embedded in such instruments, and potential material and prolonged
19
A & I Wealth Management
Disclosure Brochure 03/16/2026
deviations between the theoretical value and realizable value of a derivative. Some derivatives have the
potential for unlimited loss. Derivatives may at times be illiquid. Certain derivatives may be difficult to
value, and valuation may be more difficult in times of market turmoil. Derivative investments can increase
portfolio turnover and transaction costs. Derivatives also are subject to counterparty risk and credit risk.
New regulation of derivatives may make them more costly, or may otherwise adversely affect their
liquidity, value or performance. In addition, derivatives may be subject to the additional risks, including:
Foreign Currency Forward Contracts Risk, Futures Contracts Risk, Hedging Risk, and Swap Agreements
Risk.
Use of Certain Securities that Employ Commodity positions: This is the risk that exposure to the
commodities markets may subject fund securities (ETFs and Mutual funds) to greater volatility than
investments in traditional securities. The value of physical commodities or commodity-linked derivative
instruments may be affected by changes in overall market movements, commodity price volatility,
changes in interest rates, currency fluctuations, or factors affecting a particular industry or commodity,
such as drought, floods, weather, livestock disease, embargoes, tariffs and international economic,
political and regulatory developments.
Utilization of Alternative Investments: Strategies utilizing alternative investments are generally made with
the objective for long-term appreciation and are subject to limited liquidity. When we invest in securities
not managed by us, we have limited control over the management of such investments. Alternative
investment strategies pursued by the funds may be subject to additional risks including, but not limited to,
derivatives (including options and futures contracts) risk, liquidity risk of underlying securities, credit risk
and commodities risk. Certain alternative strategies involve the risk that a counterparty to a transaction
will not perform as promised, which would incur losses to a fund. Furthermore, alternative strategies may
employ leverage, involve extensive short positions and/or focus on narrow segments of the market, which
may magnify the overall risks and volatility associated with such investments.
For more detailed discussions of the specific risks associated with Alternative Investments, please refer to
the respective prospectuses and Private Placement Memorandum(s). The risk of loss described herein
should not be considered to be an exhaustive list of all the risks which clients should consider.
Interval Fund Risk: We may recommend or purchase shares of interval funds for clients when consistent
with a client’s investment objectives. An interval fund is a type of closed-end fund (mutual fund) that is not
listed on an exchange. Interval funds periodically offer to repurchase a limited percentage of outstanding
shares, as defined in its prospectus, from its shareholders. Interval funds are generally designed for long-
term investors who do not require daily liquidity. Therefore, the shares are subject to periodic redemption
offers by the fund at a price based on net asset value. Accordingly, interval funds are subject to liquidity
constraints. Interval funds that invest in securities of companies with smaller market capitalizations,
derivatives, or securities with substantial market and/or credit risk tend to have the greatest exposure to
liquidity risk. Generally, the interval funds we recommend offer a one to two week period, on a quarterly
basis, during which the client may seek the redemption of previously purchased interval funds. Given the
lack of secondary market, the infrequent nature of the offers to buy back shares, and the liquidity gates
(or re-purchase limits), clients should consider the shares of interval funds to be illiquid. For information
about the material risks associated with the fund’s investment strategies and other disclosures, please
see the fund’s prospectus.
General Risks
Cybersecurity Risks. Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices
designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking
by other computer users, and to avoid the resulting damage and disruption of hardware and software
systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-
attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause
losses to clients by interfering with the processing of transactions, affecting the ability to calculate net
20
A & I Wealth Management
Disclosure Brochure 03/16/2026
asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a
cybersecurity breach, including those associated with forensic analysis of the origin and scope of the
breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information,
litigation, and the dissemination of confidential and proprietary information. Any such breach could
expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be
exposed to additional losses as a result of unauthorized use of their personal information. While our firm
has established a business continuity plan and systems designed to prevent cyber-attacks, there are
inherent limitations in such plans and systems, including the possibility that certain risks have not been
identified. Similar types of cyber security risks are also present for issuers of securities, investment
companies and other investment advisers in which we invest, which could result in material adverse
consequences for such entities and may cause a client's investment in such entities to lose value.
Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in
your account as collateral in return for a loan. The loan proceeds can be used for purposes other than to
purchase or trade securities. Depending on your objectives, we can help you apply for a SBLOC. This
can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business
opportunity, or a personal goal, any of which could trigger capital gain taxes. While we do not receive a
fee for arranging these loans, our assistance in this process presents a conflict of interest, as we have an
incentive for you to maintain these assets in your account instead of liquidating them, as liquidation could
decrease the asset-based fees that we earn for managing your account. To address this conflict, we only
make recommendations to obtain such loans when we believe obtaining a SBLOC is in the best interests
of clients. Clients should note that they retain the ultimate decision to obtain such loans. The following are
some of the primary risks associated with obtaining a SBLOC:
•
Interest rate payments on the principal balance of the loan are not fixed and may increase;
•
If the value of the securities pledged as collateral decrease, you will be liable for any deficiency;
• The lender can force the sale or liquidation of securities held as collateral without contacting you
in advance to meet collateral requirements and you are not entitled to choose which securities
are liquidated or sold;
• You are only entitled to draw on the line to the extent there is credit availability; and
• There may be additional risks when money funds or similar investments may produce less
interest income or other yield than the interest you are paying on the loan.
We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or
non-purpose loan. While we can assist in the application process, we are not involved in the approval
process.
Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine learning,
probabilistic modeling, and other data science technologies ("AI Tools") when delivering our services. AI
Tools are also used to record and transcribe client meetings. Clients should note that AI Tools are highly
complex, and are known to have been flawed, hallucinate, reflect biases included in the data on which
such tools are trained, be of poor quality, or be otherwise harmful. AI Tools present Cybersecurity Risk.
The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and
rapidly evolving, and could require changes in the firm’s implementation of AI Tools and increase
compliance costs and the risk of non-compliance. Further, the firm may rely on AI Tools developed by
third parties, and the firm has limited control over the accuracy and completeness of such AI Tools.
Clients who do not want us to record their meetings have the option to opt out at the time of the meeting.
Pandemic Risk. Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality
over a wide geographic area, crossing international boundaries, and causing significant economic, social,
and political disruption. The long-term impact of such events cannot be predicted because they are
dependent on a variety of factors including the global response of regulators and governments to address
and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental
responses and policies and macroeconomic factors may negatively impact investment returns.
21
A & I Wealth Management
Disclosure Brochure 03/16/2026
Primarily Recommend One Type of Security
We do not primarily recommend only one type of security, such as a single type of mutual fund. We
frequently recommend no-load mutual funds without trade restrictions as well as certain ETFs. Some of
the risks involved with recommending these securities include fund expenses and, for certain funds,
potential tracking error with the indices these funds attempt to mirror. As stated above, ETF and mutual
fund investments bear additional expenses based on a pro-rata share of operating expenses, including
potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects
the risks of owning the underlying securities held by the ETF or mutual fund. You also incur additional
trading costs when purchasing ETFs. Although we generally attempt to purchase funds without short
term redemption fees, these funds may be purchased and, if quickly sold, performance may be adversely
affected.
Item 9 – Disciplinary Information
We have no legal or disciplinary events that are material to your evaluation of our business or the integrity
of our management. Therefore, this item is not applicable to our brochure.
Item 10 – Other Financial Industry Activities and Affiliations
Securities Sales
Some of our representatives are also registered representatives of Geneos Wealth Management, Inc.
(Geneos), a dually registered broker/dealer and investment advisor. In this separate capacity, they can
sell securities to any client and can earn commissions as a result. This is a conflict of interest because
they could receive commissions in their capacity as a registered representative and could also receive
advisory fees in their capacity as an investment advisor representative. You are under no obligation to
use the services of our representatives or Geneos and can select any broker/dealer you wish to
implement securities transactions.
Insurance Sales
Certain Associated Persons of A & I Wealth Management are licensed insurance agents. Our dually
licensed Associated Persons can effect transactions in insurance products and earn commission based
compensation for these activities. Clients are instructed that the fees paid to the firm for advisory services
are separate and distinct from the commissions earned by our other dually licensed Associated Persons.
Receipt of commission-based compensation presents a conflict of interest because our firm and persons
providing investment advice on behalf of our firm who are licensed insurance agents have an incentive to
recommend insurance products to you for the purpose of generating commissions rather than
recommendations made solely based on your needs. We address this conflict of interest by
recommending insurance products only where we, in good faith, believe that it is appropriate for the
client’s particular needs and circumstances and only after a full presentation of the recommended
insurance product to our client. In addition, we explain the insurance underwriting process to our clients in
illustrating how the insurer also reviews the client’s application and disclosures prior to the issuance of a
resulting insuring agreement. Ultimately, all insurance sales are on a non-discretionary basis and are
offered by duly licensed and supervised insurance professionals by our affiliated entity. Clients are under
no obligation contractually or otherwise, to purchase insurance products through any person or entity
affiliated with our firm.
22
A & I Wealth Management
Disclosure Brochure 03/16/2026
Recommendation of Other Advisers
We may recommend that you use a third party money manager or program as part of our asset allocation
and investment strategy. While fees are negotiable, typically, the fees charged by the third party money
manager are higher due to the sharing arrangement. The compensation arrangement presents a conflict
of interest due to a financial incentive to recommend the services of a third party money manager with
more favorable compensation arrangements than others. Fees could be higher than you would otherwise
pay through other providers that do not utilize third party money managers or that have lower fee sharing
arrangements. You are not required, contractually or otherwise, to use the services of any recommended
third party money managers. If you elect to utilize the services of any recommended third party money
manager, please carefully review all disclosures and advisory contracts to fully understand the total
advisory fees you will pay to both A & I Wealth Management and the third party money manager.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
Code of Ethics
Section 204A-1 of the Investment Advisers Act of 1940 requires all investment advisors to establish,
maintain and enforce a Code of Ethics. Advisor has established a Code of Ethics that applies to all of its
associated persons. An investment advisor is considered a fiduciary according to the Investment Advisers
Act of 1940. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of
all material facts and to act solely in the best interest of clients at all times. Advisor has a fiduciary duty to
all clients. This fiduciary duty is considered the core underlying principle for its Code of Ethics, which also
covers its insider trading and personal securities transactions policies and procedures. Advisor requires
all of its supervised persons to conduct business with the highest level of ethical standards and to comply
with all federal and state securities laws at all times. Once employed by or affiliated with Advisor, and at
least annually thereafter, all supervised persons sign an acknowledgement that they have read,
understand and agree to comply with Advisor’s Code of Ethics. Advisor has the responsibility to make
sure that the interests of all clients are placed ahead of its or its supervised persons’ own investment
interests. Advisor fully discloses all material facts and potential conflicts of interest to clients prior to
conducting any services. Advisor and its supervised persons must conduct business in an honest, ethical
and fair manner and avoid all circumstances that might negatively affect or appear to affect its duty of
complete loyalty to all clients. This disclosure is provided to give all clients a summary of Advisor’s Code
of Ethics. However, if a client or a potential client wishes to review Advisor’s Code of Ethics in its entirety,
a copy is provided promptly upon request.
In addition to abiding by Advisor’s Code of Ethics, our Certified Financial Planner® designees abide by
the Code of Ethics and Responsibility Code of the Certified Financial Planner™ Board of Standards, Inc.
The Code of Ethics and Responsibility Code requires CFP® designees to not only comply with all
applicable laws and regulations but to also act in an ethical and professional responsible manner in all
professional services and activities. The principles guiding CFP® designees are:
•
Integrity
• Objectivity
• Competence (in providing services and maintaining knowledge and skills to do so)
• Fairness (to clients, principals, partners and employers and disclosing any conflicts of interest in
providing services)
• Confidentiality (keeping all client information confidential without the specific client consent unless
in response to legal process or in defense of charges of wrongdoing or civil dispute)
• Professionalism
• Diligence
You can obtain a copy of the Code of Ethics and Responsibility Code by requesting a copy from one of
our representatives.
23
A & I Wealth Management
Disclosure Brochure 03/16/2026
Participation or Interest in Client Transactions
We and our representatives may buy or sell securities or have an interest or position in a security for our
personal accounts that are also recommended to clients. A & I Wealth Management is and shall continue
to be in compliance with The Insider Trading and Securities Fraud Enforcement Act of 1988. As these
situations may represent a potential conflict of interest, it is our policy that all persons associated in any
manner with us must place your interests ahead of their own when implementing personal investments.
We will not buy or sell securities for our personal accounts where our decision is derived, in whole or in
part, by information obtained as a result of our employment unless the information is also available to the
investing public upon reasonable inquiry. To help minimize the conflict of interest, most securities
recommended by A & I Wealth Management are widely held and publicly traded.
Item 12 – Brokerage Practices
While you are free to choose any custodian or other service provider, we recommend that you establish
an account with a custodian with which we have an existing relationship. Such relationships may include
benefits provided to our firm, including but not limited to, research, market information, and administrative
services that help our firm manage your account(s). We believe the recommended custodians provide
quality execution services for our clients at competitive prices. Price is not the sole factor we consider in
evaluating best execution. We also consider the quality of the brokerage services provided by
recommended custodians, including the value of provided research, the firm's reputation, execution
capabilities and responsiveness to our clients and our firm. In recognition of the value of research
services and additional products and services the recommended custodians provide, you may pay higher
execution costs than those that may be available elsewhere.
Axos Advisor Services as Custodian
Axos Advisor Services is the primary custodian for A & I Wealth Management. Clients benefit from Axos
Advisor Services’ favorable trading costs, ability to access accounts, ability to household accounts for fee
billing purposes and trading platform. A & I Wealth Management will recommend that clients establish
advisory accounts with Axos Advisor Services to maintain custody of clients' assets and to effect trades
for their accounts.
Axos Advisor Services offers clients an asset management account in which A & I Wealth Management
has a platform for IARs and clients to develop portfolios with a variety of assets. These assets may
include, but are not limited to: no-load mutual funds, load waived mutual funds, equities, exchange traded
funds, fixed income securities, partnerships, cash and cash equivalents. Custody of assets and funds is
maintained through an agreement with Axos Advisor Services. All transactions are cleared pursuant to
the Advisor’s agreement with Axos Advisor Services.
Research and Other Soft Dollar Benefits
Although not considered “soft dollar” compensation, A & I Wealth Management may receive various
benefits from custodians for research services, reports, software, and institutional trading support.
In some cases, the Firm(s) we recommend for custodial services may charge a higher fee for a particular
type of service, than can be obtained from another broker. Clients may utilize the custodian of their choice
and have no obligation to purchase or sell securities through the custodian(s) that A & I Wealth
Management recommends.
We may receive other economic benefits that create a conflict of interest. For example, we may receive
from a broker-dealer or other financial institution, without cost, computer software and related systems
support, which allows us to better monitor client accounts maintained at that financial institution (“other
24
A & I Wealth Management
Disclosure Brochure 03/16/2026
economic benefit”). We may receive the software and related support without cost because it renders
investment management services to clients that, in the aggregate, maintain a certain level of assets at
that financial institution. While these arrangements do not qualify as soft dollar arrangements, they
present a conflict of interest for an advisor. An advisor has the incentive to direct client transactions to the
financial institution that will provide it with the most other economic benefits. If the advisor utilizes the
services of a financial institution that provides the advisor with economic benefits, it will not be deemed to
breach its fiduciary duty to its clients even if the clients pay a commission higher than the lowest
commission available to obtain such economic benefits so long as certain conditions are met. These
conditions include the requirement that such other economic benefit is in the best interest of the clients
and that the benefit is disclosed to clients.
Examples of other economic benefits that we may receive include:
• Access to a trading desk that provides for specialized services
• Access to block trading
• Access to an electronic system for client order entry and account information
• Software, research, or other tools in connection with the delivery of investment advisory services
We take seriously our obligation of best execution for client transactions. It is a catalyst in deciding about
a particular broker/dealer or custodian. While quality of execution at the best price is an important
consideration, best execution does not necessarily mean lowest price and it is not the sole consideration.
The trading process of any broker/dealer or custodian suggested by us must be efficient, seamless and
straight-forward. Overall custodial support services, trade correction services and statement preparation
are some of the other factors we consider when suggesting a broker/dealer. We do not have any soft
dollar arrangements.
Investment Advisor Services, Money Manager X-Change Program Participation
A & I Wealth Management participates in the Money Manager X-Change program (the “MMX Program”)
offered by Axos Advisor Services. Axos Advisor Services offers to independent investment advisors
services which include custody of securities, trade execution, clearance and settlement of transactions.
The MMX program is a platform service that enables A & I Wealth Management to select third-party
money managers and strategies to assist in meeting client’s investment needs.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such
as brokerage services or research.
Directed Brokerage
If you contract for our asset management services, we must use those custodians and broker/dealers that
have been approved by Geneos. Additionally, some of the programs we utilize may require you to
establish your account with a particular custodian or broker/dealer.
Persons providing investment advice on behalf of our firm who are registered representatives of Geneos
Wealth Management (Geneos) will recommend Geneos to you for brokerage services. These individuals
are subject to applicable rules that restrict them from conducting securities transactions away from
Geneos unless Geneos provides the representative with written authorization to do so. Therefore, these
individuals are generally limited to conducting securities transactions through Geneos. It may be the case
that Geneos charges higher transactions costs and/or custodial fees than another broker charges for the
same types of services. If transactions are executed though Geneos, these individuals (in their separate
capacities as registered representatives of Geneos) may earn commission-based compensation as result
of placing the recommended securities transactions through Geneos. This practice presents a conflict of
interest because these registered representatives have an incentive to effect securities transactions for
25
A & I Wealth Management
Disclosure Brochure 03/16/2026
the purpose of generating commissions rather than solely based on your needs. You may utilize the
broker-dealer of your choice and have no obligation to purchase or sell securities through such broker as,
we recommend. However, if you do not use Geneos, we may not be able to accept your account. Please
see the “Fees and Compensation” section in this Brochure for more information on the compensation
received by registered representatives who are affiliated with our firm.
If you wish to implement our advice, you are free to select any broker/dealer or investment advisor you
wish. If you contract for our asset management services, we must use those custodians and
broker/dealers that have been approved by Geneos. Additionally, some of the programs we utilize may
require you to establish your account with a particular custodian or broker/dealer.
Block Trades
We may elect to purchase or sell the same securities for several clients at approximately the same time.
This process is referred to as aggregating orders, batch trading, or block trading and may be used when
we believe such action may prove advantageous to clients. If and when we aggregate client orders,
allocating securities among client accounts is done on a fair and equitable basis. Typically, the process
of aggregating client orders is done in order to achieve better execution, to negotiate more favorable
commission rates or to allocate orders among clients on a more equitable basis in order to avoid
differences in prices and transaction fees or other transaction costs that might be obtained when orders
are placed independently. Under this procedure, transactions are averaged as to price and are allocated
among clients in proportion to the purchase and sale orders placed for each client account on any given
day. If and when we determine to aggregate client orders for the purchase or sale of securities, including
securities in which our associated persons may invest, we do so in accordance with the parameters set
forth in the SEC No-Action Letter, SMC Capital, Inc. Neither we nor our associated persons receive any
additional compensation or remuneration as a result of blocking trades.
Item 13 – Review of Accounts
Account Reviews
Unless you contract for on-going consultation services, financial planning reviews are performed only
upon a request from you. We recommend that you have your financial plan reviewed at least annually or
more frequently if there are changes that effect your goals, objectives or financial situation. Additional
fees may be charged and a new engagement may be needed if you wish to receive additional reviews.
If you contract for on-going consultation services, you receive a review at least annually to determine if
your objectives are being met. We can perform reviews more frequently if you request it or if you notify us
about a change that triggers a review.
We will monitor your Investment Management accounts on an ongoing basis and will conduct account
reviews at least once annually to ensure the advisory services provided to you are consistent with your
current investment needs and objectives. Additional reviews may be conducted based on various
circumstances, including, but not limited to:
•
contributions and withdrawals,
•
year-end tax planning,
• market moving events,
•
•
security specific events, and/or,
changes in your risk/return objectives.
We continuously monitor model portfolios regarding asset allocation, fund or security selection, and
rebalancing. Each representative is responsible for reviewing their own accounts and determining when
changes are needed (e.g. changes in suitability or risk tolerance).
26
A & I Wealth Management
Disclosure Brochure 03/16/2026
Account Reports
You receive a statement from your account custodian at least quarterly. In addition, accounts managed
by other money managers send you reports as disclosed in their disclosure brochure. You may access
your accounts electronically at any time.
Item 14 – Client Referrals and Other Compensation
Custodial Benefits
As described in Item 12 above, we receive economic benefits from our custodial broker dealer in the form
of support products and services they make available to us and other independent investment advisors
whose clients maintain their accounts at these custodial broker dealers. The availability of custodial
products and services is not dependent upon or based on the specific investment advice we provide our
clients, such as buying or selling specific securities or specific types of securities for our clients. The
products and services provided by the custodial broker dealer, how they benefit us, and the related
conflicts of interest are described above (see Item 12 – Brokerage Practices).
As disclosed under the “Fees and Compensation” section in this Brochure, persons providing investment
advice on behalf of our firm are licensed insurance agents and are registered representatives with
Geneos, a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the
Securities Investor Protection Corporation. For information on the conflicts of interest this presents, and
how we address these conflicts, please refer to the “Fees and Compensation” section.
From time to time, we may receive expense reimbursements for travel and/or marketing expenses from
distributors of investment and/or insurance products; however, these do not constitute soft dollar
arrangements. Travel expense reimbursements are typically a result of attendance at due diligence
and/or investment training events hosted by product sponsors. Marketing expense reimbursements are
typically the result of informal expense sharing arrangements in which product sponsors may underwrite
costs incurred for marketing such as advertising, publishing, client events, and seminar expenses.
Receipt of these travel and marketing expense reimbursements are not predicated upon specific sales
quotas. The product sponsor reimbursements are typically made by those sponsors for whom sales have
been made or sales may be made in the future. As a part of our fiduciary duty, both we and our
representatives endeavor at all times to put your interests first. However, you should be aware that
receiving additional compensation through nominal sales awards, expense reimbursements, etc. creates
a conflict of interest that may impact the judgment of our representatives when making advisory
recommendations.
Item 15 – Custody
In arrangements where we are permitted and authorized to do so, we will directly debit your account(s) for
the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our
firm to exercise limited custody over your funds or securities. We do not have physical custody of any of
your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other
independent, qualified custodian. You will receive account statements from the independent, qualified
custodian(s) holding your funds and securities at least quarterly. The account statements from your
custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing
period. You should carefully review account statements for accuracy.
You should compare our statements with the statements from your account custodian(s) to reconcile
the information reflected on each statement. If you have a question regarding your account statement
or if you did not receive a statement from your custodian, please contact us at the phone number listed
on the cover of this brochure.
27
A & I Wealth Management
Disclosure Brochure 03/16/2026
Wire Transfer Authority
Our firm or persons associated with our firm may effect third party wire transfers for client accounts
without client written consent per transaction for client accounts. An adviser with authority to conduct
unauthorized third-party wire transfers have access to the client's assets, and therefore has custody of
the client’s assets in any related accounts. Pursuant to Rule 206(4)-2 (the "Custody Rule"), we have
taken steps to have controls and oversight in place to support the no-action letter issued by the SEC
on February 21, 2017 (the "SEC no-action letter"). With respect to third party standing letters of
authorization ("SLOA") where a client may grant us the authority to direct custodians to disburse funds
to one or more third party accounts, we are deemed to have limited custody. However, we are not
required to comply with the surprise examination requirement of the Custody Rule if we are otherwise
in compliance with the seven representations noted in the February 21, 2017 no-action letter.
Where A & I Wealth Management acts pursuant to a SLOA, we believe we are making a good faith effort
to comply with the representations noted in the SEC's no-action letter. Additionally, since many of those
representations involve the qualified custodian's operations, we will collaborate closely with the
custodians to ensure that the representations would be able to be met.
Item 16 – Investment Discretion
In addition to having trading authority on your accounts, we may manage accounts on a discretionary or
non-discretionary basis. If provided on a discretionary basis, this means we make all decisions to buy,
sell or hold securities, cash or other investments in the managed account in our sole discretion without
consulting with you before implementing transactions. You must provide us with written authorization to
exercise this discretionary authority.
When discretionary authority is granted, it is limited. We do not have access to your funds and/or
securities with the exception of having advisory fees deducted from your account and paid to us by the
account custodian. Any fee deduction is done pursuant to your prior written authorization provided to the
account custodian. You have the ability to place reasonable restrictions on the types of investments that
may be purchased in an account. You may also place reasonable limitations on the discretionary power
granted to us so long as the limitations are specifically set forth or included as an attachment to the client
agreement.
If management services are provided on a non-discretionary basis, we contact you before implementing
any transactions in an account. You must accept or reject our investment recommendations, including (1)
the security being recommended, (2) the number of shares or units and (3) whether to buy or sell. Once
these factors are agreed upon, we are responsible for making decisions regarding the timing of the
purchase or sale and the price at which it is bought or sold. You should know that if you are not able to
be reached or are slow to respond to our request, it can have an adverse impact on the timing of
implementing trades and we may not achieve the optimal trading price.
Item 17 – Voting Client Securities
We do not perform proxy-voting services on your behalf. You retain this right and responsibility. You
should read through the information provided with the proxy-voting documents and make a determination
based on the information provided. Upon your request, our representatives may provide limited
clarifications of the issues presented in the proxy voting materials based on their understanding of issues
presented in the proxy-voting materials. However, you have the ultimate responsibility for making all
proxy-voting decisions.
28
A & I Wealth Management
Disclosure Brochure 03/16/2026
Item 18 – Financial Information
This item is not applicable to our brochure. We do not require or solicit prepayment of more than $1,200
in fees per client, six months or more in advance. Therefore, we are not required to include a balance
sheet for its most recent fiscal year. We are not subject to a financial condition that is reasonably likely to
impair our ability to meet contractual commitments to clients. Finally, we have not been the subject of a
bankruptcy petition at any time.
Class Action Lawsuits
You retain the right under applicable securities laws to initiate individually a lawsuit or join a class-action
lawsuit against the issuer of a security that was held, purchased or sold by or for you. We do not initiate
such a legal proceeding on your behalf and do not provide legal advice to you regarding potential causes
of action against such a security issuer and whether you should join a class-action lawsuit. We
recommend that you seek legal counsel prior to making a decision regarding whether to participate in a
class-action lawsuit. Moreover, our services do not include monitoring or informing you of any potential or
actual class-action lawsuits against the issuers of the securities that were held, purchased or sold by or
for you.
Customer Privacy Policy
A & I Financial Services, LLC, dba A & I Wealth Management LLC (“AIWM”, “we”, “us”, or “our”)
values you as a customer and respects your right to privacy. We recognize that you have placed
your trust in us, and we take the responsibility to preserve that trust. One way we endeavor to
keep your trust is to properly handle your personal information.
We pledge to you that:
• Protection of your privacy is a top priority;
• Your account information and all documents you provide to us are protected in a
secure environment;
• We only collect personal information in order to accomplish our customer commitments
•
•
to you;
Information about you is only used and shared in limited and controlled ways; and
In the event that we wish to share information about you with non-affiliated third parties,
you are given options concerning what information may be shared, and your privacy
wishes will be respected. You may also choose to opt out of any information sharing.
AIWM maintains physical, electronic and procedural safeguards to ensure that personal
information we have about you is treated responsibly and in accordance with our privacy policy.
We restrict access to information about you only to those investment advisor representatives and
employees who need to know that information in order to provide products and services to you or
to conduct business. Representatives or employees who have access to the information may only
use it for legitimate business purposes. In addition, we take steps to safeguard information about
you in accordance with applicable data security regulations.
We collect personal information about you from these sources:
• New Account Application, applications for the purchase of various products, and other
forms;
• Product vendors, as a result of your transactions with us; and/or
• Depending on the product you are requesting to purchase, information received from
consumer reporting agencies, medical providers or others.
We may disclose the following categories of information to entities that perform administrative
services on our behalf or as required or permitted by law for legal, regulatory, or other purposes:
29
A & I Wealth Management
Disclosure Brochure 03/16/2026
•
•
•
Information you provide directly to us on the New Account Application, applications, or
other forms;
Information we receive about your transactions with us or with our product providers;
and/or
If required for the products you purchase, information received from other agencies
such as: consumer reporting agencies concerning your creditworthiness, motor
vehicle and driver’s license reports, medical and employment information, and loss
reports.
We may disclose information about you to our staff, affiliates, representatives, their affiliated
businesses, and third parties who provide you with financial products and services. Nonaffiliated
third parties may include retirement plan sponsors or third party administrators, mutual fund
companies, insurance companies and agencies, other broker-dealers, and clearing firms. Our
privacy policy is the same for current, as well as former clients. If you close your account, in the
process of transferring your investments we may share your information with the new custodian
that you or your advisor selects.
A special note about medical or health information: While we might receive medical or health
information from you at the time of application for various types of insurance, we do not use it or
share it – internally or externally – for any purpose other than what is directly related to the
administration of your policy, account, or claim, as required or permitted by law, or as you
authorize us to do.
We pledge to work to protect the security of your confidential information.
30
A & I Wealth Management
Disclosure Brochure 03/16/2026